Tokushoho for bilingual e-commerce and SaaS: what foreign founders get wrong

Japanese summary / 日本語要約: 特定商取引法（Tokushoho）は、日本での電子商取引・SaaSサービスに適用される消費者保護開示法です。住所・価格・キャンセルポリシーなど6つの必須項目を掲載する専用ページが必要です。詳細は消費者庁公式サイトまたはJETROをご参照ください。

You launched your SaaS in Japan. You accepted your first Stripe payment. Two weeks later, a user filed a complaint with the 消費者庁 (Japan Consumer Affairs Agency) because your tokushoho disclosure was missing.

This is a real scenario, and it happens to foreign founders more often than you'd think. Not because they're building bad products — but because 特定商取引法 (Act on Specified Commercial Transactions, commonly called "tokushoho") doesn't exist in most Western markets, so there's no cultural awareness of it.

Here's what you need to know.

What is tokushoho?

特定商取引法 is Japan's consumer protection law governing commercial transactions. It was originally designed for door-to-door sales and mail-order in the 1970s, and it has been updated multiple times to cover internet commerce, subscription services, and digital downloads.

The law requires that any business selling goods or services to consumers in Japan publicly disclose a specific set of information about the business and the transaction. This must appear on a dedicated page on your website — typically linked from the footer as 「特定商取引法に基づく表記」.

Who does it apply to? Any business conducting "specified commercial transactions" with Japanese consumers. This includes:

• →E-commerce (physical goods or digital downloads)
• →Subscription SaaS products
• →Online services with recurring billing
• →Membership sites

What are the penalties? The Minister of Economy, Trade and Industry can issue business improvement orders and, in serious cases, suspension orders. More practically: consumer complaints to the 消費者庁 can trigger audits. Chargebacks from Japanese credit card issuers often reference missing tokushoho disclosure as a reason.

If you're a foreign company with no Japanese entity, you're still subject to this law for transactions with Japanese consumers.

The six required fields (and the practical nuances)

1. Seller name (販売業者)

Your legal business name. If you're operating as a foreign company, you can use your legal entity name. If you're a sole proprietor, your legal name is required — but there is a provision that allows you to disclose an address-to-name lookup process instead of your name directly, if disclosing your name creates a safety concern (the 住所非公開 provision applies here too).

2. Business address (住所)

This is the one that surprises most foreign founders. You must disclose a physical business address. If you're operating as a foreign company, the address can be your company's registered address abroad — but it must be specific enough that a consumer could contact you by mail.

The 住所非公開 provision: If disclosing your physical address creates a genuine security concern (common for sole proprietors operating from a home address), you can instead state: 「消費者から請求があった場合には遅滞なく開示します」 — "will be disclosed promptly upon request from a consumer." This is an official exception that has been in the law since 2022. Use it if you need it; it's legitimate.

3. Contact method (連絡先)

A phone number and/or email address. Phone is technically required by the letter of the law, but in practice, a clearly displayed email address with a stated response time is generally accepted for software/SaaS products. If you have a Japanese phone number, list it.

4. Pricing (販売価格)

You must display prices inclusive of consumption tax (消費税, currently 10%). If your pricing is in USD, you can display USD prices but should note the tax treatment. For B2B SaaS targeting Japanese corporations: if you are a qualified invoice issuer (インボイス制度に登録), you should display your registration number.

The consumption tax presentation matters more than most foreign founders realize. Japanese consumers expect to see a price with the explicit notation that tax is included, e.g., ¥880,000（税込）. "¥800,000 + tax" is technically acceptable but is a worse experience.

5. Payment method and timing (支払方法・支払時期)

List all accepted payment methods (credit card / Stripe, bank transfer, etc.) and when payment is collected (at subscription start, at kickoff, at milestone delivery). This must match how your Stripe implementation actually works — don't say "billed monthly" if you have milestone-based payments.

6. Cancellation and return policy (返品・キャンセルについて)

For SaaS products, you typically cannot offer returns on digital services — this is fine and legally supported. You need to state your cancellation terms clearly: notice period required, what happens to pre-paid amounts, and when service ends. If you have a minimum term, it must be disclosed here.

The qualified invoice issuer requirement (インボイス制度): If you're selling to Japanese businesses (B2B), your customers may need your qualified invoice issuer registration number to claim input tax credits. If you're not registered, B2B customers will be paying 10% consumption tax on your invoices without being able to recover it — which affects your competitiveness against registered domestic competitors. Whether to register is a business decision, but you need to know it exists.

A minimal Next.js implementation

Here's the structure for a bilingual tokushoho page in Next.js App Router with next-intl:

// src/app/[locale]/tokushoho/page.tsx
import { getTranslations } from 'next-intl/server';
 
type Props = { params: Promise<{ locale: string }> };
 
export default async function TokushohoPage({ params }: Props) {
  const { locale } = await params;
  const t = await getTranslations('tokushoho');
 
  const sections = t.raw('sections') as { title: string; body: string }[];
 
  return (
    <div className="max-w-3xl mx-auto px-4 py-24">
      <h1 className="text-2xl font-bold mb-2">{t('title')}</h1>
      <p className="text-sm text-gray-500 mb-12">{t('subtitle')}</p>
      <dl className="space-y-8">
        {sections.map((section) => (
          <div key={section.title} className="border-t pt-6">
            <dt className="font-semibold text-sm mb-2">{section.title}</dt>
            <dd className="text-sm text-gray-600 whitespace-pre-line">{section.body}</dd>
          </div>
        ))}
      </dl>
    </div>
  );
}

The key implementation notes:

• →whitespace-pre-line preserves the multi-line formatting of the body content without requiring HTML markup in your JSON files.
• →Both /tokushoho (EN) and /ja/tokushoho (JA) should be served — Japanese consumers landing on your JA site must see a Japanese disclosure page; English-speaking consumers appreciate an English version.
• →The page should be linked from the footer with the standard label: 特定商取引法に基づく表記 in the JA footer, and Legal Disclosure or Tokushoho in the EN footer.

The disclosure structure in JSON

// messages/ja.json — tokushoho section
{
  "tokushoho": {
    "title": "特定商取引法に基づく表記",
    "subtitle": "...",
    "sections": [
      { "title": "販売業者", "body": "ZeroEn\n代表者：Daito Kojima" },
      { "title": "住所", "body": "請求があった場合には遅滞なく開示します。" },
      { "title": "電話番号", "body": "080-XXXX-XXXX" },
      { "title": "販売価格", "body": "スターター：¥380,000（税込）\nグロース：¥880,000（税込）" },
      { "title": "支払方法", "body": "クレジットカード決済（Stripe）" },
      { "title": "支払時期", "body": "マイルストーンベース。" },
      { "title": "返品・キャンセルについて", "body": "キックオフ前50%返金、着手後返金不可。" }
    ]
  }
}

This pattern works for both static and dynamically-updated disclosure pages. If pricing changes, update the JSON — the page renders automatically.

The practical checklist before going live

Before your first Japanese payment, verify:

• →[ ] /tokushoho (EN) and /ja/tokushoho (JA) routes exist and are publicly accessible
• →[ ] Both pages are linked from the footer with the correct label
• →[ ] Business address is disclosed (or the 住所非公開 statement is in place)
• →[ ] Pricing includes 消費税 notation (税込)
• →[ ] Cancellation policy matches your actual Stripe configuration
• →[ ] If selling B2B: you've decided whether to register as a qualified invoice issuer

One more thing

This post covers the structure. It doesn't replace legal advice for your specific situation — particularly if you have a Japanese entity, if you're handling physical goods, or if you're in a regulated industry.

If you're launching in Japan and you're not sure whether your site meets tokushoho requirements, I do a free 20-minute review call as part of the ZeroEn scoping process. I've built tokushoho compliance into every client project — I know the edge cases.

Book a scoping call →