Japan Post Failed to State Terms to 167 Freelancers. The First Day of the Violation Period Is the Day the Law Took Effect

On 2 September 2026 the Japan Fair Trade Commission issued a recommendation to Japan Post Co., Ltd. under the Act on Ensuring Proper Transactions Involving Specified Entrusted Businesses.

There are two parts to it. From 1 November 2024 to 30 June 2025[1], the company failed to promptly state all or part of the required terms to 167 people. And for 140 people it set no payment due date and did not pay by the day the work was received.

The work entrusted was running training sessions, delivering mail and similar items[1].

The period deserves a second look. 1 November 2024 is the day this law took effect.

The duty to state terms sits at the very start of a transaction

The law took effect on 1 November 2024. It sets out protections for individuals who take on entrusted work.

The first of its duties is Article 3, the duty to state the terms of the transaction. What is being entrusted, how much will be paid, and when. That has to reach the other party promptly, in writing or electronically.

The order matters. Without a stated amount and date, the duties that follow cannot stand up. A late payment, a reduction, an unreasonably low price — each can be judged only against terms that were agreed in the first place.

FY2025 brought ten recommendations, and all ten involved unstated terms

The commission publishes how the law is being enforced each year.

There were 10 recommendations in FY2025[2]. The breakdown by type of violation runs as follows. Failure to state transaction terms in 10 cases, failure to pay by the due date in 9, reduction of remuneration in 1, and improper demands for economic benefit in 1[2].

Ten recommendations, ten of which involved unstated terms. Every one.

Include guidance and the denominator grows. There were 1,542 guidance actions in FY2025[2]. As for reports, 604 reports were made to the commission in FY2025 alleging facts constituting a violation of the Act[2].

The content of the 1,552 measures is published too. Failure to pay by the due date was the most common at 1,135 cases (41.6%), followed by failure to state transaction terms at 1,126 (41.3%) and unreasonably low payment at 250 (9.2%)[2].

The top two account for more than eight in ten. When payment is due, and what the terms were.

With no first document, nothing after it can be checked

There is a reason the duty to state terms turns up in every case.

To judge a late payment you need a due date. To judge a reduction you need an original amount. To judge an unreasonably low price you need a figure to compare with the usual rate.

Stating the terms is the duty that makes the other duties testable. Remove it and the rest exist on paper while nobody can point to a breach.

The Japan Post case shows that order plainly. 167 people had no statement of terms, and 140 had no due date. How far the two groups overlap has not been published, but it is hard to picture a due date being honoured for someone who was never told the terms.

It started on the day the law began

The start of the period carries its own meaning.

The violation runs from 1 November 2024 to 30 June 2025, and that first day is the day the law took effect.

This needs reading carefully. Nothing under this law can be a violation before it came into force, so the start of the period coinciding with the effective date could not have fallen on any other day. It may simply mark where the commission's review began.

Something still remains. This was not a rollout that drifted out of line after a while. Within the eight months beginning on the very first day the rules operated, 167 engagements went out without their terms stated. The assumption that paperwork switches over when a law takes effect was not holding there.

The larger an organisation, the more its ordering paperwork scatters across sites. A training instructor and a delivery worker are engaged through different desks and different habits. If each desk keeps ordering the way it always has, a change in the law does not change the forms. Assuming one internal notice flips everything at once is the assumption furthest from practice.

What the numbers show is one part of the iceberg

604 reports, 1,542 guidance actions, 10 recommendations. It is worth being clear about how those relate.

Reports come from freelancers approaching the commission. Guidance actions outnumber them, so the commission is also investigating without waiting to be told. To that extent the machinery works.

What stays invisible is what never became a report. For someone taking on entrusted work, reporting a client to the authorities sits next to the risk of losing the next job. And with no written terms, it is hard even to frame what to report.

As 10 years of consultations on financial hardship reached 3.456 million, with plans drawn up for 26.6%（このサイトの記事） showed, the number that reaches the entrance of a scheme is not the number of people in difficulty. Only what arrives gets recorded.

The take-up problem set out in the common structure of unreached populations（このサイトの記事） appears here in the same shape. There is distance between holding a right and being able to exercise it.

Why it is built on recommendations rather than penalties

Enforcement here runs on guidance and recommendations. An order follows a recommendation that is ignored, and penalties follow a breach of the order. It does not open with criminal sanctions.

That mirrors Japan's subcontract transaction law, which changed its name at the start of 2026. The amended Subcontract Act came into force on 1 January 2026, and the name of the law changes as well (new short name: Toriteki Act)[3]. The name changed; the design of correcting terms without stopping the trade did not. For someone receiving work, a client being punished and having work next month are not the same thing. There has to be a route that fixes the terms while the relationship continues.

For that design to work, though, something has to hold. Violations have to be found. A transaction with nothing in writing leaves only memory and assertion. That failures to state terms turn up most often is partly because this is the one duty whose breach shows up from outside, as an absence of documents.

What to count in order to judge next

Two figures are worth following as the law enters its third year.

The first is whether the same clients keep receiving measures. Whether 1,542 guidance actions mean 1,542 clients or a smaller number repeatedly changes the remedy. The former calls for spreading the standard forms; the latter calls for individual correction.

The second is whether the share of unstated-terms violations falls. In FY2025 it was 41.3% of all measures. If the share holds while the count rises, what is growing is detection rather than misconduct. If the share falls, the forms have reached the desks.

Both can be tracked within what the commission already publishes each year. Only with three years side by side does it become visible what this law changed.

Stating the terms is the first thing you do in a transaction.

When that first step is missing, how is either party supposed to prove what was agreed?

Further Reading

• 労働法はフリーランスを守れるか (Can Labour Law Protect Freelancers?)（外部サイト、新しいタブで開きます） (Yoko Hashimoto, Chikuma Shobo). An examination of whether people who take on work as individuals fall within the protections of labour law, set against developments in Europe and the United States. The act behind this recommendation governs the fairness of transactions, which is a separate line from protection as a worker, and this book helps locate where that line runs.

References

Recommendation to Japan Post Co., Ltd. (2 September 2026) — Japan Fair Trade Commission (2026). Japan Fair Trade Commission

Enforcement of the Act on Ensuring Proper Transactions Involving Specified Entrusted Businesses in FY2025 (10 June 2026) — Japan Fair Trade Commission (2026). Japan Fair Trade Commission

Act on Ensuring Proper Transactions Involving Specified Entrusted Businesses: Pamphlet — Japan Fair Trade Commission (2024). Japan Fair Trade Commission