JPN FTC Payment of Subcontract Fee


On Feb. 28, JPN FTC proposed revisions re subcontract fee payment.


  • JPN FTC proposed revisions to the Guidance standards when bills are used as a means of payment for subcontract fees, in consideration of business practices and relations.
  • Also the Guidance policies when lump-sum payment method and electronically recorded monetary claims are used as a means of payment for subcontract fees.
  • Follows JPN METI, FTC Feb. 2023 request on appropriate payments, see #164308.
  • Revisions
  • Shorten the period from the payment date of subcontract fees until the date on which money equivalent to the amount of receivables for subcontract fees is paid to a financial institution to within 60 days from within 120 days.
  • Consultation Period
  • Comments by Mar. 28, 2024 for planned effectiveness from Nov. 1, 2024.
  • Apr. 2024 Response to Comments
  • On Apr. 30, 2024, JPN FTC issued consultation feedback after receiving 30 comments.
  • JPN FTC clarified scope, stated that opinions received will be used for future reference.
  • Finalized Guidance standards after making some additional minor adjustments; changes are effective from Nov. 1, 2024 but also involve some transition measures.
  • JPN FTC and JPN METI's Small and Medium Enterprise Agency jointly issued requests to related business organizations, FIs, ministries, and agencies on the same day.
  • For the optimization of payment methods throughout the supply chain, as well as consideration re the financing of businesses working to improve payment methods.
  • Oct. 2024 JPN METI and JPN FTC Joint Warning
  • On Oct. 1, 2024, JPN METI as well as JPN FTC, in preparation for the implementation of the new guidelines above, issued compliance warning to around 600 parent firms.
  • This was issued due to concerns arising re a regular survey under Subcontracting act.
  • The caution/warning is contained in appendix 2; JPN METI as well as JPN FTC will continue to work to improve trading conditions for small and medium-sized businesses.
  • The warning raises the prospect of potential measures such as on-site investigations.

Regulators JPN FTC; JPN METI
Entity Types Corp; IHC
Reference PR 10/1/2024; FS, Rsp, PR, 4/30/2024; CP, PR, 2/28/2024
Functions Compliance; Exams; Financial; Legal; Market Conduct; Reporting; Treasury
Countries Japan
Category
State
Products Corporate; Loan; Payments
Regions AP
Rule Type Final
Rule Date 2/28/2024
Effective Date 11/1/2024
Rule Id 202646
Linked to Rule :164308
Reg. Last Update 10/1/2024
Report Section International

Last substantive update on 10/04/2024