Japan’s Retail Electricity Market: Navigating Disclosure and Documentation Obligations under the Electricity Business Act
September 3, 2025
Key Words: Japan Electricity Business Act, Electricity Retail Market Japan, Retail Electricity Supplier Japan, METI Electricity Regulations, Japan Electricity and Gas Market Surveillance Commission, Retail Guidelines Japan, Electricity Retail Compliance Japan, Customer Explanation Obligation Japan, Documentation Obligation Electricity Japan, Electricity Business Act Amendments 2024, Japan Electricity Contract Requirements, Electricity Retail Font Size Regulation Japan, Electricity Supply Conditions Disclosure Japan, Electronic Delivery Consent Japan, Retail Power Compliance Risks Japan, Japan Electricity Market Entry Compliance
I. Introduction[1]
The Japanese government fully liberalized the retail electricity market in 2016, opening the sector to competition and encouraging a wave of new entrants. As of March 2023, there were 721 retailers, with PPSs (i.e. Shindenryoku) accounting for approximately 17.7 percent of total retail electricity sales,[2] illustrating the growing role of competitive suppliers in Japan’s energy landscape. The number of retailers has continued to rise, reaching 780 companies as of August 25, 2025.[3]
Against this backdrop of market expansion, retail electricity suppliers are required to comply with detailed rules under the Electricity Business Act, its Enforcement Regulations, and the Retail Guidelines. In particular, following the April 2024 amendments to the Act, the obligations to provide explanations to customers and to deliver written documents have been further tightened. Non-compliance can expose suppliers to corrective action or even public disclosure of violations by the Electricity and Gas Market Surveillance Commission.[4]
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[1] This communication is provided as a service to our clients and friends and is for informational purposes only. It is not intended to create an attorney-client relationship or constitute an advertisement, a solicitation, or professional advice as to any particular situation.
[2] Japan Electric Power Information Center, Inc. “The Electric Power Industry in Japan 2024”, P.5, available at https://www.jepic.or.jp/pub/epijpdf.html
[3] See, Agency for Natural Resources and Energy’s disclosure, available at https://www.enecho.meti.go.jp/category/electricity_and_gas/electric/summary/retailers_list/
(accessed on August 25, 2025)
[4] See, e.g., the Electricity and Gas Market Surveillance Commission’s press release dated November 24, 2020, available at https://www.egc.meti.go.jp/info/public/news/20201124001.html