On 6 November 2026 Japan's Consumer Affairs Agency (CAA) announced that it had issued an order under Article 7(1) of the Act against Unjustifiable Premiums and Misleading Representations (the Premiums and Representations Act) against H.I.S.Mobile Co., Ltd., concerning representations for an overseas mobile router rental service supplied by the company. The CAA found that the conduct fell under Article 5(ii) of the Act (misleading representation as to advantageous terms).
This page sets out what the CAA published, together with the statutory wording.
Overview
| Item | Detail |
|---|---|
| Date of announcement and order | 6 November 2026 |
| Issuing authority | Consumer Affairs Agency |
| Addressee | H.I.S.Mobile Co., Ltd. (Shinjuku, Tokyo) |
| Legal basis | Article 7(1), Premiums and Representations Act |
| Provision found applicable | Article 5(ii) |
| Service concerned | "HIS Wi-Fi", an overseas mobile router rental service |
| Medium | The company's own website bearing the name "HIS Wi-Fi" |
The representations and the facts found
The published material covers two types of representation.
| Representation | Period | What the CAA found |
|---|---|---|
| For the "Unlimited Plan": "Spring travel campaign — Wi-Fi Unlimited Plan rental fee 45% OFF (shipping extra), 4 Feb 2025 (Tue) – 8 May (Thu), applications during the campaign period only" | 5 February to 8 May 2025 | Applications made after the stated period could obtain a price with a higher discount rate than applications made during the period |
| "New Year Fair 2026, 18 Dec 2025 (Thu) ▶ 2 Feb 2026 (Mon), limited-time 50% OFF" and "daily rental fee: New Year Fair 50% discount applied!" (the Japanese wording differs slightly between the two periods) | 18 to 25 December 2025, and 26 December 2025 to 2 February 2026 | The pre-discount price, presented as the usual price, had not actually been offered for the service for a considerable recent period |
The CAA stated that the first representation gave the impression that the 45% discount, more advantageous than after the period, was available only to applications made within the stated period.
For the second, the CAA stated that it gave the impression that the pre-discount price was the price usually offered and that the discounted price was cheaper than that usual price.
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Try for free →How the business operates
According to the published material, the company has entered into product brokerage agreements with an agent of a communications device rental business, and also provides the service to consumers on commission from other businesses that have similar agreements with that agent. The company itself decides the content of its website representations.
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What the order requires
- Promptly notify consumers that the representations were misleading as to advantageous terms and violated the Act (the method requires prior approval of the Commissioner of the CAA)
- Take the measures necessary to prevent similar representations and communicate them to officers and employees
- Not make similar representations in future in transactions for the service or similar services
- Report promptly in writing to the Commissioner on the notice given and measures taken
The order also states that a request for administrative review may be filed within three months, and an action for revocation within six months, from the day after the company learned of the order, subject to an outer limit of one year from the day after the order, among other conditions.
Statutory wording
Article 5 of the Act provides that a business must not, in connection with transactions for goods or services it supplies, make any representation falling under any of its items. Item (ii) covers representations that cause general consumers to mistakenly believe that the price or other terms of transaction are substantially more advantageous to the counterparty than the actual terms, or than those of other businesses supplying the same or similar goods or services, and that are found likely to induce customers unjustly and to impede voluntary and rational choice by general consumers.
Article 7(1) provides that where there is conduct violating Article 4 or Article 5, the Prime Minister may order the business to cease the conduct, to take the matters necessary to prevent its recurrence, or to make a public notice or take other necessary measures relating to their implementation. The order may be issued even where the violation has already ceased.
Sources
- Consumer Affairs Agency, announcement of 6 November 2026: https://www.caa.go.jp/notice/entry/047990/
- Published material (PDF): https://www.caa.go.jp/notice/assets/representation_cms210_261106_01.pdf
- Premiums and Representations Act (e-Gov): https://laws.e-gov.go.jp/law/337AC0000000134
This page is compiled from material published by government agencies and from statutory text. Please consult a lawyer where a decision is needed on specific advertising.
