Risk of recommendations and criminal penalties for violations of the Act on Optimization of Transactions between Small and Medium-sized Entrusted Businesses

「The amended law took effect on 1 January 2026, adding employee-count criteria to the requirements for a business to qualify as an entrusting business or small and medium-sized entrusted business under the law, and newly making transactions involving designated transport outsourcing subject to the law. …Entrusting businesses found to have violated the law may be subject to recommendations and publication of their names by the Japan Fair Trade Commission, while violations including failure to specify order details and failure to prepare and retain documents may be subject to criminal penalties, including a fine of up to ¥500,000.」