Why can long-standing trust relationships lead to legal violations?

Because customs like oral contracts or shouldering transaction fees to be considerate can now be considered unfair trading environments under the new law.

Are all forms of promissory note payments prohibited under the new law?

Yes, paper promissory notes are universally prohibited for applicable transactions, and electronic claims that disadvantage the contractor are also banned.

What should a company do first?

Companies should first disseminate the law's rules to the front lines and establish internal policies, such as making written contracts mandatory.

freee Releases Survey Results on the SME Outsourcing Fairness Law

Published Jun 6, 2026 12:00 AM ・ Updated Jun 14, 2026 12:08 AM ・ 4 min read ・ Source: PR TIMES

freee K.K. conducted a survey three months after the enactment of the SME Outsourcing Fairness Law. The results revealed that one in three respondents are unaware of the law, and about 30% of businesses continue practices like operating without contracts, forcing transaction fee burdens on contractors, or using promissory notes, highlighting how established trust can inadvertently create legal risks.

freee K.K. (Headquarters: Shinagawa-ku, Tokyo; CEO: Daisuke Sasaki; hereinafter "freee") has released the results of a survey regarding the SME Outsourcing Fairness Law (hereinafter "the Law").

To prevent SMEs from being treated unfairly across the supply chain, the former Subcontract Act was fundamentally revised, and the new Law was enacted in January this year. This law clearly mandates the "explicit statement of order details (contracts, etc.) in writing or electronic records" and explicitly prohibits "forcing the contractor to bear bank transfer fees (reduction of payment)" and "promissory note payments." A survey conducted three months after enactment regarding the awareness and status of these practices revealed that ignorance of the law, combined with long-standing trust or consideration for business partners, could inadvertently lead to legal violations.

Survey Overview - Survey Name: Fact-finding survey on the SME Outsourcing Fairness Law - Method: Online questionnaire - Region: Nationwide (Japan) - Participants: 500 respondents from ordering side, 500 from contractor side - Period: March 26 to March 30, 2026

Survey Summary - One in three respondents stated they "do not know about the Law at all." - Approximately 30% of sites continue to operate without written contracts or continue to burden contractors with fees. - Approximately 15% of sites still use promissory note payments, indicating that "business as usual" customs that could be deemed inappropriate still persist.

Expert Commentary Ryohei Igarashi, Attorney at Univis Law Firm, Meguro Office: "All employees in the field need to learn the rules stipulated by the Law as a form of self-defense. Mutual consideration to 'not let the other party become a company that violates the law' will make long-term trust relationships more modern and sustainable."

About freee's Services freee provides the "freee Law Compliance Guide" and "freee Outsourcing Management" to support businesses in achieving full compliance.

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Source: PR TIMES
Category: Survey

freee Releases Survey Results on the SME Outsourcing Fairness Law

⚡ Key Points

Survey Overview - Survey Name: Fact-finding survey on the SME Outsourcing Fairness Law - Method: Online questionnaire - Region: Nationwide (Japan) - Participants: 500 respondents from ordering side, 500 from contractor side - Period: March 26 to March 30, 2026

About freee's Services freee provides the "freee Law Compliance Guide" and "freee Outsourcing Management" to support businesses in achieving full compliance.

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