Japan’s Consumer Affairs Agency issued a remedial measure order against SNOW Japan and SNOW Corporation for engaging in covert influencer marketing [1, 2].
The order follows a crackdown on "stealth marketing," a practice where companies hide the promotional nature of social media posts to deceive consumers into believing they are organic recommendations.
The agency determined that the companies violated the Act against Unjustifiable Premiums and Misleading Representations [1, 2]. This law, known as the Premiums and Misleading Advertising Law, prohibits deceptive claims and undisclosed paid endorsements that mislead the public regarding the nature of a product or service.
According to the investigation, the companies paid at least 72 influencers to post about the SNOW photo-editing app [1]. These influencers were directed to post content on X, including messages such as "I tried making a trendy AI-generated image with SNOW," without disclosing that they were being compensated [2].
Compensation for these posts ranged from several thousand yen to several ten-thousand yen [1]. These payments were delivered in the form of electronic gift certificates [1].
The measure order was officially issued on June 6, 2026 [1, 2]. The agency's action targets both the Japanese subsidiary, SNOW Japan, and the Korean headquarters, SNOW Corporation, as the coordination of the marketing campaign involved both entities [1, 2].
By failing to label these posts as advertisements, the company bypassed transparency requirements designed to protect consumers from misleading digital content. The remedial order requires the companies to cease these practices and ensure future compliance with Japanese advertising standards [1, 2].
“Japan’s Consumer Affairs Agency issued a remedial measure order against SNOW Japan and SNOW Corporation”
This enforcement action signals Japan's increasing intolerance for 'stealth marketing' in the digital economy. By penalizing both the local subsidiary and the foreign headquarters, the Consumer Affairs Agency is asserting that international companies must adhere to local transparency laws regardless of where the marketing strategy is coordinated. This sets a precedent for how AI-driven apps and social media platforms must disclose paid partnerships to avoid legal sanctions under the Premiums and Misleading Advertising Law.
