JP v13.3.0

Japan (JP) · Module Detail

Japan: Conduct, Safeguarding & Promotions

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Safeguarding for non-bank FTSPs is achieved primarily through a Performance Security Deposit (cash deposit with the Legal Affairs Bureau), with bank performance bonds and trust arrangements as alternatives; crypto/EPI custody requires segregation. The FSA supervises conduct via its Comprehensive Supervision Guidelines and the Guideline for Supervision of Funds Transfer Service Providers, which embed AML/CFT and user-protection expectations. Stablecoin/crypto intermediaries face explicit disclosure, explanation and prohibited-conduct rules under the 2025 reforms.

Horizon · 2026-06 (± a quarter)FSA crypto/EPI intermediary conduct rules take effectAdopted, not yet in force · Tier 2 source
Standing sub-brief · as of 16 August 2026188 words · last cycle 2026-08-16

Conduct, Safeguarding & Financial Promotions

Trust-type electronic payment instrument issuers may now hold up to 50% of backing assets in short-term Japanese government bonds of three months or less, or in early-cancellable term deposits, relaxing the prior requirement that reserves sit wholly in demand deposits. Separately, fund-transfer operators gain an optional bank- or trust-backed direct-reimbursement mechanism that sits alongside the existing kyotaku statutory deposit route, giving non-bank payment institutions a second safeguarding pathway for user funds held on failure. Both changes apply specifically to the non-bank payment-institution and EPI-issuer population rather than to deposit-taking banks, which continue to safeguard customer funds under existing banking-sector prudential rules; the reforms therefore widen, rather than replace, the menu of safeguarding options available to non-bank operators without altering the bank-side baseline. This is the live safeguarding-and-conduct item for Japan this cycle, distinct from the market-access and licensing changes tracked separately.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (4)
  1. T3https://www.mofo.com/resources/insights/200715-reforms-japanese-regulations.htmlretrieved
  2. T1https://www.fsa.go.jp/common/law/guide/kaisya/e014.pdfretrieved
  3. T2https://www.mexc.com/news/1109792retrieved
  4. T2https://practiceguides.chambers.com/practice-guides/financial-services-regulation-2025/japan/trends-and-developmentsretrieved