Japan Market Entry for Financial Institutions: Licensing and Regulatory Engagement

End to End Licensing and Regulatory Support

As they explore business opportunities across the Asia Pacific region to meet the financial needs of corporate partners, global financial institutions are increasingly seeking to establish a presence in Japan. However, the initial step of identifying the licenses and registrations required for the planned business is not always straightforward. Japan’s financial services laws—including the Banking Act, the Financial Instruments and Exchange Act, the Money Lending Business Act, and the Payment Services Act—are diverse, and extensive communication with regulatory authorities in the local language can pose challenges even for well established global institutions.
We support clients through every stage of the office establishment process, including direct communication and negotiation with the relevant authorities to obtain the necessary financial services licenses and registrations.

General Steps to Obtain a Financial Services License or Registration

The process of obtaining a financial services license or registration in Japan typically begins with consultation with the relevant authorities. We advise on the specific licenses or registrations required for each product or service under your business model and help facilitate efficient communications with regulators.

Financial Licenses and Registrations in Japan

Financial Licenses and Registrations in Japan

A wide range of financial businesses must obtain a license, authorization, or registration from the Financial Services Agency. Key categories include:

• Bank (Banking Act)
  When a foreign bank seeks to conduct banking business in Japan, it must establish a branch and obtain a license. Under the Banking Act, branches and other offices of foreign banks are treated in the same manner as domestic banks.
  
• Financial Instruments Business Operator (Financial Instruments and Exchange Act)
  Only registered entities may engage in financial instruments business.
  
  
  • Type I Financial Instruments Business: Sale and solicitation of Type I instruments, such as stocks, bonds, and investment trusts
    
  • Type II Financial Instruments Business: Sale and solicitation of Type II instruments, such as beneficial interests in trusts, fund interests, and membership rights
    
  • Investment Advisory and Agency Business
    
  • Investment Management Business
    
    
• Electronic Payment Handling Service Provider (Banking Act)
  Only registered entities may engage in “electronic payment handling services” as defined by the Banking Act: (i) transmitting a user’s instruction to a bank to initiate transfers from the user’s bank account (payment initiation), and (ii) obtaining account and transaction information held by banks and providing it to the user (account information services), typically via APIs under contracts with banks.
  
• Money Lender (Money Lending Business Act)
  Only registered entities may engage in the lending of money or intermediate or act as an agent for the conclusion of money lending contracts.
  
• Fund Transfer Service Provider (Payment Services Act)
  Only registered entities may provide funds transfer services by receiving funds from a sender and executing remittances to a recipient without accepting deposits. The permissible per transaction amount is set by category—Type I (transfers may exceed JPY 1 million), Type II (up to JPY 1 million), and Type III (up to JPY 50,000).
  

How We Support You

Our multidisciplinary team—comprising professionals with deep expertise in financial regulation, law, risk management, tax, and accounting, including former regulators—provides end to end support for:

• Identifying required licenses and registrations
  
• Preparing and filing applications
  
• Coordinating and communicating with financial authorities
  
• Designing operating models and compliance /risk management frameworks
  
• Providing ongoing advice and business process outsourcing after launch
  

Your Partner for Seamless Market Entry

With our extensive experience and strong connections in Japan and abroad, we help you establish your Japan office efficiently, compliantly, and strategically—turning complex procedures into smooth, timely execution.