Japan — License Map

June 6, 2026

31 min read

Japan was one of the first major economies to establish a comprehensive legal framework for digital assets, with the Financial Services Agency (FSA) requiring all crypto exchanges to register as Crypto-Asset Exchange Service Providers (CAESPs) under the Payment Services Act (PSA) since 2017. The Japan Virtual and Crypto Assets Exchange Association (JVCEA) functions as the FSA-designated self-regulatory organisation, pre-approving all new crypto asset listings. This early regulatory clarity -- combined with strict consumer protection requirements including 95% cold storage and customer fund segregation -- has created one of the world's most structured crypto markets.

The tax regime has been the primary weakness: crypto gains are classified as miscellaneous income subject to progressive taxation reaching approximately 55% (45% national + 10% local inhabitant tax), with no loss carryforward permitted. However, Japan is undergoing a landmark transformation. The FY2026 tax reform bills -- first set out in the Tax Reform Outline released December 19, 2025 -- passed the National Diet on March 31, 2026 (221st special Diet session), enacting a separate 20.315% self-assessment tax rate for "specified crypto assets" traded on FSA-registered exchanges, with three-year loss carryforward. The lower rate is operationally contingent on the companion FIEA amendment taking force; the FY2026-reform analysis anticipates it applying to transactions conducted on or after January 1, 2028 (Nagashima Ohno & Tsunematsu, March 2026, No.6), tied to the FIEA amendment's expected entry into force in fiscal 2027 (first returns filed Feb-March 2029). Simultaneously, the FSA's bill to reclassify approximately 105 crypto assets from the PSA to the Financial Instruments and Exchange Act (FIEA) -- treating them as "financial products" alongside stocks and bonds -- received a Cabinet decision on April 10, 2026 and was submitted to the Diet (pending passage; target effect ~fiscal 2027). Japan implemented OECD CARF reporting from January 1, 2026, making it one of the earliest adopters globally.

Regulatory Architecture

Japan's crypto regulation is administered by a cluster of agencies with clearly defined mandates:

BodyRole
Financial Services Agency (FSA / JFSA)Primary regulator; registers and supervises CAESPs; enforces AML; issues policy guidance; driving FIEA reclassification
Japan Virtual and Crypto Assets Exchange Association (JVCEA)FSA-designated self-regulatory organisation; pre-approves new crypto asset listings; enforces industry-specific guidelines
National Tax Agency (NTA)Classifies crypto gains as miscellaneous income; enforces tax compliance; publishes FAQ guidance (9 versions to date)
Japan Security Token Offering Association (JSTOA)Oversees security token offerings under FIEA
Ministry of Finance (MOF)Cross-border transaction reporting; overall tax policy direction

Key legislation and instruments:

LegislationScopeKey Amendments
Payment Services Act (PSA)Primary crypto asset regulation; CAESP registration; consumer protection2017 (crypto defined), 2020 (terminology to "crypto assets"), 2023 (stablecoin EPIs), 2025 (Amendment Act)
Financial Instruments and Exchange Act (FIEA)Security tokens; ICOs as "type 2 securities"; proposed crypto reclassificationPending 2026-2027 amendment for crypto as "financial products"
Income Tax ActIndividual crypto taxationPending separate taxation amendment
Corporation Tax ActCorporate crypto taxationFY2023: self-issued token exemption; FY2024: all tokens exempt from unrealized gains tax
Act on Prevention of Transfer of Criminal ProceedsAML/CFT obligations; travel rule2024: full FATF Travel Rule implementation
Consumption Tax ActConsumption tax exemption for crypto transfers since July 1, 20172017 amendment

CAESP registration requirements:

  • Minimum capital of 10 million yen (~USD 67,000)
  • Customer due diligence and KYC procedures
  • Segregation of customer funds from operational accounts
  • At least 95% of customer crypto assets stored in offline (cold) wallets
  • Annual audit of customer asset segregation
  • Margin trading limited to 2x leverage (JVCEA self-regulatory rules)
  • Registration process approximately 6 months
  • JVCEA must pre-approve any new crypto asset before listing

Tax Reporting Obligations

Current Regime: Miscellaneous Income (Through 2026 Tax Year)

Crypto gains are classified as miscellaneous income and subject to aggregate taxation at progressive national rates plus flat local inhabitant tax:

Taxable Income (JPY)National Rate
0 -- 1,950,0005%
1,950,001 -- 3,300,00010%
3,300,001 -- 6,950,00020%
6,950,001 -- 9,000,00023%
9,000,001 -- 18,000,00033%
18,000,001 -- 40,000,00040%
40,000,001+45%

Additional taxes: 10% local inhabitant tax + 2.1% special reconstruction surtax (through 2037). Effective combined maximum rate: approximately 55.945%.

Loss treatment (current): Crypto losses can only offset other miscellaneous income in the same tax year. No offset against salary, business, or stock capital gains. No loss carryforward or carryback.

Filing threshold: Individuals with crypto gains exceeding 200,000 JPY (~USD 1,340) must file. Tax year runs January 1 to December 31; filing deadline March 15 of the following year.

Separate Taxation Reform (FY2026 Tax Reform — Enacted March 31, 2026)

On December 19, 2025, the ruling LDP-Komeito coalition released the FY2026 Tax Reform Outline; the implementing FY2026 tax reform bills passed the National Diet on March 31, 2026 (221st special Diet session). The enacted separate self-assessment regime provides:

ParameterDetail
Flat rate20.315% combined (15% national + 2.1% surtax + 5% local) -- matching stock/equity capital gains rate
Eligible assets"Specified crypto assets" supervised under FIEA and traded on FSA-registered exchanges (~105 assets including BTC and ETH)
Loss carryforwardUp to three years, offsetting future gains from specified crypto assets
Covered transactionsSpot trading on registered exchanges, derivative trading, crypto ETFs (once introduced)
Effective dateContingent on the FIEA amendment's entry into force (expected fiscal 2027); the new regime is anticipated to apply to transactions conducted on or after January 1, 2028 (Nagashima Ohno & Tsunematsu, March 2026, No.6)
First returns filedFebruary-March 2029 (for the January 1 -- December 31, 2028 tax year)

What remains at progressive rates (up to 55%): Staking rewards, lending yields, mining income, DeFi protocol yields, NFT transactions, gains from non-registered (overseas/decentralised) exchanges, and airdrop income.

Status as of June 2026: The tax statute is ENACTED (Diet passage March 31, 2026). However, the reduced 20.315% rate is operationally contingent on the separate FIEA reclassification amendment (Cabinet-approved April 10, 2026; see Payment / Transfer Service License section) being passed by the Diet and brought into force. The FY2026-reform analysis anticipates the new tax regime applying to transactions conducted on or after January 1, 2028 (Nagashima Ohno & Tsunematsu, "Japan's 2026 Tax Reform on Taxation of Crypto Asset Transactions" (March 2026, No.6), authored by Tsutomu Endo: https://www.nagashima.com/wp-content/uploads/2026/03/tax_en_no6_1.pdf). Until the FIEA framework takes effect, crypto gains continue to be taxed as miscellaneous income at rates up to ~55%.

Mining, Staking, and DeFi

  • Mining rewards: Taxable as miscellaneous income at fair market value in JPY at receipt. Electricity and hardware depreciation may be deductible as necessary expenses for commercial-scale operations
  • Staking rewards: Taxable as miscellaneous income at fair market value when received. Explicitly excluded from the proposed 20% flat rate
  • DeFi yield: Taxable as miscellaneous income at fair market value when credited. Excluded from the proposed 20% flat rate reform
  • Airdrops: Taxable at fair market value when recipient gains control; recognition may be deferred if no reliable market price exists at receipt

Cost Basis Methods

  • Total Average Method (default for individuals): Per-unit cost basis calculated across all acquisitions during the year
  • Moving Average Method (default for corporations): Recalculated per-unit cost basis with each new acquisition. Individuals may elect this method by filing notification with the NTA

Corporate Taxation

Corporate unrealised gains taxation on crypto assets has been abolished in two stages:

  • FY2023 (April 1, 2023): Self-issued tokens exempted from mark-to-market taxation
  • FY2024 (April 1, 2024): All crypto assets exempted; corporations taxed only on realised gains

Standard effective corporate tax rate: approximately 30-34% combined (national + local).

Consumption Tax

Crypto asset transfers have been exempt from consumption tax (10%) since July 1, 2017. Consumption tax applies to exchange service fees, lending fees, and advisory fees.

NTA Reporting and Exchange Data

  • Registered exchanges provide annual transaction reports to both users and the NTA
  • The FY2026 Tax Reform Outline mandates formalised "duty of reporting by business operators to tax authorities" -- a system mirroring the US 1099-DA framework
  • NTA FAQ guidance documents (Version 9 released December 20, 2024) provide detailed treatment of 47 items across 7 sections

OECD CARF Implementation

Japan officially implemented the OECD CARF starting January 1, 2026, making it one of the earliest adopters:

  • Reporting entities: Reporting Crypto-Asset Exchange Service Providers (RCAESPs), including CAESPs and electronic payment instruments operators
  • Scope: Information on crypto transactions involving non-resident individuals and entities
  • Data collected: Country of tax residence, transaction volumes, aggregate proceeds, taxpayer identification numbers
  • Filing deadline: April 30 of the year following the reporting period (first reports due April 30, 2027)
  • New accounts (from January 1, 2026): Information collected at account opening
  • Pre-existing accounts: Due diligence completed by December 31, 2026
  • NTA released comprehensive CARF FAQs in September 2025

Enforcement

The NTA has progressively increased crypto-focused tax enforcement:

Fiscal YearAuditsTax Recovery
FY2022615~19 billion JPY (~USD 126M) in underreported income identified
FY20246134.6 billion JPY recovered (+31.4% year-over-year)

Notable case: Hideji Matsuda was fined approximately 22 million JPY and sentenced to one year in prison for failing to disclose cryptocurrency trading profits.

Regulatory Direction

Japan is undergoing a once-in-a-decade transformation of its crypto regulatory and tax framework. The trajectory is clearly toward liberalisation for regulated exchange-traded assets, while maintaining strict requirements for everything outside the regulated perimeter.

The 20.315% separate taxation statute is now enacted (Diet passage March 31, 2026); once the companion FIEA reclassification (Cabinet-approved April 10, 2026, pending Diet passage; target effect ~fiscal 2027) takes force, Japan will transition from one of the most punitive crypto tax jurisdictions to one broadly aligned with its treatment of traditional financial assets. The FY2023 and FY2024 corporate tax reforms -- abolishing mark-to-market taxation on unrealised gains -- have already removed a major barrier that previously drove Web3 companies out of Japan, with an estimated 200+ new Web3 startups establishing operations in Japan during 2025.

However, a two-tier structure is emerging: favourable treatment for "specified crypto assets" traded on FSA-registered exchanges (20.315%, three-year loss carryforward), and continued punitive rates (up to 55%) for staking, DeFi, mining, NFTs, and assets on non-registered exchanges. This divide will shape how the Japanese crypto ecosystem develops and may push innovative DeFi and staking activity to more favourable jurisdictions.

Japan's early CARF adoption (January 2026), combined with full FATF Travel Rule implementation (2024) and extensive NTA data access through domestic exchange reporting, creates one of the most comprehensive cross-border tax reporting infrastructures in the Asia-Pacific region.

RWA / Security Token Platform Licensing

Japan was one of the earliest jurisdictions to establish a legal framework for security token offerings (STOs), amending the Financial Instruments and Exchange Act (FIEA) in May 2020 to classify security tokens as "Electronically Recorded Transferable Rights" (ERTRs). The Japan Security Token Offering Association (JSTOA), established October 2019 and recognised by the JFSA as a self-regulatory organization in May 2020, sets industry standards.

License Details

AttributeDetail
License name(s)Type I Financial Instruments Business Operator (FIBO) registration (dealing/brokering/STO platforms); Type II FIBO registration (self-offering of tokenized CIS interests); Investment Management Business registration
Regulatory authorityJFSA (Japan Financial Services Agency); JSTOA (self-regulatory organization)
Legal basisFinancial Instruments and Exchange Act (FIEA); Act on Prevention of Transfer of Criminal Proceeds (AML)

Requirements

RegistrationCapitalKey Requirements
Type I FIBOJPY 50,000,000 minimum net capital (~USD 340,000); capital adequacy ratio 120%+ ongoingDealing in / brokering security tokens; operating STO platforms (PTS registration required); JSTOA-approved infrastructure
Type II FIBOJPY 10,000,000 (~USD 68,000)Self-offering of tokenized CIS interests; lower capital threshold
Investment Management BusinessJFSA-determinedManaging security token portfolios; fit-and-proper requirements

Key Holders

JSTOA founding members include Nomura Securities, SBI Securities, Daiwa Securities, Rakuten Securities, MUFG, and Tokai Tokyo Financial Holdings. These firms operate the primary STO issuance and distribution infrastructure in Japan.

Ongoing Obligations

  • Capital adequacy ratio maintained at 120% or above
  • JSTOA self-regulatory rules compliance (STO issuance standards, platform operations, investor protection, disclosure)
  • AML/CFT compliance under Act on Prevention of Transfer of Criminal Proceeds
  • FATF Travel Rule compliance; record-keeping for 7 years

Tax Treatment of Security Tokens

Security tokens classified as ERTRs are taxed according to the underlying right: interest income from tokenized bonds at 15.315% withholding (20.315% separate taxation); dividends from tokenized equity per standard rules; capital gains at 20.315% (15.315% national + 5% local) under separate self-assessment taxation for securities.

Transition

Japan is undergoing a major regulatory transformation. The FIEA reclassification bill (Cabinet-approved April 10, 2026, pending Diet passage; target effect ~fiscal 2027) and the enacted 20.315% separate taxation for crypto-assets (Diet passage March 31, 2026; rate effective once the FIEA framework takes force) will further align the framework. The FY2023 and FY2024 corporate tax reforms abolished mark-to-market taxation on unrealised gains, removing a major barrier that drove Web3 companies out of Japan.

See

Japan RWA Regulation for full details on FIEA ERTR framework, JSTOA self-regulation, Type I/II FIBO registration, and the STO market.

DeFi Protocol Licensing

Regulatory Approach

Japan regulates DeFi under its existing Crypto-Asset Exchange Service Provider (CAESP) framework. Any entity that facilitates exchange, custody, or intermediation of crypto-assets in Japan must register with the FSA as a CAESP under the Payment Services Act. The FSA established a DeFi Study Group to evaluate whether additional regulation is needed, and the FIEA reclassification bill (Cabinet-approved April 10, 2026, pending Diet passage; target effect ~fiscal 2027) would bring approximately 105 crypto-assets under financial instruments regulation, potentially capturing DeFi token trading.

Japan is notable for having enacted a DAO LLC framework (Limited Liability Company type) effective April 2024, making it one of the few jurisdictions with a dedicated legal wrapper for decentralized autonomous organizations.

Available License Types

License/RegistrationRegulatorRelevance to DeFiCapital/Cost
CAESP registrationFSA / JVCEARequired for any entity facilitating crypto-asset exchange, custody, or intermediation; applies to DeFi front-end operators serving Japanese usersJPY 10M (~USD 67K) minimum capital
Type I FIBOFSARequired if DeFi protocol deals in tokens classified as securities (Type I securities); applies to DEXs trading security tokensHigher capital requirements
Type II FIBOFSARequired for handling collective investment schemes, self-offering of Type II securitiesLower capital than Type I
DAO LLCPrefectural governmentLegal entity framework for DAOs; limited liability for members; registered as godo kaisha (LLC) variantStandard LLC registration costs

DeFi-Specific Requirements

  • Smart contract audits: Not explicitly mandated by FSA regulations, but JVCEA self-regulatory guidelines require operational risk management for all CAESPs, which extends to smart contract risk assessment.
  • Governance framework: The DAO LLC framework (April 2024) allows DAOs to incorporate as limited liability companies, providing legal personality, limited liability for members, and a pathway for regulatory engagement. DAO LLCs must have at least one representative member in Japan.
  • JVCEA pre-approval: All new crypto-assets must be pre-approved by the JVCEA self-regulatory organization before listing on any registered CAESP. This applies to DeFi governance tokens offered through regulated platforms.
  • Consumer protection: 95% cold storage requirement for customer crypto-assets; customer fund segregation mandatory; margin trading limited to 2x leverage under JVCEA rules.
  • FIEA reclassification (Cabinet-approved April 10, 2026): The FSA's bill reclassifying ~105 crypto-assets from the PSA to the FIEA, treating them as "financial products," received a Cabinet decision on April 10, 2026 and was submitted to the Diet (pending passage; target effect ~fiscal 2027). This could bring DeFi protocols facilitating trading in these assets under securities-equivalent regulation.

Key Licensed Operators (DeFi-Adjacent)

There are 27 registered CAESPs in Japan as of 30 April 2026 (FSA official register: 25 Kanto Finance Bureau + 2 Kinki Finance Bureau). No purely decentralized DeFi protocol has obtained a CAESP registration; instead, DeFi access is typically mediated through registered exchanges.

OperatorRegistrationDeFi Relevance
bitFlyerCAESPLargest Japanese exchange; exploring institutional DeFi services
CoincheckCAESPMonex Group subsidiary; NFT marketplace and DeFi gateway
SBI VC TradeCAESP + STOSBI Group; institutional tokenization and DeFi infrastructure

Application Timeline

  • CAESP registration: ~6 months (FSA review)
  • JVCEA token pre-approval: Additional time for each new token listing
  • DAO LLC registration: Standard company registration timeline
  • FIEA reclassification: Bill Cabinet-approved April 10, 2026; pending Diet passage (target effect ~fiscal 2027)

Cross-Reference

See

Japan DeFi Regulation for full details on CAESP registration for DeFi, FSA DeFi Study Group, DAO LLC framework, proposed FIEA reclassification, JVCEA self-regulation, and consumer protection requirements.

Sources: FSA CAESP Registration Requirements; JVCEA Self-Regulatory Guidelines; DAO LLC Act (April 2024)

Insurance / Risk Transfer Licensing

Overview

Japan does not mandate insurance for crypto-asset custody or exchange operations. Customer protection relies primarily on the 95% cold storage requirement and mandatory fund segregation under the Payment Services Act. However, the FSA's Financial System Council recommended a mandatory liability reserve system for licensed crypto exchanges, carried into the FIEA amendment bill (Cabinet-approved April 10, 2026; expected effective ~fiscal 2027). It would require CAESPs to accumulate reserve funds to compensate users in the event of asset loss -- functioning as a self-insurance mechanism -- with the FSA considering allowing approved insurance policies to count toward part of the requirement. Traditional securities firms in Japan hold reserves ranging from roughly JPY 2 billion to JPY 40 billion as a benchmark reference.

Regulatory Authority

BodyRole
FSA (JFSA)Regulates both insurance companies (Insurance Business Act) and CAESPs (Payment Services Act)
JVCEASelf-regulatory organisation; may set industry standards for insurance/compensation

Insurance Requirements for Crypto Businesses

DimensionDetail
Mandatory insuranceNo -- the PSA does not require CAESPs to hold insurance against loss of customer crypto assets
95% cold storagePrimary customer protection mechanism; CAESPs must store at least 95% of customer assets offline
Fund segregationCustomer crypto assets must be segregated from operational accounts
Proposed liability reserveMandatory liability reserve system carried into the FIEA amendment bill (Cabinet-approved April 10, 2026; expected effective ~fiscal 2027), requiring CAESPs to accumulate reserves to compensate customers for losses; approved insurance may count toward part of the requirement; pending Diet passage
Deposit insuranceJapan's Deposit Insurance Corporation (DIC) covers bank deposits up to JPY 10 million per depositor per bank; does not extend to crypto-asset holdings
Voluntary insuranceMajor Japanese exchanges (bitFlyer, Coincheck) have historically maintained some form of commercial insurance or internal reserve, though details are not publicly standardised

Regulatory Direction

  • The proposed liability reserve system, if enacted, would represent a significant shift toward mandated customer compensation capacity
  • The FIEA reclassification of ~105 crypto assets (expected 2026-2027) may bring additional investor protection requirements, potentially including insurance-like mechanisms
  • Japan's approach prioritises custody security controls (95% cold storage) over commercial insurance

Cross-Reference

See

Japan Digital Asset Insurance for full details on the FSA's proposed liability reserve system, the 95% cold storage requirement as insurance alternative, and the evolving framework for customer compensation.

Payment / Transfer Service License

Activity type: Crypto asset exchange and payment services, stablecoin (EPI) distribution, fund transfer services, intermediary services

License Details

Japan regulates crypto payment and transfer services through multiple registration categories under the Payment Services Act (PSA), administered by the Financial Services Agency (FSA/JFSA). The Japan Virtual and Crypto Assets Exchange Association (JVCEA) functions as the FSA-designated self-regulatory organisation, pre-approving all new crypto asset listings and enforcing industry-specific guidelines.

Registration / LicenceStatuteScopeCapital Requirement
Crypto Asset Exchange Service Provider (CAESP)PSABuying, selling, exchanging crypto assets; acting as intermediary/broker; custody of crypto assetsJPY 10M (~USD 67K)
Electronic Payment Instruments Exchange Service Provider (EPIESP)PSA (2022 amendments)Buying, selling, exchanging, intermediating, and custodying fiat-backed stablecoins (EPIs)JPY 10M (~USD 67K)
Fund Transfer Service Provider — Type IPSAUnlimited transfer amount (operator sets own cap)Permission required; collateral calculated daily
Fund Transfer Service Provider — Type IIPSATransfers up to JPY 1M per transactionRegistration; performance security deposit
Fund Transfer Service Provider — Type IIIPSATransfers up to JPY 50,000 per transactionRegistration (simplified); reduced security deposit
ECISBO (Electronic Payment Instrument and Crypto-asset Intermediary Service Business Operator)PSA (2025 Amendment Act)Pure intermediary services for CAES and/or EPI exchangesNone (no deposits of users' property accepted)

The CAESP registration is the primary vehicle for firms offering crypto payment services. All entities handling crypto assets for customers — whether as exchanges, payment processors, or custodians — must register. The EPIESP registration covers stablecoin distribution, while stablecoin issuance is restricted to banks, trust companies, and fund transfer service providers.

Requirements

RequirementCAESPEPIESPFund Transfer (Type II)
Minimum capitalJPY 10MJPY 10MPerformance security deposit
Net assetsMust be positiveMust be positive—
Entity typeKabushiki-kaisha or foreign CAESP with Japanese officeStock company or registered foreign entity with Japanese office—
Physical office in JapanRequiredRequiredRequired
Annual financial auditMandatory (CPA or auditing firm)Mandatory—
Annual segregation auditMandatory (CPA or auditing firm)——
JVCEA membershipRequiredRequired (since October 2024)—
Practical startup costEstimated JPY 1B+ (~USD 6.7M+)——

Custody requirements: 95% of customer crypto assets must be held in cold storage (offline wallets); customer funds must be segregated from operational accounts; management of hot wallets limited to 5% of customer assets.

AML/CFT obligations (APTCP): Customer due diligence and identity verification at account opening (My Number Card, passport, driver's licence, residence card); beneficial ownership identification (25%+ threshold); suspicious transaction reporting to JAFIC; record retention for 7 years; sanctions screening; Travel Rule compliance (no minimum threshold, applies to all crypto asset and EPI transfers between CAESPs/EPIESPs).

JVCEA self-regulatory requirements: Pre-assessment for new token listings; ongoing compliance monitoring; transaction monitoring; sanctions screening; periodic review and updating of customer information; staff AML/CFT training; reporting to JVCEA on compliance metrics.

Application Process

  1. Preparation: Establish Japanese stock company (kabushiki-kaisha) or register foreign entity with Japanese branch/subsidiary; develop comprehensive internal systems for compliance, risk management, and information security
  2. JVCEA engagement: Apply for JVCEA membership concurrently (mandatory for CAESPs and EPIESPs)
  3. FSA submission: Submit registration application to the relevant Local Finance Bureau with all supporting documents including business plan, governance framework, AML/CFT policies, IT security documentation, and staffing plans
  4. FSA review: Fit-and-proper assessment of directors, CEO, and key persons; detailed evaluation of organisational structure and internal controls
  5. Processing timeline:
    • CAESP registration: ~6–12 months (no statutory processing period; depends on application completeness and FSA review capacity)
    • JVCEA token pre-approval: additional time per token
    • Practical timeline: 12+ months including preparation
  6. Outcome: FSA grants or denies registration; registered entities listed on FSA's public register

Ongoing Obligations

  • Annual financial audit and segregation audit by CPA or auditing firm
  • Compliance with JVCEA self-regulatory rules including token listing pre-approvals
  • Ongoing AML/CFT monitoring, suspicious transaction reporting, and Travel Rule compliance
  • Maintenance of 95% cold storage requirement and customer fund segregation
  • Customer complaint handling and participation in financial ADR (alternative dispute resolution)
  • Reporting to FSA on material changes to business operations, key personnel, or corporate structure
  • Compliance with FSA business improvement orders if issued

Passporting & Cross-Border

Japan does not have a mutual recognition or passporting framework for crypto asset service providers. Foreign entities wishing to serve Japanese residents must establish a local presence (branch or subsidiary) and register separately with the JFSA. There is no equivalent to the EU's MiCA passporting system. The JFSA has actively enforced the requirement for foreign entities to register, issuing warnings to five unregistered foreign exchanges in 2024 (KuCoin, Bybit, Bitget, MEXC Global, Bitcastle LLC) and requesting Apple and Google remove their mobile applications from Japan-facing app stores in February 2025.

Cross-border crypto payments are additionally governed by the Foreign Exchange and Foreign Trade Act (FEFTA), which requires residents to report cross-border crypto asset payments or receipts exceeding JPY 1 million.

Banking Access

Registered CAESPs can generally maintain banking relationships with Japanese banks. The establishment of the JVCEA and the clearer regulatory framework since 2017 has improved the situation. However, smaller or newer entrants may still face practical difficulties obtaining and maintaining banking access. The megabank stablecoin pilot (MUFG, SMBC, Mizuho — launched November 2025) signals growing institutional acceptance of crypto-related banking services.

Key License Holders

EntityRegistrationNotable
bitFlyerCAESPLargest Japanese exchange by volume; retail crypto payments via bitFlyer Pay
CoincheckCAESPMajor retail exchange; received business improvement order 2018
SBI VC TradeCAESP + EPIESPFirst registered EPIESP (March 2025); first to distribute USDC in Japan
bitbankCAESPMajor exchange; planning USDC listing
GMO CoinCAESPSubsidiary of GMO Internet Group
JPYC Inc.Fund Transfer Service ProviderFirst registered yen-backed stablecoin issuer (August 2025); launched JPYC on 27 October 2025
FTX JapanCAESP (suspended)Operations suspended; received business improvement order 2022
DMM BitcoinCAESPReceived business improvement order 2024

As of 30 April 2026, there are 27 registered CAESPs in Japan (FSA official register, 全業者数:27 — 25 under the Kanto Finance Bureau plus 2 under the Kinki Finance Bureau): FSA Register of Crypto-Asset Exchange Service Providers.

Transition / Grandfathering

The 2022 PSA amendments creating the EPI (stablecoin) framework came into effect on 1 June 2023. Entities distributing stablecoins were required to register as EPIESPs — SBI VC Trade was the first to complete registration in March 2025.

The 2025 Amendment Act introducing the ECISBO intermediary regime was enacted on 6 June 2025 (promulgated 13 June 2025 as Act No. 66 of 2025) and took full operational effect on 1 June 2026 — the single enforcement date fixed by the FSA Cabinet Order published 22 May 2026 (the statutory one-year-from-promulgation outer limit of 13 June 2026 was not the actual date used). This creates a lighter-touch registration pathway for pure intermediaries that do not hold customer assets.

The landmark FIEA reclassification — moving approximately 105 crypto assets from PSA to Financial Instruments and Exchange Act regulation, treating them as "financial products" alongside stocks and bonds — received a Cabinet decision on April 10, 2026 and was submitted to the Diet; it is pending parliamentary passage, with the new framework expected to take effect around fiscal 2027. The bill also raises penalties for unregistered operation from up to 3 years / JPY 3 million to up to 10 years / JPY 10 million, introduces an insider-trading prohibition and mandatory annual issuer disclosure for crypto assets, and renames CAESPs "crypto-asset trading operators." NFTs and EPI stablecoins remain outside the FIEA. This will fundamentally reshape the licensing landscape, requiring existing CAESPs to obtain Financial Instruments Business Operator registration for reclassified assets.

Cross-Reference

See

Japan Crypto Payment Regulation for full details on CAESP registration, EPIESP framework, fund transfer service provider tiers, ECISBO intermediary regime, Travel Rule implementation, stablecoin (EPI) framework, megabank pilot, and the forthcoming FIEA reclassification.

Sources: Payment Services Act (English translation); JVCEA Official Website; Crypto Regulations in Japan 2024 — So & Sato; Blockchain & Cryptocurrency Laws 2026 — Japan, GLI; Stablecoin Laws in Japan — Plasma

NFT & Digital Collectibles

Activity type: NFT marketplace operation, NFT issuance, fractionalized NFT platforms

DimensionDetails
Applicable license(s)No license required for unique, non-payment NFTs (excluded from crypto-asset definition under PSA). CAESP registration with FSA required if NFTs are classified as crypto-assets (payment function or Type II equivalence). Type I FIBO registration (JPY 50M minimum capital) if NFTs qualify as securities (ERTRIs) under FIEA. ECISB registration (effective June 2026) for intermediaries. General business registration under Companies Act for non-crypto-asset NFT marketplaces.
Regulatory authorityFSA/JFSA (primary); JVCEA (self-regulatory, token listing pre-approval); JCBA/BCA (industry guidelines); Consumer Affairs Agency (gacha/premiums regulation)
Capital requirementsCAESP: JPY 10M (~USD 67K) minimum net assets; Type I FIBO: JPY 50M (~USD 340K) with 120%+ capital adequacy ratio; Type II FIBO: JPY 10M (~USD 68K); no financial capital requirement for non-crypto-asset NFT marketplaces
Timeline (actual)CAESP registration: ~6 months; JVCEA token pre-approval: additional time per token; FIEA reclassification of ~105 crypto-assets expected 2026--2027 (pending Diet approval)
Key requirementsFunctional analysis (payment function test, securities test); JCBA NFT Business Guidelines compliance (classification flowcharts, consumer protection); BCA guidelines (market manipulation prevention, insider trading prohibition); ASCT disclosure for online sales; APTCP AML/KYC if CAESP; 95% cold storage and fund segregation if handling crypto-assets
NFT-specific notesFSA holds NFTs without payment function are not regulated as crypto-assets "in principle"; unique identifier alone insufficient -- substance-over-form analysis applies; gaming NFTs subject to kompu gacha ban (complete gacha illegal since 2012) and Penal Code gambling provisions; NFTs excluded from the 20.315% separate tax rate (enacted March 31, 2026) -- taxed as miscellaneous income at up to 55%; Japan has no statutory droit de suite but smart-contract royalties common; inalienable moral rights (Copyright Act) apply to NFT art
Cross-reference
Full NFT regulation details

For Full Details

  • Digital Asset Taxation:
    Japan -- Digital Asset Taxation
  • RWA Regulation:
    Japan — RWA Regulation
    -- FIEA ERTR framework, JSTOA self-regulation, Type I/II FIBO registration, Nomura/SBI/Daiwa STO infrastructure, security token taxation
  • DeFi Regulation:
    Japan — DeFi Regulation
    -- CAESP registration, FSA DeFi Study Group, DAO LLC framework, FIEA reclassification, JVCEA self-regulation
  • Digital Asset Insurance:
    Japan Digital Asset Insurance
    -- no insurance mandate, proposed liability reserve (2026-2027), 95% cold storage as primary protection, FSA oversight
  • Crypto Payment Regulation:
    Japan Crypto Payment Regulation
    -- CAESP registration, EPIESP framework, fund transfer service provider tiers, ECISBO intermediary regime, Travel Rule, stablecoin (EPI) framework, FIEA reclassification

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Verification Notes

This file was refreshed and reconciled against the 2026-06-04 source-domain files for Japan on 2026-06-04 (verification standard version 2026-06-04). Primary-source confirmations were fetched for the two most material developments.

Targeted gap-closure pass (2026-06-06)

Verification standard version 2026-06-04. Two register gaps were worked; both closed against fetched primary sources.

Gap 1 — Current registered CAESP count (CLOSED). Fetched the FSA's official register of crypto-asset exchange operators (暗号資産交換業者登録一覧), https://www.fsa.go.jp/menkyo/menkyoj/kasoutuka.pdf, header 令和8年4月30日現在 【全業者数:27】 (as of 30 April 2026; total operators 27 — 25 under the Kanto Finance Bureau [計25業者] plus 2 under the Kinki Finance Bureau [計2業者]). Correction below applied in three places (intro is unaffected; the DeFi-section and Payment-section count lines plus the DeFi key-operators preamble).

Gap 2 — First applicable tax year of the 20.315% rate (CLOSED). Fetched Nagashima Ohno & Tsunematsu, "Japan's 2026 Tax Reform on Taxation of Crypto Asset Transactions and Its Implications for Foreign Investors" (March 2026, No.6; author Tsutomu Endo, partner), https://www.nagashima.com/wp-content/uploads/2026/03/tax_en_no6_1.pdf: "Implementation of the new regime is contingent upon an amendment to the FIEA, and it is currently anticipated that the new tax regime will apply to transactions conducted on or after January 1, 2028." This fixes the first applicable tax year at 2028 (first returns filed Feb-March 2029), not 2027. The FIEA reclassification amendment's status (Cabinet-approved 10 April 2026, pending Diet passage, expected effect ~fiscal 2027) was re-confirmed this run and is unchanged.

ClaimWasNowSource
Registered CAESP count"32 registered CAESPs ... as of 30 April 2025" / "32 ... as of March 2026"27 registered CAESPs as of 30 April 2026 (25 Kanto + 2 Kinki Finance Bureau)FSA official register (暗号資産交換業者登録一覧, 令和8年4月30日現在 【全業者数:27】) — https://www.fsa.go.jp/menkyo/menkyoj/kasoutuka.pdf (fetched; text extracted from official PDF)
First applicable tax year of 20.315% rate"transfers made on or after January 1 of the year following the FIEA amendment's entry into force (expected January 1, 2027)"; "First returns filed: February-March 2028"Anticipated to apply to transactions on or after January 1, 2028; first returns filed Feb-March 2029; contingent on FIEA amendment (expected fiscal 2027)Nagashima Ohno & Tsunematsu, "Japan's 2026 Tax Reform on Taxation of Crypto Asset Transactions" (March 2026, No.6) — https://www.nagashima.com/wp-content/uploads/2026/03/tax_en_no6_1.pdf (fetched; text extracted from official PDF)

Corrections Made (Correction Protocol)

ClaimWasNowSource
FY2026 separate-taxation status"The tax reform bill is under deliberation in the Diet. It has NOT yet been enacted into law" (as of March 2026)ENACTED — FY2026 tax reform bills passed the National Diet on March 31, 2026 (221st special session); the 20.315% rate is operationally contingent on the FIEA amendment's entry into forceKPMG Japan, "2026 Tax Reform — Passage of the Bills" (March 31, 2026) — https://kpmg.com/jp/en/insights/2026/03/e-taxnews-20260331.html (fetched; confirms 31 March 2026 Diet passage)
2025 Amendment Act (ECISBO) enactment date"enacted in May 2025"Enacted 6 June 2025, promulgated 13 June 2025 as Act No. 66 of 2025crypto-payment-regulation + stablecoin-regulations + nft-digital-collectibles source files (reconciled 2026-06-04)
ECISBO effective date"expected to take effect within one year of promulgation (by approximately June 2026)"1 June 2026 — single enforcement date fixed by FSA Cabinet Order published 22 May 2026 (statutory outer limit 13 June 2026 not used)crypto-payment-regulation + stablecoin-regulations source files (reconciled 2026-06-04)
FIEA reclassification status"expected in 2026–2027 pending Diet approval" (no Cabinet-approval milestone)Cabinet-approved April 10, 2026 and submitted to the Diet; pending passage; raises penalties to 10 yrs / JPY 10M, adds insider-trading ban + annual issuer disclosureJFSA, "Press Conference by Minister Katayama Satsuki, 10 April 2026" — https://www.fsa.go.jp/en/conference/minister/2026/20260410.html (fetched; confirms Cabinet approval + Diet submission)

Developments Added (2026-03-20 → 2026-06-04)

  • March 31, 2026 — FY2026 tax reform bills (including the 20.315% separate self-assessment tax for specified crypto assets with three-year loss carryforward) passed the National Diet. Primary: https://kpmg.com/jp/en/insights/2026/03/e-taxnews-20260331.html
  • April 10, 2026 — Cabinet approved the FIEA/PSA amendment bill reclassifying ~105 crypto assets as financial instruments (penalties to 10 yrs / JPY 10M; insider-trading prohibition; mandatory annual issuer disclosure; CAESPs renamed "crypto-asset trading operators"; NFTs and EPI stablecoins remain under the PSA) and submitted it to the Diet. Primary: https://www.fsa.go.jp/en/conference/minister/2026/20260410.html
  • June 1, 2026 — 2025 PSA Amendment Act (ECISBO/intermediary regime, expanded VASP registration, custodial wallet providers) took full operational effect per the FSA Cabinet Order published 22 May 2026.

Cross-Domain Consistency

All licence types, regulators, capital figures (CAESP JPY 10M; Type I FIBO JPY 50M / 120% capital adequacy; Type II FIBO JPY 10M; EPIESP JPY 10M; ECISBO no capital), the 95% cold-storage mandate, JVCEA pre-approval, the registered-CAESP count (updated to 27 as of 30 April 2026 in the 2026-06-06 gap-closure pass; was 32 as of 30 April 2025), and Travel Rule terms were reconciled against the refreshed crypto-payment-regulation, crypto-custody, rwa-regulation, digital-asset-insurance, digital-asset-taxation, stablecoin-regulations, defi-regulation, and nft-digital-collectibles source files for Japan and found consistent (after the corrections above). The "practical JPY 1B+ startup cost" and "JPY 50M practical minimum" figures are self-reported/estimated practitioner figures, not statutory floors (the statutory CAESP minimum is JPY 10M plus positive net assets).