Assessing Japan’s amended regulatory framework for fund transfer service providers
IFLR is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX
Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Assessing Japan’s amended regulatory framework for fund transfer service providers

Sponsored by


Shotaro Inoue of Nagashima Ohno & Tsunematsu outlines the amendments that introduce a risk-based approach to regulating fund transfer services in Japan

Under Japanese law, only entities that have obtained a bank license under the Banking Act of Japan or have been registered as a fund transfer service (FTS) provider under the Payment Services Act of Japan (PSA) are permitted to provide FTS. The PSA was enacted in 2009 and allowed registered providers to engage in FTS subject to an upper limit of ¥1 million (approximately $9,130) per transfer.

Since it is difficult to obtain a bank license in Japan and banking regulations are relatively strict, there have been requests since the PSA came into force to abolish the upper limit for FTS providers. In response, on June 5 2020, the Japanese Diet passed a bill to amend the PSA for the purpose of revising the current regulatory framework for payment and settlement (Amendment). The Amendment entered into force on May 1 2021. The Amendment introduced a risk-based approach to regulating FTS by adding the following two types of FTS registrations:

  • Type I FTS providers, which are allowed to transfer amounts exceeding ¥1 million but, in addition to registration, must receive approval of their business plans; and

  • Type III FTS providers, which are only allowed to transfer amounts below ¥50,000 and must take measures to establish a flexible customer fund protection scheme.

Both Type I FTS and Type III FTS providers will be subject to stricter regulations on retention of monies. Due to the introduction of new types of FTS providers, the current FTS providers with an upper limit of ¥1 million will be categorised as Type II FTS providers. Regulations on Type II FTS providers will, in principle, remain unchanged (except for certain revisions to the current regulations).

The following table outlines the regulations that are applicable to each type of FTS under the amended PSA.


Upper limit


Restrictions on retention of monies

Method to protect in-transit money

Type I


Registration and approval of business plan

Stricter regulations (e.g. prohibited from accepting monies for a period longer than necessary for the fund transfer)

Requirement to protect in-transit money by way of statutory deposit, bank guarantee or trust agreement

Type II

¥1 million per transfer

Registration only

Existing regulations (e.g. required to take measures to prevent retention of monies unrelated to the fund transfer)

Type III

¥50,000 per transfer

Registration only


Stricter regulations (e.g. prohibited from retaining monies exceeding ¥50,000 for each customer)


Flexible customer fund protection scheme: instead of statutory deposit, bank guarantee or trust agreement, simple deposit in a segregated bank account is sufficient


Shotaro Inoue

Associate, Nagashima Ohno & Tsunematsu


Gift this article