デジタル決済・フィンテック: 日本 (2026)
Japan operates a mature, in-force licensing regime for non-bank payments and e-money under the Payment Services Act, administered by the FSA. The PSA creates distinct registration categories for Fund Transfer Service Providers (three tiers by ticket size), Prepaid Payment Instrument Issuers, Electronic Payment Instrument Service Providers (stablecoin exchange/intermediation), and Electronic Payment Service Providers (open-banking API intermediaries). The 2025 amendment package, effective 1 June 2026, extends the regime to foreign trust-type stablecoins, tightens asset-conservation rules, and creates a new crypto-asset / electronic-payment-instrument intermediary business.
主要なフレームワーク
Payment Services Act (PSA, Act No. 59 of 2009, as amended through 2025 — in force 1 June 2026); supervised by the Financial Services Agency (FSA) and Local Finance Bureaus. Supplementary regimes: Banking Act (open-banking APIs), Installment Sales Act (credit/BNPL, administered by METI).
要点
Three-tier Fund Transfer Service Provider licensing
Non-banks must register with the Local Finance Bureau as a Type I (unlimited, authorisation of business plan required), Type II (≤ ¥1 million per remittance) or Type III (≤ ¥50,000 per remittance) Funds Transfer Service Provider. Tiering was introduced by the 2020 PSA amendment to apply proportionate conduct, user-asset-protection and AML duties.
E-money / prepaid instruments (PPII regime)
Issuers of third-party-accepted prepaid payment instruments (including server-type e-money, QR-code wallets, prepaid cards) must register as Prepaid Payment Instrument Issuers under the PSA; own-brand issuers only need to notify once outstanding balances exceed ¥10 million. Issuers are subject to deposit of ≥50% of outstanding balance with a Legal Affairs Bureau for user protection.
Stablecoins as 'electronic payment instruments'
PSA amendments effective 1 June 2023 limited stablecoin issuance to licensed banks, trust companies and registered funds-transfer providers, and created a registration category for Electronic Payment Instrument Service Providers (handling/intermediation). A further FSA ordinance taking effect 1 June 2026 classifies qualifying foreign trust-type stablecoins (e.g. USDC-style) as electronic payment instruments usable in Japan, subject to equivalent foreign licensing, audited collateral and FSA-cooperable supervision.
Open banking under the amended Banking Act
The 2017 Banking Act amendment introduced a registration regime for Electronic Payment Service Providers (denshi kessai tō daikō gyōsha) and obliged banks to publish open-API policies and contract with registered providers. Over 130 banks have implemented APIs; the Zengin interbank network launched a standardised API Gateway (replacing the legacy Relay Computer) in 2025, with Wise becoming the first non-bank to settle via it in 2025.
Instant-payment rails: Zengin System and overhaul to 2030
Domestic yen credit transfers run on the Zengin System operated by the Japanese Banks' Payment Clearing Network, with final settlement over the BOJ-NET at the Bank of Japan. The Clearing Network published a blueprint to replace the ~50-year-old core by 2030, with a build/no-build decision due by end of FY2026.
BNPL regulated indirectly via Installment Sales Act
There is no bespoke BNPL law. Where deferred-payment arrangements exceed two months, providers must register with METI as a Comprehensive or Individual Credit Purchase Intermediary under the Installment Sales Act and comply with credit-assessment and consumer-protection duties; shorter 'pay-in-30-days' models often sit outside the Act, and consumer-protection authorities continue to monitor the sector.
FSA Fintech Policy Office and single-window supervision
The FSA's Fintech Policy Office / Payment Services Monitoring Office licenses and supervises FTSPs, PPIIs, Crypto-Asset Exchange Service Providers and Electronic Payment Instrument Service Providers, and runs the FinTech Support Desk for pre-application guidance. METI shares oversight for credit cards and certain advanced payment services.
このページは便宜上翻訳されたものです。英語版が正式なものであり、法的助言ではありません。