How to Get a Crypto License in Japan: FSA Registration Under the Payment Services Act and the Move to the FIEA

The short version: Japan has no stand-alone “crypto licence”. A company that buys, sells or exchanges crypto-assets for customers, intermediates those trades, or holds crypto-assets for others needs to be registered as a crypto-asset exchange service provider (暗号資産交換業者) under article 63-2 of the Payment Services Act (PSA). The application goes to the Local Finance Bureau for the area of the head office, after a pre-consultation with the FSA that its own guide puts at about six months. The company must be a stock company (or a foreign exchange with an office and a resident representative in Japan) with at least ¥10 million of capital and non-negative net assets. The registration and license tax is ¥150,000. That is the route today. Once the main provisions of the 2026 amendment take effect (by 22 Jul 2027 at the latest, by our calculation), crypto-asset trading moves under the Financial Instruments and Exchange Act (FIEA), and new firms will need FIEA article 29 registration instead (our explainer on the amendment).

VASP Tracker is an independent information service. It is not affiliated with the Financial Services Agency (FSA), the Local Finance Bureaus or the Japan Virtual and Crypto assets Exchange Association (JVCEA), and this is not legal advice. Japanese terms and quotations are our translations; the Japanese texts prevail. Article numbers refer to the laws as published on e-Gov and the FSA site on the date below.

What Applies Today and What Changes

Two regimes matter for anyone planning an application now:

• Today: the Payment Services Act. “Crypto-asset exchange business” covers (1) buying, selling or exchanging crypto-assets, (2) intermediating, brokering or acting as agent for those trades, (3) managing customers' money in connection with them and (4) managing crypto-assets for others (PSA art. 2(15)). Only companies registered under PSA art. 63-2 may carry it on. The detailed rules sit in the Cabinet Office Ordinance on Crypto-Asset Exchange Service Providers (the Ordinance) and in volume 3, section 16 of the FSA's Guidelines for supervision (Guidelines 16).
• Next: the FIEA. The 2026 Act moves “crypto-asset trading business” (暗号資産取引業) into the FIEA. The FSA's explanatory material says rules equivalent to those for Type I financial instruments business will apply, with the current safe-custody rules (in principle, cold wallets) carried over (FSA explanatory material). Registration will be under FIEA article 29, and existing Type I firms will need a change registration instead (same source).

The Act's Supplementary Provisions also decide what happens to a PSA application that is still pending on the effective date: it is processed under the old rules (Supplementary Provisions art. 39; Act text). The firm then sits in the transition described below. The dates are in our explainer; this page covers the procedure.

Who Needs to Register

The test is the activity, not the label. If a firm does any of the four activities in PSA art. 2(15) as a business for people in Japan, it needs registration. Two points catch overseas platforms:

• An overseas crypto exchange that is not registered under PSA art. 63-2 must not solicit people in Japan to carry out any of those activities (PSA art. 63-22).
• The FSA publishes warnings to operators that did crypto-asset exchange business without registration, and since 12 August 2026 the penalty for unregistered business is higher. The FSA's material describes it as a rise from up to 3 years' imprisonment under the PSA to up to 10 years under the FIEA (FSA; our list of FSA warnings).

As of 30 Sep 2026, 27 companies are on the FSA register (our register view, analysis).

Step 1: Pre-Consultation and the FSA Questionnaire

In practice the application starts long before the formal filing. Guidelines 16 (III-2-1) says the registration review, including the pre-consultation (事前相談), follows the FSA's published registration review process. It also says the review is substantive: it covers the business plan, internal control and governance, and the documents and evidence behind them, and it includes on-site visits and hearings with officers (Guidelines 16). The FSA's 2018 process note sets out three stages (FSA, Oct 2018):

1. Hearing with officers on the business plan, including the system plan, and the basic approach to risk management.
2. Document review against the self-regulatory rules, covering:
   • the risks of the crypto-assets handled;
   • management and internal audit;
   • user protection and the segregation of customer assets;
   • user information;
   • management of outsourcees;
   • system risk;
   • AML/CFT.
3. On-site review of whether these arrangements work in practice.

The pre-consultation is organised around the FSA's registration review questionnaire (暗号資産交換業者の登録審査に係る質問票). The current version was revised on 21 June 2024 to add AML/CFT items to check before a firm opens for business (FSA, 21 June 2024). The questionnaire PDF is 78 pages. It is filed as a set of Excel files sent by e-mail, and it must be attached to the application as a reference document under Ordinance art. 6(18) (questionnaire). The Excel files are:

• a cover sheet;
• basic matters;
• internal control;
• system risk management;
• AML/CFT;
• self-issued token sales and third-party token sales.

Sections that do not fit the business model can be marked as not applicable, with reasons. In 2018 the FSA also published the main points it probes, for example:

• why the firm is entering the business;
• its 3–5 year plan;
• how it screens crypto-assets before listing them;
• how management identifies business and financial risks;
• how it runs internal audit.

(FSA, main issues)

Step 2: Company Form, Capital and Net Assets

The registration must be refused if the applicant does not fit one of these forms (PSA art. 63-5(1)(i)–(ii)):

• a stock company (株式会社);
• a foreign crypto exchange that is a foreign company with an office in Japan and a representative resident in Japan.

Guidelines 16 adds that the articles of incorporation must include crypto-asset exchange business among the company's purposes (Guidelines 16). Registration must also be refused if the trade name could be confused with another provider's (PSA art. 63-5(1)(vii)). The guidelines also check that it does not mislead users into thinking the firm is a public body or a bank.

The financial base is set by Ordinance art. 9 (Ordinance):

• capital of ¥10 million or more;
• net assets that are not negative;
• for a firm that manages customers' crypto-assets, net assets at least equal to the yen value of the crypto-assets it must hold to guarantee performance (履行保証暗号資産).

Guidelines 16 says the FSA reviews the financial base as follows (Guidelines 16):

• A new company provides its opening balance sheet and evidence such as bank balance certificates.
• The three-year income and expenditure plan is checked against realistic assumptions, including competition and the risk of systems becoming obsolete.
• The applicant attaches an estimate of the performance-guarantee crypto-assets for the first year, and net assets are compared against it.

The FSA does not publish a typical figure beyond the ¥10 million floor, and neither do we.

Step 3: Directors and Fit-and-Proper Grounds

PSA art. 63-5(1) lists grounds on which registration must be refused. Several concern the company itself:

• its PSA registration, or an equivalent foreign one, was cancelled within the last 5 years;
• it was ordered to close an electronic payment instruments business within the last 5 years;
• it was fined under the PSA, the FIEA, the Investment Deposit Act or equivalent foreign law within the last 5 years;
• it carries on another business judged contrary to the public interest.

The same article also covers the people. Registration must be refused if any director, auditor, executive officer or accounting advisor (or, for a foreign firm, the representative in Japan) falls into one of these groups:

• cannot perform the duties properly because of a mental impairment (Ordinance art. 9(2));
• is an undischarged bankrupt;
• was sentenced to imprisonment (拘禁刑) or a heavier penalty within the last 5 years;
• was fined under the PSA, the FIEA, the Investment Deposit Act, the Act on Prevention of Unjust Acts by Organized Crime Group Members or equivalent foreign laws within the last 5 years;
• was an officer of a provider within 30 days before its registration was cancelled, and 5 years have not passed since the cancellation.

Proof is document-heavy. Ordinance art. 6 requires the following for each officer:

• a residence certificate (a copy of the residence card for foreign nationals);
• an official certificate that the person is not subject to bankruptcy proceedings, or a pledge in the set form for foreign nationals;
• a curriculum vitae in the set form.

The applicant also files the following under Ordinance art. 6:

• a pledge that none of the refusal grounds applies;
• a list of shareholders;
• the CV of the person responsible for managing the business.

The application itself must name major shareholders holding 10% or more of the votes (Ordinance art. 5). Official certificates must be issued within the last 3 months. Documents in a foreign language need a Japanese translation, although some English documents may be filed with a summary translation (Ordinance art. 2).

Step 4: Systems, Asset Listing and JVCEA Membership

Most of the review time goes on systems. The PSA requires refusal if the applicant lacks systems to carry on the business properly and reliably, or systems to comply with the PSA chapter on crypto-asset exchange (art. 63-5(1)(iv)–(v)). Guidelines 16 points the review at the supervisory checkpoints in its parts II-1 and II-2, and calls out these points in particular (Guidelines 16):

• cross-border business;
• cash handling;
• mutual checks between staff;
• internal audit.

The attachments in Ordinance art. 6 show what the FSA expects to see:

• an organisation chart, including the internal control function;
• internal rules;
• the customer contract documents;
• outsourcing contracts;
• arrangements for alternative dispute resolution, either with a designated dispute resolution body or, where none exists, complaint and dispute measures of the firm's own;
• an explanation of each crypto-asset handled.

Guidelines 16 also lists what an outsourcing contract must cover, from compliance with the law to fees and facilities.

Three conduct obligations shape the build from day one (PSA art. 63-11):

• customers' money must be kept separate and entrusted to a trust company or similar;
• customers' crypto-assets must be kept separate and, apart from a limited amount, managed by a method set by the Ordinance (in practice, cold storage);
• the segregation must be audited periodically by a certified public accountant or audit firm.

On JVCEA membership, registration must be refused if the applicant neither joins a certified payment services association nor adopts internal rules equivalent to the association's rules and systems to follow them (PSA art. 63-5(1)(vi)). The application names the association the firm will join (Ordinance art. 5), and Guidelines 16 says the explanation of each crypto-asset follows the association's format. The suitability of each crypto-asset is reviewed as part of the application, and any later change to the assets handled or to the business methods needs prior notification to the authorities (PSA art. 63-6).

Step 5: Filing, Fee and Decision

The formal application uses Form No. 1 of the Ordinance (Form No. 2 for a foreign crypto exchange) (Ordinance art. 4). It is filed with the Local Finance Bureau that has jurisdiction over the head office (or the main office in Japan), which keeps the register (Ordinance arts. 2 and 8). The FSA publishes the forms (FSA forms page), and the Kinki Local Finance Bureau, for example, has its own page for applicants in its area (Kinki LFB). Under PSA art. 63-3, the application states:

• the trade name and address, and the capital;
• the offices;
• the directors and auditors;
• the crypto-assets to be handled;
• the content and methods of the business;
• any outsourcees;
• other businesses carried on.

The applicant also attaches the financial documents and the three-year income and expenditure projection (Ordinance art. 6).

Fee: registration as a crypto-asset exchange service provider is subject to the registration and license tax of ¥150,000 per registration (Registration and License Tax Act, Appended Table 1, item 49(6); e-Gov). We did not find any other official application fee.

Decision: the authority sends a registration notice (Ordinance art. 7). A refusal must be notified with reasons (PSA art. 63-5(2); Ordinance art. 10). Registration numbers are assigned in sequence by each Local Finance Bureau (Guidelines 16).

AML and the Travel Rule

A registered crypto-asset exchange service provider is also a “specified business operator” under the Act on Prevention of Transfer of Criminal Proceeds (art. 2(2)(xxxii); e-Gov). There is no separate AML registration. The duties apply from the first customer:

• Verification at the time of transaction: the customer's identity, the purpose of the transaction, the customer's occupation or business and the beneficial owner (art. 4).
• Suspicious transaction reports (art. 8).
• The travel rule: when a provider transfers crypto-assets to another provider in Japan or a foreign provider, it must pass on the originator and beneficiary information (art. 10-5).
• Internal measures: training, internal rules and an officer responsible (art. 11).

Since the June 2024 revision, the questionnaire's AML/CFT section is checked before opening (FSA). Guidelines 16 tells reviewers to use the FSA's annual AML/CFT report form as a reference (Guidelines 16). The FSA's AML/CFT guidelines and FAQs are collected on its AML page (FSA AML/CFT).

Timeline and the FIEA Transition

How long a PSA registration takes. The FSA Fintech Monitoring Office published a time guide in January 2019 (FSA time guide):

• receipt of the questionnaire answers is acknowledged immediately;
• the FSA checks within about 2 weeks whether corrections are needed;
• hearings and document review take about 3–4 months;
• the on-site visit takes 1–2 weeks;
• from the start of that process to registration takes about 6 months in total;
• of that, about 1–2 months fall between formal acceptance of the application and the decision.

Time spent on corrections is not counted, and the main process starts only once corrections are complete. The guide also says the FSA points out refusal grounds during the pre-consultation. The FSA has not published processing statistics that would show how these targets have held up.

What the 2026 Act does to applicants and registrants (Supplementary Provisions; Act text):

• Existing PSA registrants that are not FIEA firms may carry on for 6 months from the effective date, for existing customers and the crypto-assets they already handle (art. 8). If they apply for FIEA art. 29 registration within those 6 months, they may continue until the decision, but not beyond 2 years. In the meantime most FIEA conduct rules apply to them.
• Information on the assets handled. Existing PSA registrants must publish information on the crypto-assets they handle within 3 months (art. 8(5)).
• Existing Type I FIEA firms that already run a crypto business need a change registration under FIEA art. 31(4), with the same 6-month and 2-year mechanics (art. 9).
• Notification. Within 2 weeks of the effective date, transitional firms must notify the authorities of their name and address, offices, officers, the assets they handle and the content and methods of the business (art. 10). For firms registered under the art. 39 route described in the next item, the 2 weeks run from registration. Failing to notify, or notifying falsely, ends the transitional permission.
• Pending applications are decided under the old PSA rules (art. 39). The old registration and license tax treatment also continues for them (art. 39(2)).
• PSA history counts. A PSA cancellation within 5 years is a refusal ground under the new FIEA art. 29-4(1)(viii), and the same applies to officers (art. 12).

Under the amended FIEA, crypto-asset trading business joins the refusal grounds that today apply to Type I firms (Act text; current text on e-Gov):

• capital and net assets of at least amounts to be set by Cabinet Order;
• a stock company with a board and auditors or committees;
• a capital-adequacy ratio test;
• suitability of major shareholders.

The amended registration and license tax table drops the separate PSA crypto-exchange entry. Today's FIEA art. 29 registration entry is ¥150,000 per registration (item 41(1)).

What Is Not Yet Public

As of 3 Nov 2026, we found none of the following on the FSA site:

• the Cabinet Order fixing the effective date of the main provisions;
• the FIEA Cabinet Order and Cabinet Office Ordinance amounts for capital and net assets for crypto-asset trading business;
• the planned Ordinance rules on asset screening, suitability, trade surveillance and the liability reserve (FIEA art. 46-5), which the FSA's material says are still to come (FSA);
• a revised questionnaire or guidelines for FIEA crypto registration.

We do not estimate these here. Until they are published, the PSA route above is the only procedure the FSA has fully documented.

Japan Next to the UK and MiCA

• Who decides. In Japan, a Local Finance Bureau decides on delegated FSA authority after an FSA-led pre-consultation. In the UK, the FCA authorises firms under Part 4A. Under MiCA, the national competent authority of the home member state does (UK guide, MiCA guide).
• Time. Japan's published guide is about 6 months, with corrections time not counted. The UK has a 6-month statutory decision period for complete applications. MiCA sets 25 working days for the completeness check plus 40 working days for assessment.
• Money. In Japan: ¥10 million minimum capital, non-negative net assets and a ¥150,000 registration and license tax. In the UK: FCA application fees of £2,820–£28,150 and capital of £75,000–£750,000. Under MiCA: minimum capital of €50,000–€150,000, depending on the services.
• Distinctive to Japan. Association membership or equivalent rules, the per-asset suitability review and mandatory cold-wallet-style custody are conditions of registration rather than supervisory follow-ups.

Australia is also mid-reform. Applications for its new platform authorisations open on 8 April 2027 (Australia guide).

Practical Checklist Before You File

1. Map each activity against PSA art. 2(15); if you serve Japan from abroad without registration, stop soliciting (art. 63-22).
2. Decide whether your filing will land before or after the main FIEA date (by 22 Jul 2027 at the latest, by our calculation); a PSA application pending on that date is processed under the old rules, then enters the transition.
3. Set up or confirm a stock company with crypto-asset exchange business in its purposes, at least ¥10 million capital and a plan for net assets above the performance-guarantee estimate.
4. For a foreign firm: an office in Japan and a representative resident in Japan.
5. Check every director, auditor and executive officer against PSA art. 63-5(1)(xii); order certificates no more than 3 months before filing.
6. Complete the FSA questionnaire (June 2024 version) and the first-year guarantee estimate.
7. Draft internal rules, segregation and trust arrangements, cold-storage method, CPA audit engagement and outsourcing contracts.
8. Prepare the per-asset explanations in the association's format and decide on JVCEA membership (or equivalent rules).
9. Build the AML programme: verification at the time of transaction, suspicious transaction reporting, the travel rule and a responsible officer.
10. Plan for hearings with officers and an on-site visit; translate non-Japanese documents.
11. Budget the ¥150,000 registration and license tax and about 6 months from the start of the main review, plus correction time.

Checked against the Payment Services Act, the Ordinance, the Registration and License Tax Act and the Act on Prevention of Transfer of Criminal Proceeds on e-Gov, FSA Guidelines 16, the FSA questionnaire and process notes, and the 2026 Act text on 3 Nov 2026. Not published, so not estimated here: the main effective date, FIEA capital and net asset amounts for crypto-asset trading business, FIEA-era review guidance and FSA processing statistics.