A top shot of two people sitting opposite each other at the table with a laptop and a big piece of paper with a word "Finance" on it

In Japan, the majority of businesses providing financial services, especially to the citizens or residents of Japan, require a license. Depending on the type of business and the nature of its services there are different types of licenses and registration options available. In this guide, we give a high-level overview of what constitutes a financial service, what kinds of licenses there are, and how to obtain them, as well give examples of the common types of financial business available for foreigners in Japan.

Definition of Financial Business

It is difficult to define financial business precisely since the definition of a “business” significantly varies from industry to industry. Generally speaking, any business that provides financial services as the primary line of its activity can be called a financial business. As a minimal requirement, a business should be operating:

  • continuously
  • in the interest of the public
  • to receive profits

All sorts of institutions that specialize in financial services are the main actors in the finances and financial systems.

Financial Crimes

When providing financial services in Japan it is important to remember that Japanese laws and regulations are strict and financial crimes are severely punished with not only high fines but also imprisonment for all the involved regardless of whether the criminal act has taken place or was only in the preparation phase. This might include, but not limited to:

  • Corporate fraud,
  • Bribery and corruption,
  • Insider dealing and market abuse,
  • Money laundering,
  • Terrorist financing, etc.

The main laws regulating financial business in Japan are:

More information about what constitutes a financial and corporate crime, what types of frauds there are, as well as what kinds of relevant regulations are in place, and how controlling institutions and organs orchestrate the work of financial business in Japan can be found here.


What is a Financial License?

When providing financial services as the primary line of one’s business, financial license acts as proof of one’s relevant qualification and grants market entry for providers of financial services (financial businesses).

Why Do You Need a License?

A license is needed to ensure the protection of depositors and investors, maintenance of the financial system stability, and ensuring the financial integrity of the market.

Majority of the financial institutions, including financial businesses, are operating in accordance with the financial regulations. On the one hand, these regulations protect depositors and investors from moral hazards and adverse selections resulting from the information asymmetry as well as credit and market risks. On the other hand, in the case of indirect financing, it is important to maintain the stability of the crediting system by maintaining its proper management and funding, while in the case of direct financing it is important to maintain the stability of the financial system in order to preserve the financial integrity of the market.

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Types of Licenses

A quite typical question is whether a certain business needs a license, and if so, what kind of license. Financial licenses can be divided into several categories depending on how difficult it is for a business to enter the market. Below we list them in a descending order starting with the one that has the most difficult requirement for market entry.

Permits (許可, kyoka), licenses (免許, menkyo), and approvals (承認, shounin)

The permit provides a legal framework that allows a certain individual who met set requirements after a careful examination of an application to perform actions that are prohibited to regular citizens.

License or approval is quite similar to permits, but have stricter rules for obtaining it.

Authorization (認可, ninka)

The authorization allows a public agency to perform legal actions on behalf of a third party.

Registration (登録, touroku)

Registration is a procedure performed by a public administration and required to prove legal conformity of an individual in order for such an individual to perform certain actions or to enlist such an individual in the register.

Notification (届出, todokede)

Notification system prescribes that an individual/citizen must report to the public administration before or after such an individual carries out a certain action/deed.

Types of Registration

As explained by the Tokyo Metropolitan Government and Financial Service Agency of Japan in the Guidance to the Assets Management Industry in Japan, there are four principal types of businesses that foreign financial business are engaging with:

  • Discretionary investment management business for domestic institutional investors.
  • Solicitation and management of foreign funds to domestic investors.
  • Investment advisory business for domestic investors.
  • A comprehensive investment management business (including all the previous items).

These are financial instruments businesses and their providers are called financial instruments service operators (FIBOs). Depending on the type of services they provide, a company should be registered under one of the four following categories:

  1. Type I  Financial Instruments Business.
  2. Type II Financial Instruments Business.
  3. Investment Management Business.
  4. Investment Advisory Business.

Type I Financial Instruments Businesses license is the hardest to obtain, followed by Type II, and so on. If your business falls under several categories, then you need to obtain several licenses. In order to find out if your business qualifies as the financial instrument business, you can use the recently open consultation desk offered by the Financial Services Agency and the Tokyo Metropolitan Government.

The table below shows the correlation between the type of business and the correspondent type of registration.

Financial Instrument Business registration types
Financial Instrument Business registration types

How long does it take to obtain a license?

On average it takes around 4-6 months to get a license. However, if in the process you needed to make amendments to an application or provide additional documents, the process might take longer.

Where to Apply?

The main authority overseeing the financial sector in Japan is the Financial Service Agency (FSA) that is a part of the Cabinet Office. The Tokyo Metropolitan Government and The Financial Services Agency have set up a helpdesk that provides advice and guidance for foreign companies entering Japanese market. There you can get all the necessary information regarding your type of financial business.

Application Process

  1. Prior consultation. (3-4 months.) At this stage, the applicant needs to consult the Tokyo local finance office about the contents of their business, ways of organization and management, etc. A candidate should present a coherent and functional scheme of their business and operations, including information on internal rules, number of officers and employees, etc. The information provided during this stage will be later confirmed during the interview.
  2. Submission of documents. The set of documents differ for individuals and judicial persons. For more details on required documents and attachments, please see page 28 of the Guidelines.
  3. Review. (about 2 months.) The Financial Bureau will examine the documents and confirm the information an applicant has provided.
  4. Registration. If an application was accepted after the review, the company will be registered as FIBO and the date of registration, registration number and other relevant details will be published in a publically accessible Register.
  5. Association membership/ARD measures.  The company becomes a member of the financial instruments firm association that corresponds to their area of activities. It is not a compulsory step, but if the company is not a member of any association, it has to provide inner rules that are in line with the current rules of such association and measures of implementing these rules. Thus, it is recommended to join an association. Available options are the Investment trust Association, the Investment Advisors Association, type II Financial Instruments Firms Association. Complaint processing and dispute resolution measures (ADR measures) should be ready when starting operations.
  6. Deposit for operation and notification of deposit. Only for investment advisory businesses (JPY 5 mln.) and Type II financial instruments businesses (JPY 10 mln.). The deposit can also be made in bonds or bond certificates in accordance with a designation of the FSA Commissioner.
  7. Commencement of operations. Operations must start within 3 months from the day of registration. Otherwise, the registration will be canceled if the applicant cannot provide any justifiable reasons for why operations did not start on time.

Basic Requirements

Requirements may differ depending on the type of business license you are applying to. However, the minimum scope of requirements includes the following conditions:

  • The business in question must be registered as a financial instruments business operator (FIBO) beforehand.
  • Having a business office and representative in Japan (inapplicable to the IAA Business).
  • Meeting minimum capital and net worth requirements of:
    • at least ¥50 million for Type I Business,
    • at least ¥10 million for Type II Business,
    • ¥50 million in respect of DIM Business (inapplicable to IAA Business).
  • Meeting certain internal system requirements, such as having an appropriate organizational structure in place.


Financial Instruments Business Requirements, 1

Financial Instruments Business Requirements, 2



Most Common Occupations and Businesses That Require a License

Administrative Scrivener

They are also known as immigration lawyers, gyosei-shoshi lawyers or certified administrative procedures legal specialists.

Duties and responsibilities

Duties and activities of the scriveners are regulated by the Certified Administrative Procedures Legal Specialist Act. Scriveners usually work within a certain niche and the services they provide may vary significantly from person to person.  Some of the issues that the scrivener can help you with are:

  • wills and inheritance.
  • motor vehicle registration.
  • articles of incorporation and company minutes.
  • visa-related issues.
  • filing government licenses and permits.
  • drafting and giving advice on the drafting of documents to be submitted to government offices
  • providing legal advice.
  • act on behalf of their client in the procedure of submitting the documents to the public office.

Qualification and registration

To be allowed to perform the work of an administrative scrivener, a qualified individual must maintain a membership in the Administrative Scrivener Association and be certified by the Ministry of Internal Affairs and Communications of the Japanese Government. To prove own qualification a candidate must comply with one of the following attestation criteria:

  1. Pass the administrative scrivener test that assesses how well a candidate knows laws and regulations related to business such as the constitution, civil law, administrative and commercial laws as well as politics, economy, and society. The exam is held every year on the 2nd week of November in all 47 prefectures.
  2. Some professions are qualified to become an administrative scrivener without a test through a simple registration. Attorneys at law, certified public accountants, patent attorneys, and tax attorneys are automatically qualified to register as administrative scriveners without a test.
  3. A candidate that has held an administrative position at a government agency for 20 years can also be automatically registered as a scrivener.

Certified Public Accountant

The highest grade accounting license in Japan is called Certified Public Accountant, or CPA for short. Activities of CPAs are regulated by the Certified Public Accountants Act.

Duties and responsibilities

  • Audit/certification work: audit and certification of financial documents for listed companies, corporations, school corporations, social welfare corporations, etc. under the Company Law.
  • Non-audit certification work: acting as an internal accountant for a company, preparing and coordination financial documents, investigating or planning financial matters, consulting about financial affairs
  • Other work: acting as a tax consultant, administrative scrivener, partially judicial scrivener, or partial labor and social security attorney.

Qualification and registration

In order to obtain such a license, the candidate must:

  • Pass the CPA exam.
  • Have at least two years of experience in accounting or auditing.
  • undergo a 3-year education program in accountancy organized by the Japan Foundation for Accounting Education and Learning.

It is up to candidates whether they want to take an exam before or after completing their two years of practice.

Foreigners can become a CPA if they have:

  • An equal qualification from their home country.
  • The knowledge of the Japanese laws and regulations dealing with the accounting.
  • Passed a standard Japanese CPA examination.
  • Obtained an approval of the Office of the Prime Minister.

Certified Public Tax Accountant

Duties and responsibilities

  • Creation of tax documents: final return form, final return form, complaint forms
  • Representation of tax: filing and submission of tax documents to the tax office.
  • Tax consultation: counseling on topics of income amount, tax calculation and tax law treatment. Consultation on tax function performance covers improvement of tax process and controls. tax risk assistance includes identifying business key risks and assisting in controls monitoring.

Qualification and registration

If one wishes to become a Certified Public Tax Accountant a candidate must be registered with the Japan Federation of Certified Public Tax Accountants Association and perform one of the following actions:

  • Pass a certified public tax accountant exam in order to get a certificate, OR
  • register as a certified public accountant, OR
  • register as an attorney at law.


Duties and responsibilities

Due to the vagueness of the definition discussed above, not all of the financial services will need a license. Below are some examples of activities that will require a license:

  • The sale and purchase of securities.
  • Brokerage, intermediary or agency of the sale and purchase of securities.
  • Underwriting and offering securities.
  • Advisory services which are non-discretionary.
  • Management services which are discretionary.

Qualification and registration

In Japan, banks must not perform any activities related to securities and derivatives. If the bank wished to engage in these activities too, it must:

  • Establish a separate entity that will deal with securities and derivatives, AND
  • Obtain a license for such activities, OR
  • Register with the Prime Minister of Japan.

More detailed information on banking license can be found from our special banking guide.


There are no specific qualifications or certifications requirements in order to become a consultant in business, management or human resources. However, if you wish to start a recruitment services agency you need to obtain an appropriate license to do so. Sometimes consultants may be certified as Public or Tax Accountants.

Virtual Currency Exchange

Japan has implemented a rather tight regulatory framework for almost all types of services and businesses that handle cryptocurrencies in the light of recent exchange collapses and theft cases. See our guide on obtaining a license for provision of virtual currency exchange services in the separate guide.


The majority of activities that fall under the definition of financial business require a license of a certain type. Depending on the nature of the business obtaining a license can be more or less difficult since requirements and processing times may vary significantly. The average estimate for getting a license is 4-6 months, provided that there have been no delays during the application and review stages.

Some of the most common examples of financial business are administrative scrivener activities, certified public accountant and certified public tax accountant services,  banking, virtual currency exchange, consulting, etc.

Operation in these areas without a license is a financial crime that can lead to significant fines and even imprisonment. Make sure the Financial Services Agency about what kind of license your business requires and what documents you need to prepare through the consultation desk.

Financial License FAQ

What will happen if I operate without a license?

You might need to pay fine of up to 500 million yen if you run a financial business without registration (license) as a FIBO. Moreover, all the responsible managers and employees of a company that did not obtain a license might be imprisoned for up to 5 years or ordered to pay up to 5 million yen in fines.

Will my fees be reimbursed if my application is declined?

No, the fees you pay are used to cover the work of inspectors examining the compliance of your documents and business. Regardless of the outcome, these works need to be performed, and fees are used to ensure payments for the inspectors.

Can I apply in English?

It is highly advised to seek the assistance of the Japanese speaking professionals since applications are done and processed in Japanese, especially during the initial stages.

Who can help me with application in Japanese?

You can seek the assistance of the Notary Public (Gyosei Shoshi) to prepare your documents and to assist you during inspections and interviews. Remember, however, that the whole process cannot be fully outsourced to the third party as the applicant should be physically resent during inspections and interviews.

How do I know if I need a license?

If you are not sure whether your business requires a license or not, you can contact the consultation desk jointly organized by the Tokyo Metropolitan Government and the Financial Services Agency.