Asia/JP/Comparables
Japan
Financial Services Agency
Split perimeter, in force. Cryptoasset exchange service providers under the Payment Services Act; electronic payment instruments (stablecoins) under the 2023 PSA amendments; security tokens under the FIEA. Overseas issuance does not, without more, land in either PSA category. There is no CIC, and no four-year fuse.
CESP
PSA
EPI
2023 PSA
Security tokens
FIEA
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- In force
CESP = CASP; EPI = ART/EMT analogue
- In force
Digital securities — outside CIC
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| Rule 100 crypto asset | Cryptoasset (PSA) vs EPI vs ERTR (FIEA) | Partial | Three drawers. RCA has two filters and a wrapping. |
| Rule 200 / 300 | FIEA public offering if a security token; otherwise no CIC exemption | No analogue | Japan did not write a Howey holiday. |
| Intermediary | Registered cryptoasset exchange service provider | Analogue | Hot/cold wallet segregation, travel rule, order-book rules — post-Mt.Gox DNA. |
| Rule 400 | None | No analogue | A cryptoasset does not cease to be one by Form TR. |
Analysis
What the file is
Japan’s distinctive 2020s overlay is the electronic payment instrument: a fiat-referenced token issued by a bank or a licensed trust-like issuer, with redemption at par. Cryptoasset exchange service providers remain a PSA registration category with some of the world’s most specific safeguarding rules (the 2010s hack cycle wrote them). Security tokens are FIEA electronically recorded transferable rights. Counsel who flatten these three into “Japan licensed the token” will mis-advise on a US CIC.
Research
The record
- FSA publishes the list of registered cryptoasset exchange service providers. That list is the public evidence.
- EPI issuance is closer to MiCA EMT / HK Cap. 656 / MAS SCS than to Rule 200.
- FIEA tokenised-security offerings can be done under prospectus or under qualified-institutional exemptions — the digital-security path RCA expressly does not occupy.
Ideation
What to file
- Safeguarding: Japan’s hot/cold split and residual-risk insurance are the investor-protection comments to put against Rule 200’s website-only, no-financials design — if you are a retail advocate. If you are an issuer, they are the reason you would rather file in the US.
- Do not analogise EPI redemption at par to Rule 400. One is a payments promise. The other is a Howey funeral.
Analysis
What the file is
Japan’s distinctive 2020s overlay is the electronic payment instrument: a fiat-referenced token issued by a bank or a licensed trust-like issuer, with redemption at par. Cryptoasset exchange service providers remain a PSA registration category with some of the world’s most specific safeguarding rules (the 2010s hack cycle wrote them). Security tokens are FIEA electronically recorded transferable rights. Counsel who flatten these three into “Japan licensed the token” will mis-advise on a US CIC.
Primary sources on file
Japan FSA — Payment Services Act and FIEA cryptoasset / electronic payment instrument rules
Financial Services Agency of Japan/1 Jun 2023/RCA review 22 Jul 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.