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Installment Sales Act 2020 Amendment

Confidence: Likely Updated 2026-05-19 Review by 2026-11-15 Sources 5 Machine-translated Original (JA)
#JapanFG#legal#license#installment#credit#BNPL
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TL;DR

The 2020年 amended Installment Sales Act (令和2年 Act No. 第64号) is an amendment that, in step with the digitalization of credit cards / deferred payment / BNPL, established (1) certified comprehensive credit purchase intermediary operators, (2) registered small-amount comprehensive credit purchase intermediary operators, (3) card-number management on the payment-agency / acquiring side, (4) the digitization of document delivery, and (5) business-suspension orders.

For JapanFG, this is the foundational legislation for reading BNPL such as paidy, card issuance / merchant networks such as jcb, credit-sales companies such as orico / jaccs, and the credit / installment license layer of INDEX. An important boundary is that BNPL ≠ automatically a registered small-amount comprehensive credit purchase intermediary operator. In METI’s list of registered operators, as of the end of 令和8年4月 the number of registered small-amount comprehensive credit purchase intermediary operators is 0 社, and in the 2024年 administrative-disposition materials, Paidy is treated as a registered comprehensive credit purchase intermediary operator (Kanto (Comprehensive) 第122号).

Regime Map

LayerWhat it coversJapanFG reading
割賦販売 (installment sales)A transaction in which an operator sells designated goods, etc. to a consumer in installments of 2 months or more and 3 or more paymentsTraditional installment sales. A separate layer from BNPL / card acquiring
ローン提携販売 (loan-tied sales)A structure in which the seller, etc. guarantees the borrowing of funds for purchasing goodsThe boundary with purpose-specific loans becomes an issue
包括信用購入あっせん (comprehensive credit purchase intermediation)A business that advances the sale price via credit card, etc., and collects it from the consumer over more than 2 monthsjcb, orico, jaccs, paidy
個別信用購入あっせん (individual credit purchase intermediation)Credit sales / shopping credit for individual goods / servicesImportant for credit-sales companies, durable consumer goods, and education / beauty loans, etc.
クレジットカード番号等取扱契約締結事業者 (operators concluding contracts for handling credit-card numbers, etc.)Those who conclude contracts permitting merchants to handle cards. Acquirers and some PSPsThe regulatory aspect of acquiring / PSP / merchant onboarding
カード番号等取扱業者 (operators handling card numbers, etc.)Entities bearing the duty to appropriately manage card numbers, etc.PCI DSS, non-retention, fraud prevention

The METI FAQ organizes the regulatory targets in the deferred-payment field into “installment-sales operators,” “loan-tied-sales operators,” “credit purchase intermediary operators,” “operators handling credit-card numbers, etc.,” and “operators concluding contracts for handling credit-card numbers, etc.”

2020 Amendment

METI explains the background of the 2020年 amendment as “small-amount, high-frequency deferred-payment services,” “entry into deferred payment by companies from other industries,” and “the expansion of settlement via the internet and smartphone devices.” Promulgation was on 2020-06-24, and enforcement on 2021-04-01.

1. Certified comprehensive credit purchase intermediary operators

A special exception that uses a credit-screening method per operator in place of the conventional uniform “comprehensive payable-amount-estimate investigation.” While certified operators can use their own data and technology, they bear the management of expected delinquency rates and actual delinquency rates, periodic reporting, and the risk of improvement orders.

2. Registered small-amount comprehensive credit purchase intermediary operators

A registration system for operators conducting comprehensive credit purchase intermediation businesses with a credit limit of 10万円 or less. Although regulation was rationalized with “small-amount, high-frequency, smartphone-completed” deferred-payment services such as BNPL in mind, in METI’s list of registered operators as of the end of 2026-04, the registered operators in this category number 0 社.

For this reason, when reading paidy, it is necessary to separate “the 2020 amendment created a system mindful of BNPL” from “Paidy is actually a registered small-amount operator.” At least in the Kanto Bureau of Economy, Trade and Industry materials of 2024-10-03, Paidy received an administrative disposition as a registered comprehensive credit purchase intermediary operator.

3. Expansion of the entities managing card numbers, etc.

The 2020 amendment also broadened the entities bearing the duty to appropriately manage card numbers, etc. Payment-agency operators, code-payment operators, services that store and reuse card numbers, and operators that provide card numbers in deferred-payment settlement, among others, can become subject to it.

In practice, the acquiring / PSP boundary is important. The METI FAQ explains that where a PSP is comprehensively authorized by an acquirer and holds the substantive final decision-making authority over merchant contracts and merchant management, registration is required on the PSP side. On the other hand, where the PSP performs only the initial screening and the registered acquirer reserves the final judgment, registration on the PSP side may become unnecessary.

4. Digitization

In step with smartphone- and PC-completed services, document-delivery regulation was adjusted in the direction of permitting the electronic provision of usage statements, membership terms, etc. However, out of consideration for the digital divide, notification that a request for document delivery is possible, etc., is required.

5. Administrative dispositions

Supervisory means such as business-suspension orders were established for registered comprehensive credit purchase intermediary operators and registered small-amount comprehensive credit purchase intermediary operators. The 2024-10-03 improvement order against Paidy is a case showing that this layer actually takes effect on BNPL / deferred-payment operators.

JapanFG Relevance

  • paidy: Because BNPL / deferred payment has a structure of advancing the sale price of goods and collecting it from the consumer at a later date, a regulatory analysis of comprehensive credit purchase intermediation is necessary. In the 2024年 administrative disposition, deficiencies in the operation of the comprehensive payable-amount-estimate investigation and the over-extension-of-credit prevention duty became an issue.
  • jcb: Depending on which of the issuer / acquirer / network functions one holds, multiple layers — comprehensive credit purchase intermediary operator, operator concluding contracts for handling card numbers, etc., and operator handling card numbers, etc. — overlap.
  • orico / jaccs: Credit-sales companies tend to have both comprehensive and individual credit purchase intermediation aspects. The 2020 amendment broadened the scope for AI / data-driven credit, but supervision over delinquency rates, designated credit information agencies, and over-extension-of-credit prevention remains.
  • INDEX: The core of the “deferred payment / installment / card credit” licenses, alongside the Banking Act, the Money Lending Business Act, and the Payment Services Act. Where it is structured not as lending but as advance payment / credit purchase intermediation, METI jurisdiction comes to the fore, not just the FSA.

Boundary Cases

CaseLikely treatmentWatch point
Next-month lump-sum BNPLDepends on the period and contract form. Confirm whether it falls under credit purchase intermediation collecting over more than 2 monthsLook at the legal payment period and advance-payment structure, not the “BNPL” trademark / UX
3-installment / 6-installment / 12-installment deferred paymentApproaches comprehensive credit purchase intermediationPayable-amount estimate, designated credit information agencies, over-extension-of-credit prevention
Virtual-card-type BNPLEasily falls under comprehensive credit purchase intermediation regulation as the issuance / granting of a card, etc.In the Paidy administrative disposition, the credit-limit management of cards, etc. became an issue
PSP performs merchant screening on behalf of othersWhether registration is required changes depending on who holds the final decision-making authorityThe actual contractual relationship between the acquirer and the PSP
Purpose-specific loanEven a monetary loan can become individual credit purchase intermediation if it has a close connection with the sales contractTie-up with the seller, solicitation, integration of procedures
Code-payment linkageThe duty of storage, linkage, and fraud prevention for card numbers, etc., becomes an issueNon-retention, PCI DSS, EMV 3-D Secure, etc.

Sources

[!info] 校核状态 confidence: likely (2026-05-19). The outline of the 2020 amendment, the enforcement date, the small-amount registration system, the acquiring / PSP boundary, and the Paidy administrative disposition are confirmed in METI / Kanto Bureau of Economy, Trade and Industry materials. The applicability of individual companies’ current services on a service-by-service basis requires additional confirmation of terms, registration information, and service specifications.