Japan payment license stack

Confidence: Likely Updated 2026-05-22 Review by 2026-11-22 Sources 12 Machine-translated Original (JA)
#JapanFG#legal#payments#funds-transfer#prepaid#EPI
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Overview

Japan payment products can combine several public-regulatory categories: funds transfer, prepaid payment instruments, electronic payment agency, electronic payment instruments, electronic payment handling, credit / installment sales, card acquiring, and bank-account direct payment. A wallet, checkout product, code-payment service, or stablecoin-linked service can therefore have more than one legal route.

This page belongs to JapanFG legal / financial licenses and links to payments domain, funds transfer vs prepaid boundary, funds-transfer registry, prepaid issuer registry, credit / card registry, bank API route, Japan stablecoin regulatory landscape, Japan ECISB license, and Progmat stablecoin route.

License Stack Matrix

FunctionMain public categoryPrimary law / routeApproval / registrationFinWiki route
Non-bank remittance / wallet transfer資金移動業者Payment Services ActRegistrationfunds-transfer-service-providers-japan-index
Stored value for third-party paymentsThird-party prepaid payment instrument issuerPayment Services ActPrior registrationprepaid-payment-instrument-issuers-japan-index
Self-use stored valueSelf-use prepaid payment instrument issuerPayment Services ActFiling after threshold conditionsfunds-transfer-vs-prepaid-boundary
Bank account information / payment instruction電子決済等代行業者Banking Act routeRegistrationjapan-bank-api-payment-agency-route
Stablecoin / EPI sale, exchange, intermediation, custody-like handling電子決済手段等取引業者Payment Services ActRegistrationjapan-ecisb-license
Bank-commissioned electronic deposit-claim handling電子決済等取扱業Banking Act routeRegistrationbank-license-and-baas-boundary
Credit card / installment / BNPLInstallment Sales Act / credit-purchase routeMETI routeRegistration where applicablecredit-purchase-card-operators-japan-index, japan-bnpl-credit-purchase-boundary
Merchant PSP / acquiringMerchant-contracting / PSP / card acquiring routeInstallment Sales Act, card rules, service termsDepends on rolecard-acquiring-japan-stack, psp-merchant-settlement-risk
Bank-account direct paymentBank Pay / J-Debit / Cotra / bank direct debit routeNetwork / scheme / bank-account routeParticipant and scheme routeaccount-to-account-payment-japan

Funds Transfer Route

The funds-transfer route is a Payment Services Act registration category for non-bank remittance. FSA materials identify the current three-type structure:

TypePublic description in FSA materialsBoundary field
Type IRoute for transfer needs above JPY 1 millionHigher-value funds-transfer category.
Type IILegacy core funds-transfer categoryMain non-bank remittance / wallet-transfer category.
Type IIILower-value transfer routeLow-value transfer category.

Public verification uses the FSA funds-transfer page, FSA funds-transfer list, entity terms, and registration number. The balance is not recorded as a bank deposit unless the product terms and legal entity identify a licensed bank deposit route.

Prepaid Payment Instrument Route

The prepaid route is a Payment Services Act route for stored value. The main public split is between self-use and third-party prepaid payment instruments.

CategoryPublic fieldPublic verification
Self-use prepaid instrumentIssuer and eligible merchant / service scope are linked to the issuer’s own group or own service route.FSA prepaid Q&A, issuer disclosure, terms.
Third-party prepaid instrumentStored value can be used with third-party merchants or services under the instrument route.FSA third-party prepaid issuer list and service terms.
Self-use threshold fieldFSA Q&A states that a self-use issuer has filing duties once unused balance exceeds JPY 10 million on the base date.FSA FinTech Support Desk Q&A and issuer records.
Third-party approval fieldThird-party prepaid issuer route uses prior registration.FSA third-party prepaid issuer list.

The prepaid route is a merchant-payment / stored-value route. It is separate from general remittance unless another route, such as funds transfer, is also present.

Electronic Payment Instrument Route

The Payment Services Act side uses 電子決済手段等取引業者 for electronic payment instruments transaction business. Public FSA EPI materials connect this route to stablecoin / electronic-payment-instrument sale, purchase, exchange, intermediation, and custody-like handling.

The Banking Act side uses 電子決済等取扱業 for bank-commissioned electronic handling of deposit claims. This route is recorded separately in Japan bank license and BaaS boundary because the public legal category is not the same as the Payment Services Act EPI transaction route.

Product-Layer Examples

Product surfacePossible legal components
QR walletFunds-transfer registration, prepaid issuer registration, merchant PSP / acquiring, bank API, credit-card linkage.
Travel walletFunds transfer, prepaid, foreign-exchange / remittance terms, card scheme, bank agency where disclosed.
BNPL checkoutInstallment-sales / credit-purchase route, merchant-contracting, PSP settlement, credit screening.
Bank-account paymentBank account, bank API / electronic payment agency, account-direct merchant onboarding, refund / cancellation controls.
Stablecoin paymentEPI transaction route, electronic payment handling route, issuer / trust / bank classification, wallet or exchange registration where applicable.
BaaS deposit walletLicensed bank, partner UI, bank agency or electronic payment agency route where disclosed.

Public Record Fields

FieldSource route
Operator legal nameFSA / METI registry and company disclosure.
Registration categoryFunds transfer, prepaid, electronic payment agency, EPI, credit / card, bank agency, or electronic payment handling.
Registration numberRegistry row where available.
Funds-transfer typeType I, Type II, or Type III where disclosed by the FSA list / materials.
Prepaid classificationSelf-use or third-party prepaid payment instrument.
FSA list as-of dateFSA operator-list line or registry file.
Service scopeProduct terms, official service page, and regulator list.
Balance typeDeposit, prepaid balance, funds-transfer balance, credit receivable, electronic payment instrument, or bank deposit claim.
Merchant routeAcquirer, PSP, payment facilitator, Bank Pay / J-Debit route, or scheme route.
User protection / segregationRegulator guidance, terms, and disclosure documents.

Sources

  • e-Gov: Payment Services Act.
  • FSA: licensed / registered operator lists.
  • FSA: funds-transfer service provider page and registry.
  • FSA: prepaid payment instruments policy pages and issuer registry.
  • FSA: FinTech Support Desk Q&A.
  • FSA: 2020 Payment Services Act reform explanation.
  • FSA: crypto-asset / electronic payment instrument policy pages.
  • FSA: electronic payment instruments transaction business page.
  • FSA: electronic payment handling business page.
  • METI: Installment Sales Act registered operator lists.