Ashurst Perkins Coie monthly Japanese finance regulatory update – June 2026

Welcome to the June edition of our Japanese finance regulatory update, which aims to provide you with in-depth analysis and practical insights on select legislative updates that bring significant implications to Japanese corporates and international companies operating or investing in Japan. 

We hope you find these updates useful, and we look forward to having a further discussion with you on the topics and any other regulatory issues.

Introduction

This edition focuses on cross-border collection and payment agent services (shuno daiko) — a space that, until recently, operated largely outside the regulatory perimeter. As of June 1, 2026, providers of cross-border collection and payment services are now required, in principle, to obtain a licence under the Banking Act of Japan or the Payment Services Act ("PSA") of Japan. While certain exemptions apply, the reform carries significant implications for international clients involved in cross-border collection and payment arrangements. We hope you find this update useful.

Executive summary

• The 2025 amendments to the PSA (effective June 1, 2026) now require providers of cross-border collection and payment agent services (shuno daiko) to hold a licence under the Banking Act or the PSA. 
• Certain categories of cross-border collection and payment agent services — such as escrow services, platform operators, and sub-delegation to licenced entities — are exempt from this new licensing requirement.
• Even where an exemption applies, it may be overridden in specific circumstances (e.g., where the payer's obligation is not extinguished upon payment to the service provider).
• A six-month transitional period applies from the effective date (i.e., until December 1, 2026), during which providers may continue to perform cross-border collection and payment agent services without a licence. If an application for registration is filed during that period, the relevant activities may, in principle, continue until two years after the effective date.

Key changes

1. Background

Under Japanese law, any person engaging in "exchange transactions" (kawase torihiki) is required to hold a licence under either the Banking Act or the Payment Services Act ("PSA"). Domestic collection and payment agent services (shuno daiko) have traditionally been treated as falling outside the scope of "exchange transactions" and therefore not requiring a licence.

However, pursuant to the 2025 amendments to the PSA which took effect on June 1, 2026, cross-border collection and payment services are now to be classified as "exchange transactions," thereby requiring a licence under the Banking Act or the PSA. Certain categories of cross-border collection and payment agent services are exempt from this licensing requirement, as described in Section 3 below.

2. What Constitutes "Cross-Border Collection and Payment Agent Services"

The following sequence of activities may constitute cross-border collection and payment agent services, and the relevant service provider would therefore be required to obtain the necessary licence unless an exemption applies:

1. The service provider acts on behalf of the payee (creditor) under a mandate from the payee;
2. The service provider receives funds from the payer (debtor) as payment of the payer's obligation, with the result that the payer/debtor is discharged from such obligation;
3. The service provider delivers those funds to the payee;
4. The above results in a transfer of funds from the payer to the payee; and
5. The transfer of funds occurs either from Japan to a foreign jurisdiction or from a foreign jurisdiction to Japan.

3. Exempt Categories of Cross-Border Collection and Payment Agent Services

The following categories of cross-border collection and payment agent services are exempt from the licensing requirement:

1  Sub-delegation to a licenced entity – Cross-border collection and payment agent services performed by sub-delegating the activity to an entity holding a licence under the Banking Act or the PSA.

2  Escrow services – Collection and payment agent services performed in connection with escrow arrangements.  

3  Platform operators – Cross-border collection and payment agent services performed by platform operators. A "platform operator" is an entity that plays an indispensable role in the formation of the contract giving rise to the payee's monetary claim (e.g., by prescribing the method of contract execution), receives funds from the debtor as payment, and delivers those funds in accordance with the contract terms. Examples include e-commerce marketplace operators and travel booking platform operators.

4  Entities with economic unity with the payee – Cross-border collection and payment agent services performed by an entity recognized as having economic unity with the payee. 

5  Activities subject to risk mitigation under other laws – This includes:

a. Cross-border collection and payment agent services performed as part of the settlement process between credit card issuers and acquirers for designated international card brands (such as Visa, Amex, etc., with specific brands to be designated by public notice); and

b. Cross-border collection and payment agent services where the payee is a credit card merchant.

6  Sub-delegation from an escrow provider or platform operator – Cross-border collection and payment agent services performed under a mandate from an escrow service provider or platform operator described in (2) or (3) above.

7  Sub-delegation from a bank or fund transfer service provider – Cross-border collection and payment agent services performed under a mandate from a bank or licenced fund transfer service provider.

4. Exceptions to the Exemptions

Even where an activity falls within categories 1 through 7 above, a licence under the Banking Act or the PSA will still be required if any of the following conditions applies, on the grounds of insufficient user protection:

1. The payer's obligation is not extinguished upon payment to the service provider;
2. The escrow service provider or platform operator does not assume liability to the payee;
3. The activity relates to gambling;
4. The activity relates to securities or derivatives transactions; or
5. The activity otherwise involves conduct in violation of applicable laws

Other Authors: Chiharu Takatori, Associate.