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Japan’s PSA Crypto Exchange Registration: Requirements & Checklist

Japan’s PSA Crypto Exchange Registration: Requirements & Checklist

Japan CAESP Registration Checklist

Registration Requirements Overview

This tool helps you determine if your exchange meets the core requirements for CAESP registration under Japan's Payment Services Act (PSA).

Compliance Results
Detailed Checklist:

Japan has turned crypto into a legal, property‑based asset, but the government’s guardrails are anything but casual. If you’re thinking about launching a crypto exchange in the Land of the Rising Sun, you’ll need to navigate the PSA registration Japan maze - a process that can swallow months, millions of yen, and a mountain of paperwork.

Key Takeaways

  • Any entity that buys or sells crypto as a business must register as a Crypto‑Asset Exchange Service Provider (CAESP) under Japan’s Payment Services Act (PSA).
  • Minimum capital is ¥10million and you must show positive net assets.
  • Only stock companies (kabushiki‑kaisha) can qualify - foreign firms must set up a Japanese subsidiary.
  • Customer coins must be kept at least 95% offline and fully ring‑fenced from the operator’s balance sheet.
  • The whole application takes up to six months, but preparation can easily double that time.

What the PSA Actually Is

Payment Services Act (PSA) is Japan’s primary legislation governing crypto‑asset exchange services. Enacted in 2019 and repeatedly amended, the PSA defines a “crypto asset” as any payment mechanism not denominated in fiat money that can be transferred to an unidentified party. In plain English, Bitcoin, Ethereum, and most standard tokens fall under the law, while e‑money cards or bank‑issued stablecoins do not.

Who Must Register?

If you are engaged in the purchase or sale of crypto assets as a business, you are automatically a Crypto‑Asset Exchange Service Provider (CAESP) and are required to register with the Financial Services Agency (FSA), Japan’s financial watchdog. Operating without registration is a criminal offense - punishable by up to three years imprisonment (or confinement punishment after the 2022 Penal Code amendment) and fines of ¥3million.

Core Registration Requirements

The PSA lays out a stringent checklist. Below is a practical breakdown of each bucket.

  • Legal Form: Must be a Japanese stock company (kabushiki‑kaisha). Foreign entities cannot register as a branch; they need a wholly‑owned subsidiary.
  • Capital Threshold: Minimum paid‑in capital of ¥10million (≈ USD70,000) and positive net assets at the time of application.
  • Organizational Structure: A board of directors, at least one compliance officer, and a dedicated IT security team.
    • Internal policies must cover anti‑money‑laundering (AML), know‑your‑customer (KYC), and cyber‑risk management.
  • Segregation of User Assets: At least 95% of user‑held crypto must be stored in offline cold wallets, fully ring‑fenced from the company’s operational accounts.
  • System Audits: External auditors must certify that the exchange’s wallet management, transaction monitoring, and data retention meet FSA standards.
  • Service Scope Disclosure: The application must list every crypto asset you intend to list, the trading mechanisms (spot, margin, etc.), and any outsourcing arrangements.

Documentation Checklist

Gather these files before you hit the FSA portal. Missing a single item can add weeks to the review.

  1. Certificate of incorporation (kabushiki‑kaisha) and proof of ¥10million capital.
  2. Names, addresses, and resumes of directors, executive officers, and compliance officers.
  3. Detailed business plan, including target crypto assets, projected trading volume, and fee structure.
  4. Technical white‑paper describing wallet architecture, cold‑storage procedures, and disaster‑recovery plan.
  5. AML/KYC policy manual and evidence of staff training.
  6. External audit report confirming net‑asset positivity and capital adequacy.
  7. Contracts with any third‑party service providers (custodians, cloud hosts, etc.).
  8. Proof of registration or licensing in the home jurisdiction for foreign firms.
Foreign Exchanges: The Extra Layer

Foreign Exchanges: The Extra Layer

Non‑Japanese companies face two hurdles: establishing a legitimate subsidiary and proving they meet the same capital and compliance standards.

Domestic vs. Foreign CAESP Requirements
Aspect Domestic Entity Foreign Entity (Subsidiary)
Legal Form Kabushiki‑kaisha (stock company) Kabushiki‑kaisha subsidiary or 100% Japanese‑registered branch (branch approvals have not been granted so far)
Minimum Capital ¥10million ¥10million (must be injected into the subsidiary)
Home‑Country Licensing Not required Proof of crypto‑exchange license in the home jurisdiction
Application Timeline 4-6 months (review) 6-9 months (additional time for subsidiary setup)
FSA Oversight Standard quarterly reporting Same reporting plus annual audit of subsidiary’s parent‑company controls

Consumer Protection Rules You Can’t Ignore

The Japan Virtual Currency Exchange Association (JVCEA) is a self‑regulatory organization recognized by the FSA and issues detailed operational guidelines. Two rules stand out:

  • Ring‑Fencing: Customer crypto must be stored separately from any corporate wallet. The FSA requires a clear audit trail proving that the exchange never mixes the two.
  • Cold‑Wallet Ratio: At least 95% of all user holdings must reside offline, with multi‑signature controls and geographic diversification.

Violating these standards triggers immediate supervisory orders, fines, and possible revocation of registration.

Step‑by‑Step Application Flow

  1. Form a Japanese kabushiki‑kaisha (or subsidiary) and inject the required capital.
  2. Hire a qualified compliance officer and set up internal AML/KYC procedures.
  3. Develop a technical white‑paper that outlines wallet architecture and segregation methods.
  4. Commission an external audit confirming net‑asset positivity and capital compliance.
  5. Compile the full document package (see checklist) and submit it via the FSA’s online portal.
  6. The FSA reviews the submission (up to six months). Expect follow‑up questions about security controls and outsourcing contracts.
  7. Upon approval, you receive a CAESP registration number and must file quarterly compliance reports.

While the FSA’s review is the bottleneck, many firms stumble during the preparation phase-especially when drafting the segregation methodology. Investing in a specialist consulting firm early can shave weeks off the timeline.

Common Pitfalls and Pro Tips

  • Pitfall: Treating the subsidiary as a shell company. Tip: The FSA conducts on‑site inspections; a genuine staff presence and local board members are mandatory.
  • Pitfall: Under‑estimating the cold‑wallet infrastructure cost. Tip: Budget at least ¥3million for hardware security modules and multi‑sig devices.
  • Pitfall: Assuming the same AML policy works worldwide. Tip: Align your KYC screens with Japan’s “Act on Prevention of Transfer of Criminal Proceeds”.
  • Pitfall: Over‑promising marketing claims. Tip: The Japan Security Token Offering Association (JSTOA) enforces strict advertising guidelines; keep messaging factual and avoid guaranteed‑return language.

What Happens After Registration?

Being a licensed CAESP doesn’t end at the certificate. The FSA requires:

  • Quarterly financial statements filed in Japanese yen.
  • Annual compliance audit by a FSA‑approved firm.
  • Immediate notification of any material change - e.g., adding a new token, expanding to margin trading, or changing the custodian.

Failure to comply can lead to a “re‑examination order” that temporarily suspends trading and may culminate in revocation.

Frequently Asked Questions

Do I need a Japanese resident director?

Yes. The FSA requires at least one director who is a Japanese resident and can be contacted locally for regulatory inquiries.

Can an existing foreign exchange operate in Japan without a subsidiary?

No. To obtain CAESP registration, the foreign entity must set up a kabushiki‑kaisha subsidiary. Branch registrations have never been approved.

What is the penalty for operating without registration?

Under Article 107, Item5 of the amended PSA, offenders face up to three years imprisonment (now confinement punishment) and fines up to ¥3million.

How long does the review process usually take?

The FSA’s formal review can last four to six months, but preparation often adds another two to three months.

Is there any difference in requirements for security tokens?

Yes. Tokens with investment‑like features fall under the Financial Instruments and Exchange Act (FIEA) and need a separate securities license, which has higher capital thresholds.

Related Post

Japan’s PSA Crypto Exchange Registration: Requirements & Checklist

A practical guide to Japan's PSA registration for crypto exchanges, covering legal forms, capital, asset segregation, foreign subsidiary rules, timelines, and common pitfalls.

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Comments (24)

Gaurav Joshi

Gaurav Joshi

December 28 2024

The PSA requirements are a perfect example of bureaucratic overreach.

Kathryn Moore

Kathryn Moore

January 4 2025

The Japanese PSA mandates a ¥10 million capital floor and a domestic kabushiki‑kaisha structure for any crypto exchange. It also requires at least 95 percent of user assets to be stored offline. The compliance officer must be a resident Japanese citizen. Audits have to be performed by an FSA‑approved firm before the application is submitted. Failure to meet any of these criteria results in outright rejection.

Christine Wray

Christine Wray

January 11 2025

While the checklist seems daunting, many firms successfully navigate it with proper planning. The key is to treat the capital and segregation requirements as non‑negotiable fundamentals. Engaging a local legal partner can smooth out the residency and documentation hurdles. Ultimately, compliance builds trust with Japanese users and regulators alike.

roshan nair

roshan nair

January 18 2025

Alright folks, let’s break this down – the PSA isn’t just a paper chase, it’s a full‑blown regulatory marathon. First off, you need a bona‑fide kabushiki‑kaisha, no branch shortcuts – that means a real Japanese board, not just a paper name. Capital? Yep, ¥10 million stamped in, and your net assets must show a positive glow, otherwise the FSA will slap you with a “no‑go”. Cold‑wallets are the holy grail – stash 95 % of user coins offline, preferably in multi‑sig vaults scattered across islands for extra spice. Don’t forget a compliance officer who actually speaks Japanese and knows the local AML dance; a half‑hearted appointment won’t cut it. Audits need to be done by an FSA‑approved firm – think of it as a health check before you step on the track. And finally, keep every contract, from custodians to cloud hosts, in pristine order – the FSA loves a tidy file cabinet.

Jay K

Jay K

January 25 2025

Dear colleagues, please note that the requirement for a resident director is non‑negotiable. The director must be reachable locally for any regulatory inquiry. Compliance with this clause demonstrates good governance.

Kimberly M

Kimberly M

February 1 2025

Thanks for the heads‑up! 😊 It’s easy to overlook the director residency rule until the FSA calls.

Navneet kaur

Navneet kaur

February 8 2025

You missed the cold wallet point.

Marketta Hawkins

Marketta Hawkins

February 15 2025

Foreign exchanges think they can just waltz in, but Japan’s law says no – you need a fully Japanese subsidiary or you’re out. Don’t try to bypass the capital floor, it’s a trap set for outsiders.

Drizzy Drake

Drizzy Drake

February 22 2025

Man, reading through this whole PSA checklist feels like climbing Mt. Fuji in a snowstorm. You start with the capital, which sounds simple enough – ¥10 million, that’s about seventy‑odd thousand bucks, but then you have to prove your net assets are positive, which means a deep dive into balance sheets that most startups dread. The real pain comes with the cold‑wallet requirement; you’re forced to keep most of your users’ crypto offline, which is great for security but horrendous for liquidity and quick withdrawals. On top of that, the FSA wants a resident board member, a compliance officer who knows every nuance of Japanese AML law, and a whole audit from an approved firm before they even look at your application. It’s a massive upfront investment in time, money, and legal counsel, but hey, if you want to operate in the land of the rising sun, that’s the price of admission. And let’s not forget the ongoing quarterly reports – they’re not just a formality, they’re a continuous audit trail that keeps you on your toes.

AJAY KUMAR

AJAY KUMAR

March 1 2025

Whoa, that’s a marathon, not a sprint! 🎭

bob newman

bob newman

March 8 2025

Sure, the FSA is just a friendly watchdog, nothing to worry about. They’ll probably let anyone in as long as you sign a prayer.

Logan Cates

Logan Cates

March 15 2025

Looks like another bureaucratic nightmare.

Shelley Arenson

Shelley Arenson

March 22 2025

Great summary! 👍👍

Joel Poncz

Joel Poncz

March 29 2025

i think dis is realy good info thx.

Kris Roberts

Kris Roberts

April 5 2025

Regulation shapes behavior, it’s a subtle dance between freedom and order. When rules are clear, innovation finds a path; when they’re opaque, confusion reigns. The PSA is a case study in that balance.

lalit g

lalit g

April 12 2025

I appreciate the balanced view; it helps newcomers understand both the hurdles and opportunities.

Reid Priddy

Reid Priddy

April 18 2025

The checklist seems overly strict and could stifle competition without offering real consumer protection.

Shamalama Dee

Shamalama Dee

April 25 2025

Thank you for providing such a comprehensive overview; it will be invaluable for anyone considering entry into the Japanese market.

scott bell

scott bell

May 2 2025

Interesting how the PSA blends traditional financial oversight with modern crypto concerns, especially the emphasis on offline storage and resident governance; this dual approach could set a global precedent.

vincent gaytano

vincent gaytano

May 9 2025

Obviously the FSA just wants to control everything, nothing else matters.

Dyeshanae Navarro

Dyeshanae Navarro

May 16 2025

Regulation can be a guide, not a barrier, if we see it as a way to build trust.

Matt Potter

Matt Potter

May 23 2025

Go for it! The tougher the rules, the stronger the exchange will become.

Marli Ramos

Marli Ramos

May 30 2025

meh, looks like too much work 😂

Christina Lombardi-Somaschini

Christina Lombardi-Somaschini

June 6 2025

In summary, the Japanese Payment Services Act establishes a rigorous framework that aligns crypto‑asset exchanges with established financial institutions; the capital threshold of ¥10 million ensures sufficient financial backing, while the requirement for positive net assets serves as a safeguard against insolvency; the mandate for a domestic kabushiki‑kaisha structure reinforces corporate accountability and facilitates clear jurisdictional oversight; appointing a resident director and compliance officer guarantees that regulatory communications can be conducted efficiently and in the native language; the segregation of user assets, with at least 95 percent stored offline, markedly reduces custodial risk and aligns with global best practices for cold‑wallet security; external audits performed by FSA‑approved firms provide an additional layer of verification, confirming that both financial and operational controls meet statutory standards; comprehensive AML/KYC policies, coupled with regular staff training, mitigate the risk of money‑laundering and illicit activity; detailed documentation-including white‑papers outlining technical architecture, custody solutions, and disaster‑recovery plans-facilitates transparent evaluation by the regulator; third‑party contracts must be disclosed and vetted, ensuring that outsourcing does not introduce hidden vulnerabilities; the requirement to report quarterly financial statements in Japanese yen enhances fiscal transparency and enables timely regulator insight; any material change, such as the addition of new tokens or the introduction of margin trading, must be promptly reported to maintain compliance; non‑compliance triggers swift supervisory actions, ranging from re‑examination orders to revocation of the CAESP licence, underscoring the seriousness of adherence; foreign entities are not exempt; they must establish a fully‑owned subsidiary, inject the requisite capital, and obtain proof of licensing in their home jurisdiction, thereby extending the regulatory net globally; the structured timeline-four to six months for domestic firms and six to nine months for foreign subsidiaries-allows applicants to plan resources accordingly; finally, ongoing compliance, including annual audits and immediate disclosure of significant operational changes, cultivates a stable and trustworthy market environment, which ultimately benefits both consumers and legitimate service providers.

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