Cross-Border Payment Collection and Funds Transfer License in Japan

Under the amended Payment Services Act (資金決済に関する法律), which took effect on 1 June 2026, cross-border payment collection is generally treated as a foreign exchange transaction, and businesses now need funds transfer business registration (資金移動業の登録). Businesses already operating have a transition period, and according to the amendment, they can continue without registration until 30 November 2026. Map your own and your outsourcing providers’ fund flows early.

What the rules cover

Payment collection means a business receiving or paying money on behalf of a client. The amendment now regulates the subset of these arrangements that cross national borders.

The amendment is the Act to Partially Amend the Act on Payment Services (Reiwa 7 Act No. 66). According to commentary, the amended Act and related Cabinet Orders and Cabinet Office Ordinances took effect on 1 June 2026. To conduct foreign exchange transactions as a business, you need funds transfer business registration (or a banking license).

Amendment timeline

Continuing a registrable business without registration may constitute a violation of the law. Do not run operations while leaving the registration question unresolved.

Exemption framework

Not every cross-border payment collection requires registration. Certain transactions are treated as outside the regulations when they fall within categories specified in the Cabinet Office Ordinance on Funds Transfer Service Providers (資金移動業者に関する内閣府令).

Whether a category applies depends on checking each statutory requirement. Similar-sounding arrangements can reach different conclusions depending on the fund flow and contract terms. Do not rely only on summaries in commentary. Confirm against the text of the Ordinance and official Financial Services Agency (FSA, 金融庁) materials.

Scenarios where foreign companies are most affected

The following types of business warrant priority review:

• Collecting payments from overseas customers on behalf of a Japanese business.
• Consolidating payments from a Japanese business to overseas counterparties.
• Pooling and distributing funds for multiple businesses outside your group.
• Using an overseas payment company or collection provider as an outsourcing or partner provider.

If you offer a collection scheme yourself, you may need registration. If you use an outside provider, confirming that the provider holds the required registration is practically important.

Transition period and the 30 November 2026 deadline

The amendment includes a transition period. According to a law firm’s commentary, the outline is as follows:

Eligibility and conditions for the transition depend on your current registration status and business activities. Check the amendment’s supplementary provisions and the Ordinance to confirm whether they apply to you.

Doing nothing after the deadline may mean operating without registration. A practical sequence is:

1. Diagram your fund flows, showing who receives and sends money, and for whom.
2. Review with your adviser whether any exempt category applies.
3. If it applies, decide between a registration application and a redesign of the scheme (stopping the service or switching to a partner model).
4. Revise contracts, terms of use and internal rules to match the new scheme.

Preparing for registration

Funds transfer businesses are subject to a registration system. Specific requirements vary by the type of registration and business. Confirm the details in materials published by the FSA or the relevant Local Finance Bureau (財務局). Preparing the following early will help your review:

• A fund flow diagram showing the full service (receipt, holding and transfer at each stage).
• A list of customers, payees, partners and outsourcing providers, with the contracts for each.
• Terms of use and explanatory documents for users.
• Materials summarizing transaction volumes and counterparties.
• Materials showing your internal structure and the responsible officers.
• The current state of your anti-money laundering (AML) and other internal rules.

Foreign companies may also need materials to explain the position to headquarters management. Creating a terminology table early helps avoid drift between Japanese documents and translations. Keep dated records of decisions with the names of the people responsible.

For the overall registration process and how it differs from other financial licenses, see our guide to types of financial licenses in Japan and the registration process.

What to confirm with outsourcing and partner providers

If you use an outside collection provider or payment company, it is advisable to confirm the following in writing before and after contracting:

Where answers are unclear, record that point and consult an adviser. Relying on verbal explanations alone makes it harder to verify the facts later.

Questions to determine whether your business is covered

When starting an internal review, check whether you can answer these questions:

1. Does money move between Japan and overseas, and in which direction?
2. On whose behalf does your business receive or pay money?
3. Does the money received first enter your own account?
4. From whom do you receive fees, and for what?
5. Did you operate in the same way before the effective date (1 June 2026)?

Documenting the answers makes it easier to consult advisers and explain the position to authorities.

Common mistakes and how to check the latest information

Common mistakes

• Assuming your business is unaffected because an outside provider handles collection.
• Assuming that, because a transition period exists, no preparation is needed until the deadline.
• Applying another firm’s commentary classification to your own business without checking.
• Reviewing only the contract wording and not the actual fund flow.

How to check the latest information

The area is still being clarified in interpretation and practice shortly after enforcement. Before deciding, check the following:

• The text and supplementary provisions of the amended Act (e-Gov Laws and Regulations search).
• The latest text of the Cabinet Office Ordinance on Funds Transfer Service Providers.
• Results and responses from public comment procedures published by the FSA.
• FSA administrative guidelines and guidance on registration.

Related points for bank accounts and remittances

Businesses involving fund transfers often face stricter screening for opening and maintaining bank accounts. Preparing materials that explain your business will make the process smoother. For how to approach this, see our guide on opening a corporate bank account in Japan as a foreign executive.

Summary

Under the amended Payment Services Act, cross-border payment collection is subject to funds transfer business regulation where the requirements are met. Whether an exemption applies, and how the transition period applies, depends on each scheme. The transition period is generally understood to end on 30 November 2026, so early review is important.

TIMOA works with partner lawyers and other specialists to support scheme analysis, assessment of whether registration is required, application preparation, and the organizational setup that comes with entering Japan. For financial licensing in general, see our licensing and financial license services page.