Money Lending Registration in Japan: Requirements and Steps

Lending money as a business in Japan requires registration under the Money Lending Business Act. The main requirements are net assets of ¥50 million or more, a Money Lending Business Operations Supervisor (貸金業務取扱主任者), and a full-time officer with experience in lending operations. Registration must be renewed every three years.

When money lending registration is required

To operate a money lending business, you must be registered with the Director-General of the Local Finance Bureau or with a prefectural governor. If your business involves lending money in Japan, the first step is to confirm whether this registration applies to you.

For foreign companies, the question typically arises when you are considering:

• Starting a lending business targeting individuals or companies in Japan
• Offering fintech or lending services in Japan
• Building customer loans into part of your business

Depending on the form of the loan and who the borrower is, the answer may differ. Because the analysis varies by business model, it is important to check with the registering authority or a professional at the planning stage.

Note that the legal basis and supervising authority for money lending differ from those for a bank or trust company licence, or for other financial licences such as those for funds transfer services or crypto-asset exchange services. For an overview of the whole picture, see Types of financial licences in Japan and the registration process.

Main requirements for money lending registration

According to guidance published by the Japan Money Lenders Association and local governments, the main requirements for registration are as follows.

The table above shows the main requirements. In addition, applicants must not fall under any of the grounds for refusal of registration set out in the law. For the latest practice and detailed standards, always check the guidance issued by the Local Finance Bureau or the prefecture.

Net assets of ¥50 million are a different test from capital

The requirement is based on net assets, not capital stock. Net assets are total assets minus total liabilities. This test should be considered when you decide the capital at incorporation. For how to think about capital, see How much capital should a Japanese company have?

The registration guidance indicates that net assets are shown in the latest asset statement or balance sheet. Supporting documents such as balance certificates may be required to verify assets and liabilities.

Business experience is assessed through officers’ backgrounds

For a corporation, at least one officer who regularly engages in management must have three or more years of experience in lending operations. How experience gained overseas is assessed requires case-by-case confirmation. Start gathering documents that verify each officer’s background early.

The Money Lending Business Operations Supervisor is a national qualification

The supervisor must work full-time. The supervisor does not have to be the business owner, and you can recruit a qualified person. For the latest information on the examination and registration, check the guidance from the Japan Money Lenders Association.

Where to register: prefectural governor or Director-General of the Local Finance Bureau

The registering authority depends on how your offices are arranged.

• Offices all within one prefecture: registration with that prefectural governor
• Offices in more than one prefecture: registration with the Director-General of the Local Finance Bureau

If you start with a single base in Tokyo and later open an office in Osaka, the registering authority will change. Planning your office network in advance reduces the risk of having to redo your application.

Application steps and costs

Procedure

1. Define your business model and confirm whether registration is required
2. Prepare the operating entity and include money lending in the business purposes in its articles of incorporation
3. Prepare net assets of ¥50 million or more
4. Secure a supervisor and an officer with the required experience
5. Obtain the registering authority’s guide and confirm the required documents
6. Submit the application form and supporting documents to the registering authority

For how to word the business purposes, see How to write business purposes in the articles of incorporation. If the purposes do not include money lending, you may need to amend the articles and register the change before applying.

Required documents depend on the registering authority’s guide

In addition to the application form, various supporting documents are required. The forms and number of copies are set out in each authority’s guide. Many local governments, including Tokyo, Kanagawa and Hyogo, publish their guides online.

Foreign-language documents may need a Japanese translation. Confirm in advance with the registering authority how overseas documents will be treated.

Application fee

The registration application fee is ¥150,000. It is stated to be the same for new and renewal registrations. The guides from Tokyo and Hyogo state that the fee is not refunded if registration is refused or the application is withdrawn.

Payment methods differ by authority. Examples include revenue stamps, cash and electronic payment. Budget separately for document preparation and professional fees.

How to assess whether registration applies to you

“Lending” can cover very different business models. The following questions help structure the analysis.

1. Who lends money to whom, and on what terms?
2. Is the lending carried out as a business on a repeated and continuing basis?
3. Do you receive interest or fees?
4. Is the funding limited to intra-group arrangements, or are external customers involved?
5. Are you only acting as an intermediary for loans?

Organising this information will help when you consult the registering authority. We recommend checking with a professional or the registering authority in advance rather than proceeding on your own assessment.

Planning the preparation period

The time needed for registration depends heavily on how firm your business plan is. The three areas that most often take time are:

• Securing a supervisor (this assumes a holder of the national qualification)
• Preparing net assets (capital contributions and remittances must be arranged)
• Securing an officer with the required experience and organising their background documents

Review periods vary by registering authority. Before applying, check whether you can consult the authority in advance.

What to keep in mind after registration

Renewal every three years

Registration is valid for three years. To keep operating, you must renew, and the application is due two months before the registration expires. The Tokyo guidance advises completing procedures between five months and two months before the expiry date. Start preparing with enough lead time.

Maintaining net assets

The ¥50 million requirement applies not only at registration but throughout the period in which you operate. If you post continued losses, consider measures such as a capital increase in advance.

Do not start lending before registration

Do not begin lending as a business before you are registered. Consequences of a breach follow the provisions of the Money Lending Business Act. For specifics, consult a professional or the registering authority.

Points for foreign companies to confirm in advance

• What type of office you will establish in Japan, and which corporate form you will use
• Whether you plan to set up offices in more than one prefecture (this affects the registering authority)
• Preparing the ¥50 million capital contribution and the overseas remittance
• Who will serve as the supervisor
• Whether your officers’ experience meets the requirement

Establishing a Japanese company and making capital contributions follow the same procedures as a standard company formation. The difference with money lending is that you can only start the business after registration, which comes after the company has been set up.

If funds are coming from an overseas parent company or investors, align the timing and amount of contributions with your application schedule. Net assets are shown in financial documents at the time of application. It is important to keep records of contributions and balance statements in order.

How to check the latest information

Each registering authority maintains its own guides and forms for money lending registration. Content may be revised. Before applying, confirm the following:

• The revision date of the latest guide from the registering authority (Local Finance Bureau or prefecture)
• Required documents, number of copies and payment methods
• Pre-application consultation contacts and how to request them
• The Japan Money Lenders Association’s membership information and fees

How TIMOA can help

Money lending registration requires a step-by-step process, from company formation through setting up the organisation to filing the application. TIMOA supports overall planning for entry into Japan, preparation for establishing a Japanese company, and the organisation of required documents. Tasks that by law must be handled by professionals, such as preparing registration application documents, are carried out by our partner professionals.

For support with licensing in general, see our licensing and financial licence service page.