Representative Director Address Non-Disclosure in Japan: Scope and Risks

The representative director address non-disclosure measure is a system under which part of a representative director’s address is not shown on certificates of registered matters (登記事項証明書) and similar documents for a kabushiki kaisha. It was created through an amendment to the Ministry of Justice Ordinance and has been in force since October 1, 2024. The application is made together with a registration that records the address, such as incorporation. Before using it, check how it may affect bank loans and property transactions.

What the representative director address non-disclosure measure is

The address of a representative director is a registered matter. Under this measure, and subject to certain requirements, part of that address is not shown. The Ministry of Justice describes it as a system created by the Ordinance Partially Amending the Commercial Registration Rules, etc. (Ministry of Justice Ordinance No. 28 of 2024).

The measure affects the certificate of registered matters, the summary of registered matters (登記事項要約書) and the Registry Information Service (登記情報提供サービス). The information recorded in the register does not change. What changes is how it appears in these documents and on-screen.

Who and which companies are covered

• The measure applies to a kabushiki kaisha (KK). A godo kaisha (GK), a general partnership company or a limited partnership company is not covered under the current system.
• The eligible officers are representative directors, representative executive officers and representative liquidators.

How much of the address appears on certificates

Once the measure is applied, the address is shown only down to the municipality. In Tokyo, it is shown down to the special wards. One commentary states that designated cities are shown down to the ward level. Information below the street number level is not shown.

When and how to apply

An application can be made only when it is filed together with a registration that will record the representative director’s address. The Ministry of Justice lists the following examples:

• Registration of incorporation
• Registration of the appointment of a representative director, etc.
• Registration of a change due to a move of the representative director’s address

In other words, the measure cannot be applied for on its own. If you want to use it from the start, apply when you file the incorporation registration.

What the application form must include

According to the Ministry of Justice, the application is made by stating it in the registration application form. The following three items must be stated:

1. A statement that the representative director address non-disclosure measure is requested
2. The qualification, name and address of the person covered
3. Attached documents required for the application (if an application has been made to keep a beneficial owner list, that fact and the place of application)

If the registration is filed online, the application details are entered in the “other application form entries” field. A sample entry is attached to the Ministry of Justice page.

Required documents and checking the latest rules

The application requires specified documents to be attached. Which documents can be used depends on the company’s circumstances. Commentaries describe two requirements: the application must be made together with the registration, and the specified documents must be attached.

Document types and sample entries may change with revisions or changes in practice. Check the latest version on the Ministry of Justice page immediately before filing.

Addresses registered in the past are not covered

The Ministry of Justice explains that the address covered is limited to the address recorded by the registration filed together with the application. Addresses registered before the application are not covered by this measure.

A company that is already registered can use the measure with future registrations of appointment or change of address. Note that it does not erase past records.

Ending the measure

There is also a procedure to end the measure. According to the Ministry of Justice page, the application to end it must state the name and address of the representative director, etc. who no longer wants the measure. The company’s seal registered with the registry office must also be affixed.

Effects foreign founders should check before using the measure

The Ministry of Justice explains that once the measure is applied, the company representative’s address can no longer be proven by certificates of registered matters and similar documents. Some effects are therefore expected.

• Obtaining loans from financial institutions may be inconvenient.
• Property transactions and similar dealings may require additional necessary documents, such as the company’s seal registration certificate.

The Ministry of Justice asks applicants to consider these effects carefully and thoroughly before applying.

Impact on opening a bank account

Because the representative’s address cannot be confirmed from the certificate of registered matters, a financial institution may ask for other documents. Requirements differ by institution. Before incorporation, it is advisable to ask the bank you plan to use what it requires. For preparation of a corporate account, see our article on opening a corporate bank account in Japan as a foreign founder.

Points to confirm before incorporation

• Whether you plan to borrow money. If so, ask the lender whether non-disclosure is possible and which documents it requires.
• Whether you plan to buy or lease property. Confirm the required documents with your counterparties.
• How the measure applies if the representative lives overseas. Because the answer depends on individual circumstances, check with a judicial scrivener (司法書士).

Keep a record of what you confirm, such as by email, so you can later explain the process. Decide whether to apply before filing the incorporation registration. If you realize the issue after filing, you will need to wait for the next registration that records the address. Counterparty requirements may change over time. If you are unsure, consult a judicial scrivener first.

How to fit the measure into your incorporation plan

This measure is linked to your choice of company form and incorporation schedule. Because a godo kaisha is not covered, check this when selecting the form.

1. Decide the company form. If you want to hide the address, a kabushiki kaisha is required. For a comparison of forms, see the differences between a KK and a GK.
2. Confirm the representative’s address. If the representative is expected to move, decide this in advance.
3. Check bank accounts and counterparty requirements. Confirm that non-disclosure will not cause problems.
4. Decide whether to apply when filing the incorporation registration.
5. If you apply, prepare the entries required in the application form and the documents to be attached.

For the overall incorporation process, see how foreigners and foreign companies incorporate in Japan.

Common mistakes

• Deciding after incorporation and trying to apply on its own. The application can be made only together with a registration that records the address.
• Assuming a godo kaisha can use it. The current system covers only kabushiki kaisha.
• Assuming past registered addresses will also disappear. The measure covers only the address in the registration filed with the application.
• Applying without checking the effects. Loans and property transactions may require more documents.

Expansion proposals and how to check rule changes

Some commentaries report proposals to expand the scope of this system. However, this article has not confirmed the content or effective date of any such changes in the Ministry of Justice materials. For that reason, we do not describe any expanded scope or requirements.

This article is current as of October 1, 2024, when the current system took effect. Before filing, check the latest scope and requirements on the Ministry of Justice page titled “Representative director address non-disclosure measure (代表取締役等住所非表示措置について).”

Summary｜What TIMOA can do

The representative director address non-disclosure measure shows only the municipality on certificates of registered matters and similar documents, so the detailed home address is not disclosed. It applies to kabushiki kaisha and must be applied for together with a registration that records the address. Loans and property transactions may, however, require additional documents.

TIMOA works with partner judicial scrivener offices to support choosing the company form, incorporation registration and deciding whether to apply. For full incorporation support, see our Japan entry and company setup service page. We also summarize the overall steps in our Japan entry checklist.