Japan banking-license tier comparison matrix

ConfidenceLikelyUpdated2026-07-29Review by2026-10-27Sources22Machine-translatedOriginal (JA)

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TL;DR

Japan’s deposit-taking system is not one legal form. The Banking Act, the Act on Engagement in Trust Business Activities by Financial Institutions, 信用金庫法, 中小企業等協同組合法 / 協金法, 労働金庫法, 農協法 / 水協法, and 農林中央金庫法 create different perimeters. At the same time, “megabank”, “regional bank”, “second regional bank”, and “net bank” are operating or industry labels within the ordinary-bank licence, not four separate statutory licences. This matrix compares both legal categories and those explicitly labelled operating categories.

Wiki route

This entry sits under banking index and pairs with Cooperative banking in Japan for the cooperative-finance lane, Japan net bank competition map for the digital-bank lane, Foreign-bank Japan retreat for the foreign-branch lane, and Regional bank consolidation pattern for the regional-bank lane. The regulatory boundary is bank license and BaaS boundary inside JapanFG legal / financial licenses. The deposit-insurance system is Yokin Hoken Kiko. The cooperative central institutions are Norinchukin and Shinkin Central.

Why a tier matrix matters

A single phrase like “Japanese bank” hides the fact that the licence tier controls almost every public-surface field that matters for analysis:

  • which statute the institution lives under;
  • which regulator inspects it (FSA, 厚労省 jointly for rōkin, 農水省 jointly for JA / JF / Norinchukin);
  • whether the protection scheme is DICJ or the separate 農水産業協同組合貯金保険機構;
  • whether the institution can hold a securities licence, trust licence, or only ordinary banking;
  • whether it can incorporate inside a bank holding company;
  • whether it has direct banking-domain access to the BoJ as a counterparty;
  • and whether membership / geography is a hard legal constraint.

Without the licence tier, a net bank looks like just another retail bank, a shinkin looks like just another small regional, and a foreign branch looks like just another wholesale player.

Tier 1 — Megabank (普通銀行 / 都市銀行)

  • Statute / regulator. Banking Act 普通銀行 license; supervised by FSA Major-Banks-and-Bank-Holding-Companies Division, with BoJ on-site monitoring as monetary-policy counterparty.
  • License + count. Banking Act 普通銀行. “Megabank” is an analytical / industry grouping rather than a separate licence; this page uses MUFG, SMBC, and Mizuho as the core comparison set and routes Resona separately through post-megabank positioning.
  • Capital floor. Banking Act minimum paid-in capital is ¥2 billion for ordinary banks; megabanks operate far above this and run on BIS Basel III group capital — Common Equity Tier 1 ≥ 4.5%, Tier 1 ≥ 6%, total capital ratio ≥ 8%, plus the G-SIB / D-SIB capital buffer surcharge tier (MUFG, SMFG, Mizuho carry G-SIB surcharges; Resona is treated as a D-SIB).
  • Liquidity. Full Basel III LCR ≥ 100% and NSFR ≥ 100% applied on a consolidated basis.
  • Deposit insurance. DICJ coverage; ¥10 million principal plus interest under the standard deposit-insurance frame, with 決済用預金 fully protected.
  • Permitted activities. Deposits, lending, FX, settlement, bond and government-bond underwriting, securities-affiliated business through subsidiaries, derivatives, custody, asset management, leasing, consumer finance, holding-company strategic functions.
  • Cross-border. Full international banking: overseas branches, foreign-bank subsidiaries, USD / EUR clearing access, cross-border lending, project / trade finance, swap-line eligibility.
  • Governance. Joint-stock company listed on TSE Prime; bank holding company structure permitted and used (MUFG, SMFG, Mizuho FG, Resona HD).
  • Geography. No statutory geographic restriction; nationwide branch and overseas presence.
  • M&A / holding company. Bank holding company permitted with prior FSA approval; cross-shareholding and consolidation routes are open under the Banking Act.
  • BoJ counterparty. Current-account and market-operation status are separate, entity-specific relationships; verify the current BoJ counterparty list rather than inferring both from the bank label.
  • Recent regulatory changes. Banking Act 改正 (Reiwa 3 / 2021) expanded the bank-affiliated-company scope and digital / regional revitalization investment scope; updates around bank-issued digital-money and 電子決済等取扱業 affect this layer most directly. See bank license and BaaS boundary.

Tier 2 — Regional bank (地方銀行)

  • Statute / regulator. Banking Act 普通銀行 license; supervised under FSA’s 中小・地域金融機関 supervision guideline; many regional banks also fall under regional bank consolidation pattern when prefectural FSA bureaus engage.
  • License + count. Banking Act 普通銀行 license, 第一地方銀行協会 member; the 全銀協 grouping treats this as the “regional bank” tier sitting between megabanks and second-regional banks.
  • Capital floor. Same Banking Act ¥2 billion minimum; BIS standardized approach for most, IRB only for the largest; domestic-standard 4% core capital ratio applies to banks without international operations.
  • Liquidity. LCR / NSFR applied for internationally active banks; domestic-standard banks run a simpler liquidity requirement under the FSA domestic framework.
  • Deposit insurance. DICJ coverage on the same terms as megabanks.
  • Permitted activities. Deposits, lending, FX, settlement, securities-affiliated business through subsidiaries; trust business via separate licence (some regionals carry trust ancillary functions).
  • Cross-border. Limited; the larger regionals operate overseas representative offices and select branches but most are domestically focused.
  • Governance. Joint-stock company; many are TSE-listed; bank holding company structure increasingly common (regional bank consolidation pattern).
  • Geography. No legal geographic restriction, but franchise concentrates in one to a few prefectures.
  • M&A / holding company. Bank holding company permitted with FSA approval; consolidation under FSA’s 経営統合 framework is the dominant M&A route.
  • BoJ counterparty. Direct BoJ current account; eligible for BoJ market operations on a smaller scale than megabanks.
  • Recent regulatory changes. 2021 Banking Act 改正 expanded permitted-affiliated-company business and made it easier for regional banks to invest in regional revitalization, digital banking subsidiaries, and consulting subsidiaries — material to the consolidation arc tracked in regional bank consolidation pattern.

Tier 3 — Second regional bank (第二地方銀行)

  • Statute / regulator. Banking Act 普通銀行 license; same FSA 中小・地域金融機関 supervision guideline. Legally indistinguishable from a regional bank — the “second” tag is industry-association membership.
  • License + count. Banking Act 普通銀行 license, 第二地方銀行協会 member; historically the conversion from 相互銀行 (mutual savings banks) into ordinary banks under the 1989 reform.
  • Capital floor. Banking Act minimum identical to regionals; BIS regime identical.
  • Liquidity. Same as ordinary regional banks; domestic-standard liquidity for non-internationally-active banks.
  • Deposit insurance. DICJ coverage on full Banking-Act terms.
  • Permitted activities. Same as regional banks; in practice the franchise is more SME-tilted and the balance sheet is smaller.
  • Cross-border. Minimal; almost entirely domestic franchises.
  • Governance. Joint-stock company; TSE-listed in many cases; bank holding company permitted.
  • Geography. Single-prefecture franchise more typical than first-tier regionals.
  • M&A / holding company. The consolidation flow described in regional bank consolidation pattern often pairs a first-tier regional with a same-prefecture second regional inside one holding company.
  • BoJ counterparty. Direct BoJ current account.
  • Recent regulatory changes. Same 2021 Banking Act 改正 envelope as ordinary regionals; FSA support measures for consolidation (system-cost subsidies, governance flexibility) are a meaningful nudge at this tier.

Tier 4 — Trust bank (信託銀行)

  • Statute / regulator. Banking Act bank licence plus authorisation to conduct trust business under the Act on Engagement in Trust Business Activities by Financial Institutions (兼営法) and related trust rules. Do not reduce this to a generic Trust Business Act “second licence”.
  • License + count. Public membership is captured in 信託協会 trust-bank rosters. Operating-company anchors include banking index trust-bank routes plus the JapanFG trust-bank pages; the operating-comparison surface is trust-bank custody operating comparison.
  • Capital floor. Banking Act requirements apply to the bank; trust-business authorisation adds fiduciary, segregation, and operating requirements.
  • Liquidity. Banking Act LCR / NSFR on the banking-book side; trust assets are off-balance-sheet under separate fiduciary accounting.
  • Deposit insurance. DICJ coverage on the banking-book deposits; trust accounts protected through the 元本補填信託 path for protected-principal money trusts under the same DICJ frame.
  • Permitted activities. Banking (deposits, lending, FX, settlement) plus trust business (money trusts, securities-investment trusts, pension trusts, custody, securities settlement, real-estate trusts, asset administration). The dual-license tier carries the broadest activity envelope in the deposit-taking universe.
  • Cross-border. Megabank trust arms (MUFJ Trust, SMBC Trust, Mizuho Trust) operate global custody and asset-administration networks; specialist asset-administration banks (Master Trust Bank of Japan, Custody Bank of Japan) operate the institutional infrastructure layer.
  • Governance. Joint-stock company; almost always under a bank holding company.
  • Geography. No statutory restriction; nationwide.
  • M&A / holding company. Bank holding company permitted; trust-bank subsidiaries often sit alongside ordinary bank subsidiaries in megabank groups.
  • BoJ counterparty. Banks and trust banks are eligible categories, but current-account, BOJ-NET, and JGB-system participation must be checked for the legal entity and service.
  • Recent regulatory changes. FSA’s expansion of fiduciary-duty principles, asset-management business-improvement orders, and the legal-financial-licenses track on trust-business reform reshape the operating envelope; bank-issued digital-money intermediation under 電子決済等取扱業 also lands on bank-side trust intermediation.

Tier 5 — Net bank (ネット銀行)

  • Statute / regulator. Banking Act 普通銀行 license. No separate statutory category — “net bank” is operational, not legal. The licence is identical to a megabank’s.
  • License + count. Banking Act 普通銀行 license; the operating universe is tracked in Japan net bank competition map (ecosystem retail, full-banking BaaS, corporate API, asset-formation, regional digital).
  • Capital floor. Banking Act minimum capital; BIS standardized approach for most, domestic-standard 4% for many; some net banks (Rakuten Bank, SBI Sumishin Net Bank) have grown into mid-cap balance sheets.
  • Liquidity. Standard Banking Act LCR / NSFR rules, domestic-standard for non-internationally-active operators.
  • Deposit insurance. DICJ coverage on full Banking-Act terms.
  • Permitted activities. Full ordinary-bank envelope; some operate full-banking BaaS for partners (Japan BaaS operating models), some operate corporate API banking, some operate securities-adjacent retail banking.
  • Cross-border. Limited; FX retail and overseas remittance are common, full overseas branches uncommon.
  • Governance. Joint-stock company; bank holding company permitted; many net banks sit inside fintech / ecommerce / telecom / securities parent groups rather than under a bank holding company.
  • Geography. No branch network in the traditional sense; nationwide digital channel.
  • M&A / holding company. Bank holding company permitted; the operational-model question (parent ecosystem, partner BaaS, securities adjacency) is in Japan net bank competition map.
  • BoJ counterparty. Ordinary-bank status makes the institution an eligible category, but an account relationship is not automatic; verify the current BoJ list.
  • Recent regulatory changes. 2021 Banking Act 改正 expansion of banking-affiliated-company scope is one of the most directly material changes for this tier; 電子決済等取扱業 and BaaS-boundary supervision tracked in bank license and BaaS boundary affect operating freedom rather than licence shape.

Tier 6 — Foreign bank branch (外国銀行支店)

  • Statute / regulator. Banking Act 外国銀行支店 license under Chapter IX of the Banking Act; supervised under FSA’s Major-Banks and the foreign-bank supervisory route.
  • License + count. Banking Act 外国銀行支店 license; FSA publishes the foreign-bank branch list and updates it periodically. The pattern is tracked in Foreign-bank Japan retreat.
  • Capital floor. Branch capital-equivalent rule applies (assets-equivalent treatment, home-office capital adequacy reliance); not the ordinary ¥2 billion paid-in capital floor for domestically incorporated banks. Home-office Basel III standing matters.
  • Liquidity. Branch-specific liquidity expectations; home-office LCR / NSFR carry through home-supervisor frame, with FSA add-on requirements where domestic operations are material.
  • Deposit insurance. DICJ coverage does not automatically apply to foreign bank branches in the same way as Japanese banks — under Banking Act Chapter IX, foreign bank branch deposits are not covered by the Japanese DICJ system; depositors rely on home-country protection and branch asset / Japan-asset-pledge rules.
  • Permitted activities. Banking, FX, securities-affiliated through licensed subsidiaries; activities limited to what the licence authorises plus home-office capability subject to Japanese regulatory equivalence.
  • Cross-border. Native; the entire point of the licence is to support corporate, wholesale, custody, markets, FX, trade, and Asia-corridor business — see the segment map in Foreign-bank Japan retreat.
  • Governance. Branch of an overseas legal entity; not a Japanese joint-stock company; governed by home-office board and Japan branch governance under FSA expectation.
  • Geography. Typically one to a few branches in Tokyo / Osaka.
  • M&A / holding company. Cannot be parented inside a Japanese bank holding company; restructuring usually goes through home office.
  • BoJ counterparty. Foreign bank branches can hold BoJ current accounts and participate in BoJ-NET; not all foreign branches do.
  • Recent regulatory changes. FSA’s foreign-bank-branch supervision guideline updates around AML, suspicious-transaction monitoring, governance-equivalence, and home-office risk controls remain the active perimeter.

Tier 7 — Shinkin (信用金庫)

  • Statute / regulator. 信用金庫法; supervised under FSA’s 中小・地域金融機関 supervision guideline (Part V on cooperative financial institutions) and Local Finance Bureau / 福岡財務支局 / 沖縄総合事務局 routes.
  • License + count. 信用金庫法 license; 254 licensed shinkin banks per Japan shinkin bank registry, plus the central institution Shinkin Central.
  • Capital floor. 信用金庫法 minimum 出資金 ¥100 million for ordinary shinkin (¥200 million for designated areas); BIS-style capital adequacy is the FSA domestic-standard 4% core capital framework.
  • Liquidity. FSA domestic-standard liquidity expectations; central-institution liquidity support from Shinkin Central.
  • Deposit insurance. DICJ coverage applies on the same Banking-Act-equivalent terms.
  • Permitted activities. Member deposits, member lending, settlement, FX, securities investment; lending to non-members is restricted in proportion (50% non-member cap is the historic anchor, with carve-outs).
  • Cross-border. Generally none; some larger shinkin run modest FX / remittance through corresponding-bank routes.
  • Governance. Cooperative / 協同組織 — member-based, one-member-one-vote governance, with 出資 (membership investment) rather than tradeable equity.
  • Geography. Statutory business area (営業地区) tied to municipality / prefecture; members must reside, work, or have business in the area.
  • M&A / holding company. No bank holding company route; mergers happen between shinkin under 信用金庫法 procedures and FSA approval; cross-shinkin alliances run through Shinkin Central.
  • BoJ counterparty. The BoJ identifies shinkin banks as an eligible category and its current list includes individual shinkin; institutions without a direct relationship may use Shinkin Central services. Do not publish a federation-only rule for all shinkin.
  • Recent regulatory changes. 信用金庫法 amendments expanding affiliated-business scope and 2021-era cooperative-finance reform mirroring the Banking Act expansion are the main updates; see Cooperative banking in Japan for context.

Tier 8 — Credit cooperative (信用組合)

  • Statute / regulator. 中小企業等協同組合法 plus 協同組合による金融事業に関する法律; supervised by FSA’s 中小・地域金融機関 route in coordination with prefectural authorities. License granted to 信用協同組合.
  • License + count. 143 licensed credit cooperatives per Japan credit cooperative registry, plus the central institution 全国信用協同組合連合会.
  • Capital floor. Cooperative-law minimum 出資金 with FSA-domestic-standard capital adequacy; smaller floors than shinkin.
  • Liquidity. FSA domestic-standard liquidity; central-institution liquidity support from 全信組連.
  • Deposit insurance. DICJ coverage applies.
  • Permitted activities. Member deposits, member lending, FX, settlement; tighter member-eligibility rule than shinkin (members are restricted by industry, region, occupation, or affinity — 業域 / 地域 / 職域).
  • Cross-border. Generally none.
  • Governance. Cooperative / 協同組織 with one-member-one-vote and 出資 membership investment.
  • Geography. Statutory business area; many cooperatives serve a specific occupation or industry rather than a prefecture (e.g. 商工組合中央金庫 historically, ethnic-Korean / Chinese commercial cooperatives, transport-industry cooperatives).
  • M&A / holding company. No bank holding company route; mergers among credit cooperatives are permitted under 中小企業等協同組合法 procedures.
  • BoJ counterparty. 全信組連 is the BoJ counterparty for the credit-cooperative system.
  • Recent regulatory changes. Same cooperative-finance reform envelope as shinkin; affiliated-business scope expansion makes regional revitalization / consulting / digital subsidiary investment somewhat easier than it was pre-2021.

Tier 9 — Rōkin (労働金庫)

  • Statute / regulator. 労働金庫法; jointly supervised by FSA and 厚生労働省 (Ministry of Health, Labour and Welfare). This dual-regulator shape is unique inside the deposit-taking universe.
  • License + count. 13 licensed rōkin per Japan rokin bank registry (regional rōkin like 中央労働金庫, 近畿労働金庫, 東海労働金庫, etc.), plus the central institution 労働金庫連合会.
  • Capital floor. 労働金庫法 minimum 出資金; FSA-domestic-standard capital adequacy applies.
  • Liquidity. FSA domestic-standard liquidity; central-institution liquidity support from 労金連.
  • Deposit insurance. DICJ coverage applies.
  • Permitted activities. Member deposits, lending, mortgage, settlement; members are labour unions, consumer-livelihood cooperatives, and persons affiliated with member organizations. Loans are concentrated in household / worker finance (mortgages, education loans, life-event finance).
  • Cross-border. None of meaningful scale.
  • Governance. Cooperative / 協同組織; member organizations rather than individuals own the rōkin; labour-union representation is structural.
  • Geography. Regional business area; 13 regional rōkin cover Japan together rather than overlapping.
  • M&A / holding company. No bank holding company route; rōkin can merge under 労働金庫法 procedures.
  • BoJ counterparty. 労金連 is the BoJ counterparty for the rōkin system.
  • Recent regulatory changes. Joint FSA / 厚労省 supervision means that workplace and consumer-protection updates filter into rōkin supervision in addition to ordinary FSA bank-supervision updates.

Tier 10 — Norinchukin / JA / JF system (農林系統金融)

  • Statute / regulator. 農林中央金庫法 (for 農林中央金庫); 農業協同組合法 (for JA / Shinnoren credit business); 水産業協同組合法 (for JF / Shingyoren credit business). Jointly supervised by FSA and 農林水産省 (Ministry of Agriculture, Forestry and Fisheries) — another dual-regulator regime.
  • License + count. Norinchukin sits at the apex as the central institution. Below it: prefectural Shinnoren (JA credit federations) and Shingyoren (JF credit federations), and underlying credit-business JA and JF cooperatives. See banking index for the JA Bank system and JF Marine Bank system routes.
  • Capital floor. 農林中央金庫法 sets a dedicated statutory framework for Norinchukin as a cooperative financial institution and national financial institution for agricultural, fishery, and forestry cooperatives; member cooperatives operate under their respective cooperative laws.
  • Liquidity. Banking-equivalent prudential framework applied to Norinchukin (BIS-style capital and liquidity, given its market activities); member institutions run on cooperative-law prudential standards.
  • Deposit insurance. Credit-business JA / JF, Shinnoren / Shingyoren, and Norinchukin are covered by the separate 農水産業協同組合貯金保険制度, not by DICJ “through” that pathway.
  • Permitted activities. Member deposits / 貯金 (technically called 貯金, not 預金, in JA / JF), lending, settlement, FX (through Norinchukin), large-scale securities investment, asset management. Norinchukin is a globally active fixed-income / structured-credit investor by mandate, which is highly distinctive among Japanese deposit-takers.
  • Cross-border. Norinchukin operates a large overseas investment portfolio and has overseas representative offices; member JA / JF cooperatives do not.
  • Governance. Cooperative / 協同組織 at the JA / JF level; at the Norinchukin level, governance follows its dedicated statute and member-organization structure. Agricultural-policy proximity is part of the institutional design.
  • Geography. JA / JF cooperatives are local to their municipal / prefectural areas; Shinnoren / Shingyoren are prefectural; Norinchukin is national.
  • M&A / holding company. No ordinary bank holding company route; system consolidation happens through cooperative-law mergers, federation reorganizations, and central-institution restructuring.
  • BoJ counterparty. Norinchukin holds direct BoJ current-account access as the system central institution.
  • Recent regulatory changes. 農林中央金庫法 amendments around capital structure / regulatory capital, FSA-MAFF joint supervision updates on market-risk and concentration management, and ongoing post-2024 disclosures on portfolio losses / restructuring tracked in the Norinchukin page.

Cross-tier comparison matrix

| Dimension | Megabank | Regional | 2nd regional | Trust bank | Net bank | Foreign branch | Shinkin | 信用組合 | Rōkin | 農林系統 / Norinchukin | |—|—|—|—|—|—|—|—|—|—|—| | Statute / legal route | Banking Act 普銀; “megabank” is not a separate licence | Banking Act 普銀; industry category | Banking Act 普銀; industry-association category | Banking Act + 兼営法 trust-business authorisation | Banking Act 普銀; “net bank” is operational | Banking Act foreign-bank-branch route | 信用金庫法 | 中協法 / 協金法 | 労働金庫法 | 農林中央金庫法 / 農協法 / 水協法 | | Regulator | FSA + BoJ | FSA + Local Finance Bureau | FSA + Local Finance Bureau | FSA (Banking + Trust) | FSA | FSA Major-Banks (foreign-branch route) | FSA 中小・地域 | FSA 中小・地域 + 都道府県 | FSA + 厚労省 | FSA + 農水省 | | Capital / liquidity evidence | Use applicable FSA capital and liquidity notices plus current bank disclosure | Same ordinary-bank rules, selected by international/domestic status | Same ordinary-bank rules, selected by international/domestic status | Bank rules plus trust-business requirements | Same ordinary-bank rules, selected by actual status | Japan-branch rules plus home-office disclosure | Applicable cooperative capital rules and current disclosure | Applicable cooperative capital rules and current disclosure | Applicable rokin rules and current disclosure | Norinchukin and member-institution rules must be checked separately | | Deposit insurance | DICJ | DICJ | DICJ | DICJ + protected-principal trust | DICJ | Not covered by DICJ; home-country regime | DICJ | DICJ | DICJ | 農水産業貯金保険機構 (parallel) | | Permitted activities | Full + securities subs + trust subs | Full + securities subs | Full + securities subs | Full banking + full trust | Full banking | Banking + licensed sub activities | Member deposits / loans + investments | Member deposits / loans (tighter) | Worker / member finance | Member 貯金 / loans + 農中 markets | | Cross-border evidence | Verify legal entities and current offices | Entity-specific | Entity-specific | Entity- and service-specific | Entity-specific | Inherent cross-border parent link; Japan scope is entity-specific | Entity-specific | Entity-specific | Entity-specific | Norinchukin and member institutions differ | | Governance | Joint-stock bank / group | Joint-stock bank / group | Joint-stock bank / group | Joint-stock bank; group position varies | Joint-stock bank; parent route varies | Branch of foreign legal entity | Cooperative / 協同組織 | Cooperative / 協同組織 | Cooperative / labour-organization membership | Cooperative member institutions + special-law Norinchukin | | Geography | No megabank-specific statutory area | No regional-label statutory area | No second-regional-label statutory area | No trust-bank-label statutory area | No net-bank-label statutory area | Licensed Japan branch perimeter | Statutory business area | Statutory business / membership area | Regional rokin area | Local JA/JF scope; national Norinchukin role | | Holding-company route | Banking Act route available, subject to approval | Same | Same | Same bank route; group structure is entity-specific | Same | Japan operation is a branch of foreign parent | Do not infer an ordinary bank-HD route | Do not infer an ordinary bank-HD route | Do not infer an ordinary bank-HD route | System structure; verify each statute | | BoJ current-account route | Eligible bank category; verify current list | Eligible bank category; verify current list | Eligible bank category; verify current list | Eligible bank/trust-bank category; verify current list | Eligible bank category; verify current list | Eligible branch category; verify current list | Individual shinkin may be direct; otherwise central support | Central institution route | Central institution route | Norinchukin central route; member JA/JF generally indirect | | Systemic designation | Check current FSB/FSA lists separately from licence | Not a licence attribute | Not a licence attribute | Group/entity-specific | Not a licence attribute | Home-office and Japan entity differ | Not a licence attribute | Not a licence attribute | Not a licence attribute | Not a licence attribute |

Sources: this matrix separates statutory status from industry/operating labels. FSA registers and supervisory guidance support licence/regulator fields; DICJ and the agricultural/fisheries savings-insurance corporation support the two protection paths; BoJ sources support only eligible categories and the current counterparty list, not universal direct access. ^[Sources: https://www.fsa.go.jp/menkyo/menkyo.html; https://www.fsa.go.jp/common/law/guide/city/index.html; https://www.fsa.go.jp/common/law/guide/chusho/index.html; https://www.fsa.go.jp/menkyo/menkyoj/kenei.pdf; https://www.dic.go.jp/; https://www.sic.or.jp/afc/about/summary/summary/mechanism-insurance-savings/; https://www.boj.or.jp/en/about/education/oshiete/kess/i08.htm; https://www.boj.or.jp/paym/torihiki/ichiran.pdf.]

How to read this matrix

The licence-tier matrix is a public-surface tool. It does not rank institutions, does not estimate balance-sheet health, and does not predict consolidation. It exists so that a banking index entry, a net bank entry, or a foreign-branch entry can be classified consistently before the question of strategy, channel, or franchise gets asked.

When reading any single institution page:

  1. Start with the statute column — that determines almost every other field.
  2. Check the deposit-insurance column. Foreign branches and 農水産業 cooperatives are exceptions to the default DICJ frame.
  3. Check the BoJ current-account route column. Individual shinkin may be direct, while the BoJ describes central-institution access for credit cooperatives, rokin, and agricultural cooperatives.
  4. Check the holding-company column. Cooperative tiers cannot use a bank holding company; foreign branches cannot use one either.
  5. Use the governance column to read whether one-member-one-vote, joint-stock-listed, or branch-of-overseas-entity language applies — that determines what governance, disclosure, and M&A surfaces are available.

Boundary cases and caveats

  • Net bank vs ordinary bank. A net bank is operationally distinct but legally identical to any other 普通銀行. The licence tier is the same as a megabank. See Japan net bank competition map.
  • Trust bank vs ordinary bank. A trust bank is legally distinct (dual licence). An ordinary bank with a trust subsidiary is not the same as a trust bank.
  • Shinkin vs credit cooperative. Both are 協同組織 cooperative-finance institutions with separate statutes; eligibility rules and supervisory bureaus differ. See shinkin registry and credit cooperative registry.
  • Rōkin vs other cooperative-finance. Rōkin are uniquely jointly supervised with 厚労省 and have a labour-union membership structure. See rōkin registry.
  • 農林系統 vs ordinary cooperative-finance. The system uses 貯金 (savings) rather than 預金 (deposits) terminology and has its own savings-insurance organization parallel to DICJ; supervision is joint FSA / 農水省.
  • Foreign bank branch vs Japanese-incorporated foreign-owned bank. A 外国銀行支店 is a branch under Chapter IX. A Japanese-incorporated subsidiary (e.g. banking INDEX entities like SBJ Bank) is a 普通銀行 with foreign ownership, not a foreign-bank branch. Deposit insurance treatment differs.
  • Bank-agent / BaaS surface vs bank licence. A partner-branded app, a BaaS service, or a bank-agent channel is not a separate banking licence — the deposit obligor is the licensed bank. See bank license and BaaS boundary for the legal-stack-vs-UX-stack mapping.

Sources

  • FSA: licensed bank registry workbook (ginkou.xlsx).
  • FSA: shinkin license registry (shinkin.xlsx).
  • FSA: credit-cooperative authorization registry (shinkumi.xlsx).
  • FSA: rōkin license registry (rokin.xlsx).
  • FSA: licensed / registered operator portal (menkyo.html).
  • FSA: 主要行等向けの総合的な監督指針 (major banks supervision guideline).
  • FSA: 中小・地域金融機関向けの総合的な監督指針, including Part V on cooperative financial institutions.
  • DICJ: Deposit Insurance Corporation of Japan public site.
  • 農水産業協同組合貯金保険機構: covered institutions and savings-protection scope.
  • Bank of Japan: eligible current-account-holder categories and current counterparty list.
  • BIS: Basel III framework documentation.
  • 全国銀行協会 (Japanese Bankers Association): Financial Institutions in Japan.
  • 信託協会: trust banks roster and trust-business overview.
  • JA Bank: JAバンクのしくみ / JAバンクシステム.
  • 農林中央金庫: 農林中央金庫の特徴 / system overview.
  • JF Marine Bank: 基本方針 page.
  • 信用金庫: 信用金庫の制度 page.
  • Japanese Law Translation (japaneselawtranslation.go.jp): Banking Act English translation.
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