Japan payment license stack
#JapanFG#legal#payments#funds-transfer#prepaid#EPI
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Overview
Japan payment products can combine several public-regulatory categories: funds transfer, prepaid payment instruments, electronic payment agency, electronic payment instruments, electronic payment handling, credit / installment sales, card acquiring, and bank-account direct payment. A wallet, checkout product, code-payment service, or stablecoin-linked service can therefore have more than one legal route.
This page belongs to JapanFG legal / financial licenses and links to payments domain, funds transfer vs prepaid boundary, funds-transfer registry, prepaid issuer registry, credit / card registry, bank API route, Japan stablecoin regulatory landscape, Japan ECISB license, and Progmat stablecoin route.
License Stack Matrix
| Function | Main public category | Primary law / route | Approval / registration | FinWiki route |
|---|---|---|---|---|
| Non-bank remittance / wallet transfer | 資金移動業者 |
Payment Services Act | Registration | funds-transfer-service-providers-japan-index |
| Stored value for third-party payments | Third-party prepaid payment instrument issuer | Payment Services Act | Prior registration | prepaid-payment-instrument-issuers-japan-index |
| Self-use stored value | Self-use prepaid payment instrument issuer | Payment Services Act | Filing after threshold conditions | funds-transfer-vs-prepaid-boundary |
| Bank account information / payment instruction | 電子決済等代行業者 |
Banking Act route | Registration | japan-bank-api-payment-agency-route |
| Stablecoin / EPI sale, exchange, intermediation, custody-like handling | 電子決済手段等取引業者 |
Payment Services Act | Registration | japan-ecisb-license |
| Bank-commissioned electronic deposit-claim handling | 電子決済等取扱業 |
Banking Act route | Registration | bank-license-and-baas-boundary |
| Credit card / installment / BNPL | Installment Sales Act / credit-purchase route | METI route | Registration where applicable | credit-purchase-card-operators-japan-index, japan-bnpl-credit-purchase-boundary |
| Merchant PSP / acquiring | Merchant-contracting / PSP / card acquiring route | Installment Sales Act, card rules, service terms | Depends on role | card-acquiring-japan-stack, psp-merchant-settlement-risk |
| Bank-account direct payment | Bank Pay / J-Debit / Cotra / bank direct debit route | Network / scheme / bank-account route | Participant and scheme route | account-to-account-payment-japan |
Funds Transfer Route
The funds-transfer route is a Payment Services Act registration category for non-bank remittance. FSA materials identify the current three-type structure:
| Type | Public description in FSA materials | Boundary field |
|---|---|---|
| Type I | Route for transfer needs above JPY 1 million | Higher-value funds-transfer category. |
| Type II | Legacy core funds-transfer category | Main non-bank remittance / wallet-transfer category. |
| Type III | Lower-value transfer route | Low-value transfer category. |
Public verification uses the FSA funds-transfer page, FSA funds-transfer list, entity terms, and registration number. The balance is not recorded as a bank deposit unless the product terms and legal entity identify a licensed bank deposit route.
Prepaid Payment Instrument Route
The prepaid route is a Payment Services Act route for stored value. The main public split is between self-use and third-party prepaid payment instruments.
| Category | Public field | Public verification |
|---|---|---|
| Self-use prepaid instrument | Issuer and eligible merchant / service scope are linked to the issuer’s own group or own service route. | FSA prepaid Q&A, issuer disclosure, terms. |
| Third-party prepaid instrument | Stored value can be used with third-party merchants or services under the instrument route. | FSA third-party prepaid issuer list and service terms. |
| Self-use threshold field | FSA Q&A states that a self-use issuer has filing duties once unused balance exceeds JPY 10 million on the base date. | FSA FinTech Support Desk Q&A and issuer records. |
| Third-party approval field | Third-party prepaid issuer route uses prior registration. | FSA third-party prepaid issuer list. |
The prepaid route is a merchant-payment / stored-value route. It is separate from general remittance unless another route, such as funds transfer, is also present.
Electronic Payment Instrument Route
The Payment Services Act side uses 電子決済手段等取引業者 for electronic payment instruments transaction business. Public FSA EPI materials connect this route to stablecoin / electronic-payment-instrument sale, purchase, exchange, intermediation, and custody-like handling.
The Banking Act side uses 電子決済等取扱業 for bank-commissioned electronic handling of deposit claims. This route is recorded separately in Japan bank license and BaaS boundary because the public legal category is not the same as the Payment Services Act EPI transaction route.
Product-Layer Examples
| Product surface | Possible legal components |
|---|---|
| QR wallet | Funds-transfer registration, prepaid issuer registration, merchant PSP / acquiring, bank API, credit-card linkage. |
| Travel wallet | Funds transfer, prepaid, foreign-exchange / remittance terms, card scheme, bank agency where disclosed. |
| BNPL checkout | Installment-sales / credit-purchase route, merchant-contracting, PSP settlement, credit screening. |
| Bank-account payment | Bank account, bank API / electronic payment agency, account-direct merchant onboarding, refund / cancellation controls. |
| Stablecoin payment | EPI transaction route, electronic payment handling route, issuer / trust / bank classification, wallet or exchange registration where applicable. |
| BaaS deposit wallet | Licensed bank, partner UI, bank agency or electronic payment agency route where disclosed. |
Public Record Fields
| Field | Source route |
|---|---|
| Operator legal name | FSA / METI registry and company disclosure. |
| Registration category | Funds transfer, prepaid, electronic payment agency, EPI, credit / card, bank agency, or electronic payment handling. |
| Registration number | Registry row where available. |
| Funds-transfer type | Type I, Type II, or Type III where disclosed by the FSA list / materials. |
| Prepaid classification | Self-use or third-party prepaid payment instrument. |
| FSA list as-of date | FSA operator-list line or registry file. |
| Service scope | Product terms, official service page, and regulator list. |
| Balance type | Deposit, prepaid balance, funds-transfer balance, credit receivable, electronic payment instrument, or bank deposit claim. |
| Merchant route | Acquirer, PSP, payment facilitator, Bank Pay / J-Debit route, or scheme route. |
| User protection / segregation | Regulator guidance, terms, and disclosure documents. |
JapanFG Operator Links
- Wallet / funds transfer: paypay, merpay, au-payment, rakuten-edy, recruit-mufg-business, jal-payment-port, sbi-remit.
- Merchant PSP / acquiring: gmo-payment-gateway, gmo-epsilon, sb-payment-service, dg-financial-technology, netstars.
- Credit / card / installment: smbc-card, mufg-nicos, rakuten-card, paypay-card, orico, jaccs, paidy.
- Stablecoin / EPI adjacency: jpyc, progmat, jp-exchange-sbi-vc-trade, jp-stablecoin-progmat.
Related
- INDEX
- bank-license-and-baas-boundary
- INDEX
- funds-transfer-vs-prepaid-boundary
- prepaid-payment-instrument-issuers-japan-index
- funds-transfer-service-providers-japan-index
- credit-purchase-card-operators-japan-index
- japan-bank-api-payment-agency-route
- japan-bnpl-credit-purchase-boundary
- account-to-account-payment-japan
- japan-stablecoin-regulatory-landscape
- japan-ecisb-license
- FinWiki index
Sources
- e-Gov: Payment Services Act.
- FSA: licensed / registered operator lists.
- FSA: funds-transfer service provider page and registry.
- FSA: prepaid payment instruments policy pages and issuer registry.
- FSA: FinTech Support Desk Q&A.
- FSA: 2020 Payment Services Act reform explanation.
- FSA: crypto-asset / electronic payment instrument policy pages.
- FSA: electronic payment instruments transaction business page.
- FSA: electronic payment handling business page.
- METI: Installment Sales Act registered operator lists.
Discovery
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