The regulatory landscape for foreign banks in Japan remains marked by both longstanding structural issues and recent areas of incremental reform. While we commend authorities for the clear progress in certain domains such as updates to the AML framework and early steps toward a digital currency regime, the EBC believes that some hurdles remain, that impede the full and efficient participation of foreign banks in the Japanese market. These challenges are particularly evident in the Foreign Bank Agency Business framework, where the current dual-approval system remains cumbersome and out of step with global practices.
Japan’s ambition to enhance its role as an international financial centre hinges on its ability to adapt its regulatory systems to the evolving needs of global finance. However, rules rooted in legacy concerns, such as the firewall regulations limiting joined-up banking and securities activities, continue to restrict operational flexibility. Similarly, while discussions are underway on syndicated lending and stablecoin infrastructure, the policy and regulatory responses remain either pending or incomplete.
The Japanese authorities have taken some commendable steps, including the establishment of working groups and forums to explore forward-looking reforms. Yet, the pace and scope of these efforts need to accelerate. Ensuring a level playing field for all market participants—foreign and domestic—requires coordinated adjustments across multiple legal frameworks, including the Banking Act and the Money Lending Act. Without such systemic changes, Japan risks limiting both its competitiveness and the attractiveness of its financial sector to international institutions.
The issues raised in this document reflect practical experiences and persistent concerns from the foreign banking community. They are presented alongside specific recommendations aimed at informing the ongoing dialogue between industry stakeholders and Japanese regulators, with the shared objective of promoting a more open, efficient, and globally integrated financial system.
Key issues and recommendations
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Published:
Firewalls
status:
No progress -
Published:
CBDC
status:
Progress -
Published:
AML
status:
Some progress -
Published:
Cross-border payments
status:
Some progress -
Published:
Foreign Bank Agency Business
status:
No progress -
Published:
Syndicated loans
status:
New
Chairman
c/o Mr. Bjorn Kongstad
Chief Policy Director, European Business Council in Japan (EBC)
Toranomon Hills Business Tower 15F
1-17-1 Toranomon
Minato-ku, Tokyo 105-6415
Tel: +81-3-6807-5933
Upcoming committee meeting schedule
Please contact the EBC ( ebc@ebc-jp.com ) to confirm the meeting location prior to attending
DATE | TIME | LOCATION |
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2025 |