Financial Service Intermediary License Update

Norbert Gehrke
Tokyo FinTech
Published in
3 min readMar 24, 2023

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Japan’s revised “Act on Provision of Financial Services” came into effect in November 2021, and with it a new, cross-sector Financial Service Intermediary Business license was introduced. This license makes it possible to offer simple financial products and services across banking, securities, insurance and money lending businesses with a single registration.

Source: KPMG

The intent of the law was to introduce three important factors for the FinTech:

  • Single licensing regime
  • Fundamental change in agency
  • Ability to initiate money transmissions under same license

In July 2022, we noted “A slow start for Japan’s Financial Services Intermediary License”, with only three registrants, two of which — 400F and SBI Neo Mobile Securities — were granted an early start and got approved with the launch of the new regime.

Taking a fresh look at the licensing situation, we now see seven registrants, with the “newbies” including SJML Japan, the operator of Habitto, the first foreigner-founded company to be granted the license, as well as Recruit Payment, NTT Docomo and SBI NeoTrade Securities.

In addition, while the Intermediary License allows for operations across various industry verticals in principle, the actual approval for such business operation always depends on the FSA being satisfied with the business plan and the operating model. As such, a company that has previously obtained an Intermediary License for Securities, for example, will need to go through an additional approval process if it now wants to intermediate deposits as well. This is how SJ Mobile Lab Japan, which was initially licensed in October 2022, recently added other verticals and is now in the leading position in terms of the overall scope of intermediary services provided.

Should you be interested in learning more about Habitto, please join our Tokyo FinTech Meetup on Wednesday, March 29, when André Bose do Amaral, Chief Product Officer, will discuss with our community the “New Generation, New Money Habits: the Habitto road ahead”.

This article is part of our Tokyo FinTech Publication, please follow us to read more from our writers, like hundreds of readers do every day. Please also register for our short weekly digest, published some Saturdays, at the link below.

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Norbert Gehrke
Tokyo FinTech

Passionate about strategy & innovation across Asia. At home in Japan. Connector of people & ideas.