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2026年08月07日

Japan Demands Advertiser Verification: How a Seven-Agency Request Exposes the Contest Over Identity Infrastructure

詐欺広告に「本人確認」を求める日本政府——7省庁要請が突きつける身元インフラの主導権問題

Administrative Guidance With Reporting Obligations Attached

The text of the request reveals something more demanding than a policy appeal. Under the first pillar, platforms must implement reliable advertiser verification including electronic authentication methods, submit written descriptions of their specific implementation to the Digital Agency by October 16, 2026, and report on results achieved between October 1, 2026 and February 28, 2027 by March 16, 2027. The reporting schema is unusually granular, extending to case counts and percentages broken out by verification method and by domestic versus overseas advertisers, plus rejection counts and rates attributable to verification failures.

The second pillar requires platforms to display the advertiser's name, address, and verification status, alongside disclosure that an advertisement was created primarily using generative AI. The third pillar requires reporting of takedown counts broken out by legal basis and by trigger, along with per-requesting-body removal rates, average response times, and reasons for non-removal.

Legally, the measure is administrative guidance under Article 2, Item 6 of the Administrative Procedure Act, not a disposition. Yet the text explicitly flags that displaying fabricated investment records under a celebrity's name may violate Article 161(1) of the Penal Code, and that unregistered operators using advertisements as a funnel may violate Article 29 of the Financial Instruments and Exchange Act. Criminal and regulatory hooks are embedded inside a non-binding request.

Advertising as Entry Point, Crypto as Exit

According to the NPA's finalized 2025 figures, SNS-based investment fraud reached 9,523 recognized cases, up 48.5 percent year on year, with losses of ¥128.80 billion, up 47.9 percent—an average of roughly ¥13.53 million per case. Banner advertising accounted for 3,785 initial contacts and direct messaging for 3,549, together roughly 80 percent of the total. The request further notes the banner-advertising contact channel breakdown: YouTube at 27.1 percent, Instagram at 16.3 percent, TikTok at 10.4 percent, Facebook at 6.5 percent, LINE at 4.8 percent, and X at 2.1 percent. The five recipient companies operate all six of these services.

The exit-side figures are heavier still. Within SNS-based romance fraud, crypto-transfer cases rose to 2,177, up 177.0 percent, with losses of ¥24.77 billion, up 189.7 percent. Combined with crypto transfers within the bank-transfer category, cases where proceeds were effectively delivered in crypto assets accounted for 40.4 percent of recognized cases and 48.6 percent of total losses. Fraud enters through advertising and exits through crypto. What connects the two ends is a gap in identity verification, and the government is now moving to close both simultaneously.

The Taiwan Comparison and the Enforcement Risk

Taiwan offers the reference case. Its Fraud Crime Hazard Prevention Act, effective July 2024, imposes binding legal obligations on online advertising platform operators to verify the identities of advertisers and funding providers using digital signatures, FIDO authentication, or equivalent methods, to maintain a fraud prevention plan, and to publish an annual transparency report. Taiwan's Ministry of Digital Affairs subsequently reported that investment scam advertising fell 96 percent and impersonation advertising fell 94 percent.

Japan has chosen administrative guidance with reporting obligations rather than statutory duty—a choice that carries risk. Internal documents reported by Reuters in late 2025 indicate that Meta, fearing Japan would mandate universal advertiser verification, identified the search terms and celebrity names regulators used, ran those searches itself, and removed flagged advertisements from its Ad Library. The reporting describes an effort that cleaned what regulators could see while avoiding structural verification. Following the outcome in Japan, the approach was reportedly incorporated into a global playbook deployed in the United States, Europe, India, Australia, and Brazil. The granularity of the current reporting schema reads as a response to precisely that experience.

Why the My Number Card Was Named

An easily overlooked element carries strategic weight: the request explicitly identifies the My Number card as a reliable individual verification method and the commercial registry electronic certificate for corporate entities. The design would embed Japan's national digital identity infrastructure at the entry point of advertising placement on foreign platforms. The joint LDP project team on deepfake countermeasures, chaired by Masaaki Taira, adopted its formal party recommendation on May 19, 2026, calling for statutory Know Your Advertiser obligations backed by penalties. The current request functions as the evidence-gathering phase preceding that legislation.

The implications for the crypto sector are explicit. Among the contact points listed for this request is the FSA's Crypto Asset and Stablecoin Division, newly established in the same August 7 reorganization, and the Director-General of the Asset Management and Insurance Supervision Bureau that oversees it is a co-signatory. One day earlier, on August 6, the FSA and NPA jointly asked the JVCEA to strengthen eleven categories of fraud countermeasures, including withdrawal restrictions and advance registration of withdrawal destination addresses. Within a single week, the government has placed monitoring points at both the advertising entry and the exchange exit.

Business Development Insights

  1. Identity verification shifts from a compliance cost to an exportable product category. Taiwan made risk-proportionate authentication—digital signatures, FIDO, OTP, bank account matching—a statutory requirement, and Japan has now named the My Number card and the commercial registry electronic certificate. Because verification implementation depends on each country's national ID infrastructure, operators who build advertiser authentication against Japanese credentials acquire a reference implementation transferable to other platform-regulation regimes. For digital identity providers, eKYC vendors, and firms handling corporate registry data, advertising placement has opened as a new demand surface.
  2. Crypto exchanges are being repositioned from fraud exit point to fraud detection point. The August 6 JVCEA request and the August 7 advertising request together place surveillance at both ends of the victim journey. Withdrawal restrictions and advance address registration impose obvious UX degradation, but whether a firm implements these as pure compliance burden or converts them into improved suspicious-transaction detection and explanatory capability will determine future regulatory cost and business risk. The ability to correlate transaction monitoring with advertising-originated complaint data becomes a competitive asset beyond compliance.
  3. The reporting deadlines constitute a de facto decision calendar. The structure—implementation reporting by October 16, 2026, an execution window from October 1, 2026 to February 28, 2027, and results reporting by March 16, 2027—is precisely an evidence-collection process for a legislative decision in spring 2027. Financial and crypto-related businesses dependent on platform advertising should plan on the assumption that stricter ad review standards, corporate authentication requirements, and rising rejection rates will arrive simultaneously by autumn 2026, and restructure placement plans and customer acquisition channels accordingly.

Sources

Supervisor

Akihisa Ishida

Cabinet Inc. Founder CEO

Since 2017, He has been consistently engaged in token and NFT utilization, blockchain game planning and development, and NFT-based business development. Having contributed to over 80 blockchain products—including projects for major entertainment companies listed in Tokyo Stock Exchange —He has served in various key roles such as Business Lead, Designer, PM, and Advisor. In 2021, founded Cabinet Inc.

Disclaimer

This report has been prepared solely for informational purposes regarding crypto assets and related markets, and is not intended to recommend, solicit, or offer the purchase, sale, holding, or any other transaction of any specific crypto asset. It does not constitute investment advice, investment solicitation, or the sale or intermediation of financial products as defined under the Financial Instruments and Exchange Act or any other applicable laws and regulations, nor does it constitute tax, legal, or accounting advice.

The information contained in this report is based on sources believed to be reliable at the time of preparation; however, we make no representation or warranty, express or implied, as to its accuracy, completeness, timeliness, or usefulness. Crypto assets are subject to significant price volatility and may result in the loss of principal or other financial losses. Any investment decision shall be made solely at the user's own discretion and responsibility, and we accept no liability whatsoever for any damages arising out of or in connection with the use of this report.

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