Japan's FSA Publishes an Eight-Jurisdiction Survey of Financial Regulation: Japan's Trust-Type Stablecoin Is Closest to the UK Model, Isolated by Its Transfer Cap and Issuer Trichotomy

What was published

The FSA's Planning and Coordination Bureau commissioned the survey "as a reference for planning and drafting financial regulation." The cover is dated March 2026 and press reports put it at 609 pages. Each jurisdiction's chapter has two parts, supervisory authorities and types of financial institutions with their principal regulation, running from deposit-takers through insurers, comprehensive exchanges and fund-transfer and crypto-exchange operators. The table of contents starts the US at page 1, the UK at 103, the EU at 198, Germany at 269, France at 330, Singapore at 378 and China at 433; crypto-related sections sit around pages 86, 182, 259, 321, 369 and 421 respectively. The separate comparison tables focus on conventional metrics such as supervisory headcount, capital ratios and interest-rate caps, with no stablecoin or RWA table. This is not a crypto document; it embeds digital-asset regulation as one section within a whole-of-system comparison.

Where the eight jurisdictions stand in the report

According to press coverage, the US chapter centers on the GENIUS Act signed July 18, 2025, recording 100% or more reserve backing, the ban on paying interest to holders, and an effective date of the earlier of January 18, 2027 or 120 days after final rules. The EU's MiCA applied in full from December 30, 2024, and the transition period of up to 18 months ended in June 2026. The UK is described at the FCA consultation stage, with three features: reserves held by a third party outside the issuer's group, redemption no later than the next business day after required information is complete, and no pass-through of reserve interest to holders. China's February 6, 2026 notice from the People's Bank of China and seven other departments prohibits domestic RWA tokenization issuance, trading and intermediation in principle, with an exception only for business approved by the competent authority and conducted through designated financial infrastructure. Hong Kong's SFC circulars of November 3, 2025 broadened the tokenized securities licensed exchanges may handle and permitted order-book integration with overseas group affiliates. Because the report is dated March, it predates the FCA's final rules PS26/10 of June 30, 2026 and the failed September procedural vote on the CLARITY Act.

What Japan's trust-type resembles

Japan's electronic payment instruments are split into three types by issuer licence: bank-deposit type, fund-transfer type and trust type. The trust type is structured as a beneficial interest in a trust issuing beneficiary certificates, and the amendment effective June 2026 allowed up to 50% of backing assets to be held in Japanese and US government bonds maturing within three months and in term deposits. Structurally the closest match is the UK. The FCA's PS26/10 holds the backing pool on statutory trust for tokenholders, ring-fenced from the issuer's insolvency estate, with third-party custody and T+1 redemption. Both regimes locate insolvency protection in a legal vessel, the trust, rather than in issuer capital. By contrast, the GENIUS Act is issuer-licence-centric, confining reserves to cash and Treasuries of 93 days or less and banning interest to blunt competition with deposits. MiCA's e-money token rules resemble Japan's deposit-heavy backing by requiring a share of reserves in bank deposits, but the vessel is an e-money institution licence. Hong Kong's ordinance, in force since August 2025, sets a HKD 25 million (about JPY 480 million) minimum capital; Singapore requires redemption within five business days under an MPI licence. Japan shares the UK's vessel but is looser in lacking a statutory redemption deadline and stricter in its transfer rules.

Three points where Japan stands alone

First, the JPY 1 million transfer cap on Type 1 instruments and the requirement that Type 3 transfers above JPY 1 million be covered by an approved business plan have no counterpart in any of the eight jurisdictions. Second, Japan's May 2026 Cabinet Office ordinance, effective June 1, admits foreign stablecoins through an equivalence test: the issuer's home regulation must be comparable and its supervisor able to share information with the FSA. This points the same direction as the GENIUS Act's bilateral comparability determinations due by July 2027, but Japan has neither a negotiating counterpart nor a deadline. Third, the amendment promulgated July 2026 moving crypto-assets into the FIEA left stablecoins outside, fixing a two-statute structure in which investment crypto and payment stablecoins live under different laws, the opposite of MiCA's single rulebook.

Reverse-engineering next year's reference jurisdictions

The secretariat paper for the FSA study group on digital and decentralized finance, which convened October 20, 2026, lays out a timeline of GENIUS Act milestones (effectiveness January 2027, bilateral arrangements July 2027, trading cutoff for non-approved coins July 2028) alongside the UK's October 2027 commencement and ESMA's September 30 recommendations. The pattern suggests a three-way borrowing: the UK's PS26/10 for reserve and insolvency design, the GENIUS comparability framework for mutual recognition of foreign stablecoins, and Hong Kong's SFC circular for widening tokenized securities trading. Nomura Holdings' request at the study group to revisit the JPY 1 million holding and transfer restriction on foreign-issued stablecoins is defensible only once UK-style redemption guarantees and US-style mutual recognition are both in place. Whether a bill reaches the 2027 ordinary session depends on how far Japan can replicate, in equivalent terms, the end-states this report documents for the eight jurisdictions.

[Business Development Insights]

1. Japan's trust-type stablecoin translates structurally into the UK's statutory trust under PS26/10, so equivalence claims or dual issuance in the UK are more tractable than in other jurisdictions. Building in the UK's 80%-plus third-party custody and T+1 redemption from the domestic launch allows an issuer to argue "already compliant" in mutual-recognition talks from 2027 onward.
2. The June 2026 equivalence route opened domestic handling of foreign stablecoins, but the JPY 1 million wall still rules out institutional DvP and trade settlement. With the restriction now on the study group's agenda, intermediaries and custodians have a window to table a concrete proposal: move transfers above JPY 1 million from approval to notification.
3. With mainland China prohibiting RWA tokenization in principle and Hong Kong's SFC widening tokenized securities trading, Greater China demand will funnel through Hong Kong's designated infrastructure. Connecting Japanese real-estate security tokens or tokenized MMFs structured via beneficiary-certificate trusts to Hong Kong licensed exchanges is the clearest institutional interface among the eight jurisdictions.

[Sources]

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