Third-party issuer: Registration application
Updated: July 2026, 3
What is a prepaid payment instrument (third-party) issuer?
A prepaid payment instrument is a system in which users can pay money in advance and receive goods or services according to the value of that money.
Typical examples are prepaid cards and electronic money.Third-party prepaid payment instrumentsThis refers to a type that can be used not only by your own company but also by external affiliated stores.
For example, systems that can be used at many stores other than the issuer, such as transportation IC cards and retail electronic money, are all classified as third-party types.
In contrast, there are also "in-house" types that can only be used at a company's own stores, but this article explains how to apply for registration as a third-party issuer.
Please see here for the differences between this and third-party types.
Registration is required to issue
If you wish to issue a third-party prepaid payment instrument, you must register with the local finance bureau in your jurisdiction in accordance with the Payment Services Act.
Issuing a third-party prepaid payment instrument without registration is a violation of the law, so prior registration is required.
Registration application process
The registration application process can be broadly divided into three stages: "preliminary consultation," "draft review," and "main review."
(The following is based on the experience of the Support Administrative Scriveners Corporation, and the process may differ depending on the local finance bureau.)
① Advance consultation
The first step is to have a preliminary consultation with the Finance Bureau or Finance Office.
We will explain the planned business scheme and work content, and receive confirmation from the authorities regarding the system and application requirements.
Specifically, confirmation is carried out using a prescribed form called the "Pre-Consultation Summary Sheet."
The "Pre-consultation Form" contains approximately 50 questions, and even after you have answered them all, the authorities will continue to ask you additional questions about more detailed aspects.
② Draft screening
After the preliminary consultation, we will prepare a draft of the complete application documents (application form, internal rules, checklists, etc.) and proceed to confirm them with the authorities.
This stage is not yet a formal application, but rather a pre-application check by the authorities, and you will receive a variety of comments, from matters related to basic internal system development to minor typos and omissions.
If there are no problems after the draft review, you can pay the registration tax (15 yen) and proceed to the main review.
(We also voluntarily join the Japan Payment Service Association, etc.)
③ Main examination
In this review, the completed application documents based on the draft are officially submitted (often via electronic application using G Biz ID) and then reviewed by the authorities.
In practice, authorities may request detailed confirmations or corrections at this stage.
The standard processing period is two months, and notification of registration is generally sent after that period.
After that, you will need to complete the necessary procedures after registration, such as depositing the issuance guarantee.
These processes will allow you to officially register as a "third-party prepaid payment instrument issuer" and begin operations.
Registered businesses can be found on the Financial Services Agency website"List of Registered Issuers of Prepaid Payment Instruments (Third Party Type)"The company name etc. will be published.
Overview of registration requirements
The outline of the registration requirements for issuers of prepaid payment instruments (third-party type) is as follows:
(1) About the organization
Corporations or foreign corporations with a business office or office in Japan
(2) Property
Net assets must be 100 million yen or more. *Excluding non-profit corporations specified by government ordinance.
(3) Business execution system
Measures have been taken to ensure that goods or services provided through prepaid payment instruments do not violate the public interest.
A system has been established to ensure that payments to affiliated stores are made appropriately.
(4) Legal compliance system
The necessary systems have been established to comply with the provisions of laws and regulations related to issuers of prepaid payment instruments.
(5) Trade name
Not to use the same or similar trade name or name used by other prepaid payment instrument issuers (third-party issuers)
(6) Refusal requirements for corporations or their officers
The corporation or its officers engaged in the prepaid payment instrument issuing business do not fall under certain refusal requirements (violation of laws and regulations, bankruptcy proceedings, etc.)
Regarding business execution system and legal compliance system
In the "Overview of Registration Requirements"The key points are "Business execution system" and "Legal compliance system."
The rest of the definitions are concise and easy to understand, but the law only provides abstract definitions for "Business execution system," such as "Measures are taken to ensure that products or services provided through prepaid payment instruments do not violate the public interest, and a system is in place to ensure appropriate payments to affiliated stores," and "Legal compliance system," such as "A system necessary to comply with the provisions of laws and regulations related to issuers of prepaid payment instruments is in place."
The reason for this is that ``the law makes rough decisions, so please see the Administrative Guidelines (Book 3: Related to financial companies, 5. Related to prepaid payment instrument issuers) for details.''
The administrative guidelines (Volume 3: Financial Companies, 5. Prepaid Payment Instrument Issuers) contain a huge number of rules.
There are a wide range of hurdles that businesses aiming to register as prepaid payment instrument issuers must overcome, from preventing damage caused by anti-social forces to managing user information and systems.
In terms of volume, the pages containing the rules alone amount to nearly 50 A4 pages.
reference:Administrative Guidelines (Volume 3: Financial Company Relations, 5. Prepaid Payment Instrument Issuers Relations)
High-value electronically transferable prepaid payment instruments
If you wish to issue high-value electronically transferable prepaid payment instruments, you will also be required to have systems in place to combat money laundering and terrorist financing, such as transaction verification, customer management, and transaction monitoring.
For details on what constitutes a high-value electronically transferable prepaid payment instrument, please see the article below.
Post-registration procedures
After registering as an issuer of prepaid payment instruments (third-party type), there are certain administrative procedures that must be completed.
Here we will introduce some of the most representative administrative procedures.
■Report on publishing operations
Third-party issuers are obligated to submit a "Report on the Issuance of Prepaid Payment Instruments" to the competent financial (branch) director, etc.
As for when to submit, it is within two months from each reference date (the end of March and the end of September), so it must be submitted at the end of May and the end of November.
■ Notification of changes
If there is a change in any of the following matters, a third-party issuer must notify the competent financial (branch) director, etc. of the change without delay along with the attached documents.
| Changes |
| Change of name, trade name or name |
| Amount of capital or investment |
| If a business office or office is established, relocated, or abolished; |
| Change of officers |
| Changes in the type, name, payable amount, etc. of prepaid payment instruments |
| When purchasing or borrowing goods or receiving services, there is a period or time limit in which the money can be used to pay for these costs, or a request can be made for the delivery of goods or the provision of services. is a change in the period or deadline. |
| Changes in the content and method of issuing prepaid payment instruments |
| Changes in the location and contact information of the business office or office that responds to complaints or consultations from users regarding the issuance and use of prepaid payment instruments |
| Change in major shareholders |
| If there is a change in the bank, etc. where the general incorporated association, etc. deposits the deposits. |
| If you join or withdraw from the Certified Fund Settlement Business Association |
If you have any problems, please contact Support Administrative Scrivener Corporation.
At Support Administrative Scrivener Corporation, we provide application support and consulting regarding the Fund Settlement Act for both those wishing to obtain new permits and licenses as well as existing businesses.
Registration related to the Funds Settlement Act (funds transfer business, prepaid payment instrument issuing business, etc.) is highly specialized and can be said to be one of the fields in which there are few administrative scriveners who can handle it.
We provide legal services related to the Fund Settlement Act based on the know-how and track record that we can accumulate because we are administrative scriveners who handle applications and negotiations with administrative agencies on behalf of companies on a daily basis.
The first interview is free of charge. Please feel free to contact us.
Editor of this article
Certified AML Specialist
Yu Shimizu
