Japan introduced the Electronic Payment Instruments and Crypto-Asset Service Intermediary Business framework on June 1, 2026.
Under this framework, a business that intermediates the purchase and sale or exchange of crypto-assets between users and a registered crypto-asset exchange service provider may use a separate registration regime from that applicable to traditional crypto-asset exchange service providers.
However, simply connecting users to a Japanese exchange does not mean that every service is subject to the same regulatory treatment. Whether registration is required may differ depending on whether the business recommends or explains specific crypto-assets, induces users to enter into transactions, or directly handles user assets.
[Japan Financial Services Agency: Information for Persons Engaging in Electronic Payment Instruments and Crypto-Asset Service Intermediary Business]
1. What Is a Crypto-Asset Service Intermediary Business in Japan?
A crypto-asset service intermediary business is a registration framework for businesses that, under delegation from a registered crypto-asset exchange service provider, intermediate the purchase, sale, or exchange of crypto-assets.
Previously, even businesses that merely intermediated crypto-asset transactions could potentially fall within the registration requirements applicable to crypto-asset exchange service providers.
Under the current framework, however, a business may consider separate registration as a service intermediary where it performs intermediary functions for a registered exchange without directly holding users’ cash or crypto-assets.
This does not mean that the regime allows an intermediary to freely broker transactions across multiple exchanges. The framework presupposes that the intermediary operates under delegation from a registered crypto-asset exchange service provider.
In addition, whether a business falls within the intermediary regime should not be determined solely by whether it provides a one-time connection. It is also necessary to consider whether the business repeatedly and continuously provides intermediary services to an unspecified number of users.
[Japan Financial Services Agency: Guidelines on Relationships Between Electronic Payment Instruments and Crypto-Asset Service Intermediaries]
2. How Is It Different from a Crypto-Asset Exchange Service?
The most important distinction is that a service intermediary generally does not directly hold users’ cash or crypto-assets, but instead performs an intermediary function.
Comparison of Crypto-Asset Exchange Services and Crypto-Asset Service Intermediary Businesses
| Category | Crypto-Asset Exchange Service | Crypto-Asset Service Intermediary Business |
| Main activities | Purchase/sale, exchange, intermediation, asset management, etc. | Intermediation of purchase/sale or exchange |
| Affiliation with an exchange | Not required | Delegation from a registered exchange required |
| Custody of user assets | May be permitted depending on the business | Generally not permitted |
| Financial requirements | Applicable | No separate financial requirement where no user assets are held |
| AML / identity verification | Performed directly | Generally handled by the affiliated exchange |
| Advertising and disclosure rules | Applicable | Applicable |
Rather than viewing the intermediary regime simply as a deregulated version of the crypto-asset exchange business, it is more accurate to understand it as a separate registration framework for intermediary activities that do not involve custody of user assets.
Because the model assumes affiliation with a registered exchange, that exchange is also expected to supervise and oversee the intermediary’s activities. Accordingly, businesses preparing to enter the market must determine which registered exchange will delegate the intermediary work and what scope of activities will be delegated.
[Japan Financial Services Agency, Minutes of the First Working Group on Crypto-Assets]
3. Can Simply Linking Users to an Exchange Constitute “Intermediation”?
Providing a link to an exchange does not automatically constitute an intermediary business.
Rather than focusing solely on whether a business formally provides a link, the Japan Financial Services Agency considers the extent to which the service provider is actually involved in the process of entering into crypto-asset purchase and sale agreements.
The likelihood of being regarded as an intermediary may increase where the business:
- recommends crypto-asset transactions to specific users;
- explains specific crypto-assets for the purpose of encouraging transactions;
- independently recommends or prioritizes certain products;
- negotiates terms for the execution of transactions; or
- actively induces users to complete transactions.
By contrast, if a platform merely connects users to a registered exchange, while the exchange itself provides product explanations and the platform does not separately engage in recommendations, inducement, or negotiation of transaction terms, it may be less likely to constitute intermediary activity.
Accordingly, it is necessary to review the service interface, recommendation algorithms, explanatory language, and the overall transaction flow, rather than focusing only on whether the platform provides an external link.
[Japan Financial Services Agency: Guidelines on Relationships Between Electronic Payment Instruments and Crypto-Asset Service Intermediaries]
4. Gaming, Wallet, and Web3 Services Also Require Review
Games, wallets, Web3 platforms, and similar services targeting Japanese users should also assess whether their services may constitute crypto-asset intermediation when they connect users with crypto-asset purchases or transactions.
In particular, the following points should be reviewed:
- whether the platform recommends specific crypto-assets;
- whether it directly explains how to purchase or trade crypto-assets;
- whether it participates in determining orders or transaction terms;
- whether the counterparty is a registered Japanese crypto-asset exchange service provider; and
- whether users’ cash or crypto-assets pass through the platform.
For example, even where a game merely guides users to purchase a specific token and redirects them to an exchange, the legal assessment may differ depending on whether the platform is only providing a technical connection or is actually recommending or explaining the transaction.
[Japan Financial Services Agency: Guidelines on Relationships Between Electronic Payment Instruments and Crypto-Asset Service Intermediaries]
5. What Korean Companies Should Review Before Entering Japan
Operating a service from Korea does not automatically exclude the business from Japanese regulation.
Where an overseas business commercially provides crypto-asset intermediary services to Japanese users, it should review whether Japanese registration requirements apply.
In particular, the following service flow should be examined:
Service interface → Recommendation or explanation of crypto-assets → Connection to exchange → Order → Movement of cash or crypto-assets
At each stage, businesses should determine the respective roles of the platform and the Japanese exchange, identify which party has the contractual relationship with the user, and assess the extent to which the platform is involved in the transaction.
Where intermediary registration is required, businesses should also review the following matters:
- the scope of delegation from the registered crypto-asset exchange service provider;
- user-facing disclosures and advertising; and
- internal management and compliance systems.
[Japan Financial Services Agency: Guidelines on Relationships Between Electronic Payment Instruments and Crypto-Asset Service Intermediaries]
6. How Will Japan’s Crypto-Asset Regulatory Framework Change?
The current service intermediary regime is already in force, but Japan has also finalized broader reforms to its crypto-asset regulatory framework.
In July 2026, Japan enacted amendments to the Financial Instruments and Exchange Act and the Payment Services Act, and regulatory reforms are expected to shift crypto-asset trading rules from the Payment Services Act framework toward the Financial Instruments and Exchange Act framework.
As a result, intermediary activities involving crypto-assets that currently fall within the Electronic Payment Instruments and Crypto-Asset Service Intermediary Business regime are expected to transition in the future to an intermediary framework under the Financial Instruments and Exchange Act.
[Japan Financial Services Agency: Explanatory Materials on Amendments to the Financial Instruments and Exchange Act and Payment Services Act]
As of August 2026, however, the detailed implementation rules have not yet been finalized, and the effective date will be determined separately by Cabinet Order within the scope provided by the amended legislation.
Accordingly, businesses preparing new crypto-asset services in Japan should structure their operations with both the currently effective intermediary regime and the anticipated transition to the Financial Instruments and Exchange Act framework in mind.
[Japan Financial Services Agency: Original Text of the Amendments to the Financial Instruments and Exchange Act and Payment Services Act]
7. Frequently Asked Questions (FAQ)
Q1. Do we need registration if we only provide a link to a Japanese exchange?
Not necessarily.
Simply providing a link does not automatically constitute intermediary activity. However, if the service recommends or explains specific crypto-assets and induces users to enter into transactions, the likelihood of being regarded as an intermediary may increase.
Q2. What if we recommend a specific coin and then connect users to an exchange?
Depending on the level of recommendation or product explanation, the service may constitute intermediary activity. The platform interface, recommendation method, and the extent of the platform’s involvement in the actual transaction should all be reviewed.
Q3. Can a service intermediary hold customers’ crypto-assets?
As a general principle, the service intermediary framework assumes that the intermediary does not directly hold users’ cash or crypto-assets. If the business intends to provide direct custody, it should separately review whether other registration or regulatory requirements apply.
Q4. Can a Korean company be subject to Japan’s intermediary regulations?
Yes.
If a Korean company commercially provides crypto-asset intermediary services to users in Japan, it may need to assess Japanese regulatory requirements even if the service itself is operated from Korea.
Q5. Is the current intermediary regime expected to disappear?
The current framework remains in effect. However, amendments enacted in July 2026 are expected to move crypto-asset intermediary regulation toward the Financial Instruments and Exchange Act framework. New market entrants should therefore consider the upcoming regulatory transition when structuring their businesses.
Japan Crypto-Asset Businesses Should Begin with Their Service Structure
Japan’s crypto-asset service intermediary framework allows businesses that connect registered exchanges with users without directly holding user assets to consider a registration model that differs from the traditional crypto-asset exchange service framework.
However, the required registration and applicable regulations may vary depending on the distinction between mere introduction and actual intermediation, the flow of user assets, and the nature of the delegation relationship with the registered exchange.
Japan is also in the process of restructuring its broader crypto-asset regulatory framework. New market entrants should therefore design their business models with both the current regulations and the upcoming transition in mind.