JAPAN Law and Practice Contributed by: Keisuke Hatano, Takeshi Nagase, Takato Fuki and Tomoaki Katayama, Anderson Mori & Tomotsune
Anderson Mori & Tomotsune Otemachi Park Building 1-1-1 Otemachi Chiyoda-ku Tokyo 100-8136 Japan Tel: +81 3 6775 1000 Email: keisuke.hatano@amt-law.com Web: www.amt-law.com
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain 1.1.1 Evolution of Uses of Blockchain Recent Developments in the Adoption of Blockchain Over the Past 12 Months Over the past year, the use of blockchain in Japan has undergone a notable transition from a phase centred on “speculative trading” to a phase of “implementa- tion as part of a regulated financial infrastructure”. The key developments are as follows. First, the launch of the stablecoin. On 27 October 2025, JPYC Inc. issued Japan’s first yen-denominated stablecoin, JPYC, under a fund remittance business operator license under the Payment Services Act (PSA). Second, there is progress in the tokenisation of secu- rity tokens (STs), real estate and bonds. In addition to the development of an ST secondary market on the Osaka Digital Exchange, projects involving the tokeni- sation of the so-called Real-World Assets (RWAs), such as real estate Security Token Offerings (STOs), corporate bond STOs and municipal green bonds, are being continuously structured. Third, there is progress on the amendment bill regard- ing the transition of crypto-assets under the Financial Instruments and Exchange Act (FIEA). On 10 Decem- ber 2025, the “Working Group on Crypto-Asset Sys- tems,” established by the Financial System Council, compiled a report on the appropriate framework for
crypto-asset systems (the “Working Group Report”). In response, on 10 April 2026, the “Bill to Partially Amend the Financial Instruments and Exchange Act and the Payment Services Act” (the “Amendment Bill”) was approved by the Cabinet and submitted to the 221st Diet session. The core of this amendment lies in transferring regulations concerning crypto-assets from the PSA to the FIEA. The Working Group Report noted that the FIEA is based on the principle of establishing a comprehen- sive investor protection framework that covers a wide range of financial products with strong investment characteristics. It further noted that, as most crypto- asset transactions are conducted with the expecta- tion of returns tied to price fluctuations, this aligns with the concept of “investment characteristics” that should be subject to regulation under the FIEA. Con- versely, as crypto-assets generally do not represent any legal rights and do not involve the distribution of dividends or residual assets, their nature differs from that of securities under the FIEA. Therefore, it is con- sidered appropriate to position them within the Act as a regulatory category distinct from securities. Major Use Cases Currently Under Consideration In practice, the cases currently under consideration for use are as follows. First, B2B and cross-border payments using stablecoins as a settlement mecha- nism. Several major financial institutions are exploring the use of JPY-denominated stablecoins and bank- issued deposit tokens for inter-company settlements and trade finance.
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