Japan Act No. 28 of 2019 Crypto Asset Amendments

The Payment Services Act side of the reform strengthened the regulatory perimeter around cryptoasset exchange and custody services. FSA materials describe the act as requiring, in principle, reliable custody methods such as cold wallets for customer cryptoassets, while requiring providers to hold same-kind and same-volume performance-guarantee cryptoassets when customer assets are managed by other methods. The act also extended relevant exchange-service rules to businesses that only manage cryptoassets for others.

• Cryptoasset terminology: the act changed statutory references from “virtual currency” to “cryptoasset,” aligning Japanese legislation with the terminology used in international policy discussions.
• Registration and custody: cryptoasset exchange services remained subject to registration, while custody-only business was brought into the cryptoasset exchange service framework.
• User protection: the amendments added advertising and solicitation controls, customer-information measures, asset segregation, periodic audit requirements, and a priority-right concept for returning managed cryptoassets in an exchange-provider insolvency.
• Tokenized investment rights: the FIEA amendments clarified treatment of electronically recorded transferable rights and token offerings that carry rights to profit distributions.
• Derivatives and market conduct: cryptoasset derivatives and certain cryptoasset-related transactions became subject to FIEA-style conduct rules, including restrictions on misleading representations, wrongful acts, rumor spreading, fraudulent means, intimidation, and market manipulation.

For cryptoasset exchange service providers, the amendments made the regulatory model more operationally specific. The consolidated Payment Services Act now provides that no person may provide a cryptoasset exchange service unless registered by the Prime Minister. It also requires prescribed information in registration applications, advance notice for specified changes, advertising disclosures, customer-protection measures, separate management of user money and cryptoassets, and performance-guarantee cryptoassets for certain managed assets.

The practical effect is that Act No. 28 should be linked with Japan's broader cryptoasset exchange regime, including FSA registration supervision and the role of certified self-regulatory associations. It is especially relevant to custody, exchange listing-change notifications, wallet-risk controls, and customer-asset return mechanics.

The FIEA side of the act addressed cryptoasset margin trading, cryptoasset-related derivatives, and investment-style token offerings. FSA explanatory materials state that rules were developed for cryptoasset margin transactions similar to foreign-exchange margin trading, and that tokens with rights to profit distributions would be clarified as subject to financial instruments regulation, including issuer disclosure and sales or solicitation rules.

The consolidated FIEA also includes a chapter on cryptoasset transaction rules. Those provisions prohibit wrongful acts, rumor spreading, fraudulent means, intimidation, and market manipulation in transactions of cryptoassets and cryptoasset-related derivatives. As a result, Act No. 28 is important not only for licensing and custody, but also for market integrity and securities-style treatment of some tokenized rights.

As of July 21, 2026, this profile treats Act No. 28 of 2019 as in force, with later amendments to Japan's PSA and FIEA requiring separate review when describing the current Japanese crypto regime as a whole.