An applicant applying for a license, authorization or registration in Japan must undergo a formal process. This involves the completion of required application forms and the submission of supporting information.

In relation to timing, each regulation has a specified standard processing period (depending on the case, typically between two weeks and four months).  However, this period does not include the time necessary for pre-application consultation with the regulator, amendment of the application to reflect the regulator’s concerns, response to the regulator’s questions, and/or the submission of additional material for further explanation.

In practice, it often takes six months to one-and-a-half years to obtain a financial services business license after the start of the pre-application consultation process.

Furthermore, for certain licenses, the applicable laws provide for a formal preliminary examination procedure that an applicant may use, on a voluntary basis, to assess whether it can obtain the license.

The particular forms and annexes must be completed for submission to the regulator, depending on the applicable laws and the type of regulated activity to be conducted. However, broadly speaking, the following items should be included:

• The application form containing basic information regarding the applicant and its business
• The articles of incorporation and other constitutional documents of the applicant
• An explanation of its corporate governance features
• All relevant internal rules
• Financial statements
• Résumés of the members of senior management (including their respective track records and capabilities)
• Details of major shareholders and corporate groups
• Certain undertakings, and representations and warranties

The above procedures apply both to traditional banking and financial services and to innovative services such as fintech. In case it is not clear whether or which license is required, the Fintech Support Desk of the JFSA mentioned in Question & Answer 1 can be a contact point for inquiries relating to fintech matters.

Furthermore, Japan has introduced a "Regulatory Sandbox" system for businesses to experiment with their new business models that use cutting-edge technologies under the supervision and support of regulators. This system allows businesses to demonstrate new technologies even when it is difficult to start such a business under the existing law. As of the end of December 2023, 31 projects have been approved under the system, including several fintech cases.