The Financial Services Agency (FSA) of Japan has provided a very rigid structure. The FSA sets a clear direction. If you fail to meet their imperatives, you will not be allowed to proceed with your blockchain development solution. Let's dissect the steps necessary to prepare yourself for a compliant launch.

The first step is obtaining the vital licenses. If your offering will access customer funds (including stablecoin custody), Payment Services Act registration is a must-have.

Note

Firms can now access the cryptocurrency market more quickly and efficiently under the 2025 Amendment's "Intermediary" category by teaming up with a licensed custodian rather than seeking full licensure to operate as a regulated exchange.

If you deal with the trading of crypto derivatives or digital security tokens, you are obliged to have an additional (FIEA) Financial Instruments and Exchange Act License.

The next aspect is custody architecture. Established after the major Coincheck hack ($530M) and validated by the successful return of funds during the collapse of FTX Japan, the legal asset protection framework necessitates the following:

At minimum, 95% of customer assets must be in cold storage
Assets must be segregated and cannot commingle
In the wake of the DMM Bitcoin breach, all organizations need to keep a reserve of operational liabilities that is at least equal to their exposure in terms of hot wallets
Auditors will need to confirm that you have met the new standard.

Then comes reporting. There should be near real-time KYC & transaction monitoring, ongoing JVCEA obligations, and full compliance with Japan’s FATF Travel Rule for VASP‑to‑VASP transfers.

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