SAKURA Law Office | Legal Update by Managing Partner Kenshiro Michishita

September 30, 2026 (fully revised October 2, 2026; corrected October 16, 2026)

SAKURA Law Office | Kenshiro Michishita, Managing Partner

SAKURA Law Office has fully revised the twenty-seventh edition of the Legal Update series by Managing Partner Kenshiro Michishita, entitled “Japan’s 2026 Crypto-Asset Regulatory Reform — Transition to the FIEA, Issuer Disclosure, Investment Advice and Management, Insider Trading and Web3 Transition Planning.”

Japan’s 2026 crypto-asset reform is best understood as a regulatory transition rather than an overnight replacement of one statute with another. A new Electronic Payment Instruments / Cryptoassets Service Intermediary Business regime took effect under the Payment Services Act on June 1, 2026. Separately, the Diet enacted the Act Partially Amending the Financial Instruments and Exchange Act and the Payment Services Act on July 15, 2026, and the Act was promulgated on July 23. The enacted legislation will move the core regulation of crypto-asset transactions from the Payment Services Act to the Financial Instruments and Exchange Act. As of October 2, 2026, however, the principal crypto-asset provisions of that reform are not yet in force. Businesses must therefore comply with the current Payment Services Act regime while designing their future operating model for the enacted FIEA framework.

The reform should not be described as turning Bitcoin, Ether or all other crypto-assets into “securities.” The Financial Services Agency has expressly described the new architecture as treating crypto-assets as financial instruments distinct from securities under the FIEA, with rules calibrated to their characteristics. The result is a broader financial-regulatory framework covering issuer and product disclosure, crypto-asset transaction businesses, investment advice and investment management, borrowing and related services, intermediation, critical system providers, insider trading and stronger enforcement.

Legal classification remains the first question. A fiat-linked stablecoin may be an Electronic Payment Instrument regulated under the Payment Services Act; a security token may already constitute a security under the FIEA; and an NFT may fall outside both categories or enter a regulated category depending on its rights and economic function. Technology does not determine the legal result. The analysis begins with the holder’s rights, the issuer and redemption structure, transferability, custody model, investment characteristics, marketing and actual transaction flow.

This fully revised Legal Update therefore focuses on the transition architecture as of October 2, 2026: what remains governed by current law, what became effective in June and August 2026, what has been enacted but remains pending commencement, and how exchanges, Web3 companies, banks, investors, venture funds, technology providers and General Counsel should organize the implementation programme.

Executive Summary

Under current law, spot crypto-asset trading remains centered on the Cryptoasset Exchange Service Provider registration framework under the Payment Services Act. The regulatory perimeter extends beyond operating an exchange: purchase and sale, exchange, intermediation or agency, certain related handling of customer funds and management of crypto-assets for another person can each require analysis. Since June 1, 2026, a narrower intermediary registration has been available where a business acts solely as an intermediary on behalf of an affiliated registered provider and does not take custody of customer assets.

The enacted 2026 FIEA reform will move crypto-asset transaction regulation into the FIEA while keeping crypto-assets legally distinct from securities. It establishes statutory information-publication regimes for certain issuer-based crypto-assets and for crypto-assets handled by regulated transaction businesses. FSA materials also contemplate investment caps for specified offerings where the issuer has not undergone the contemplated financial audit; the detailed thresholds and other implementing conditions remain matters for subordinate legislation and should not be treated as final rules already in force.

The future framework reaches well beyond exchange execution. Crypto-asset investment advice and investment management will be brought into the relevant FIEA business categories; customer crypto borrowing will be regulated; intermediation will connect to the Financial Instruments Intermediary Business framework; and providers of critical systems used for custody will enter the regulatory perimeter. The reform therefore requires a functional review of wallets, custody, lending, staking, advisory apps, portfolio services, market infrastructure and key-management vendors rather than a simple licence conversion.

Market-integrity rules will also change materially. Existing FIEA prohibitions can already apply to fraudulent conduct and market manipulation involving crypto-assets, but the amended statute adds a dedicated crypto-asset insider-trading regime, including restrictions on pre-publication trading, information transmission and trading recommendations by specified insiders and information recipients. Web3 organisations should begin designing insider lists, personal-dealing controls and controlled communication channels before commencement.

The transition is already being shaped by current operational measures. The FSA finalized its crypto-asset cybersecurity policy in April 2026; the industry self-regulatory body introduced system-governance rules effective July 1; Travel Rule coverage expanded on August 3; the FSA and National Police Agency requested stronger fraud-prevention controls in August; and cyber-incident reporting guidance was updated with effect from October 1. A credible transition programme must therefore combine future FIEA readiness with present-day cybersecurity, AML/CFT, fraud, outsourcing and incident-response obligations.

1. The Reform Is a Staged Transition, Not an Immediate Replacement of the Payment Services Act

The distinction between enactment and commencement is central. Act No. 64 of 2026 was enacted on July 15 and promulgated on July 23. The principal provisions that transfer crypto-asset transaction regulation to the FIEA, create the new disclosure framework and introduce crypto-asset insider trading are subject to a commencement date to be specified by Cabinet Order within one year from promulgation, as provided in the Supplementary Provisions. Certain provisions did take effect on August 12, including stronger penalties for unregistered financial instruments business and additional criminal-investigation authority for the Securities and Exchange Surveillance Commission, but those partial commencements did not move the entire crypto-asset regime into the FIEA.

For a business operating today, legal analysis therefore has two timelines. The first asks whether the existing service complies with the Payment Services Act, the currently effective FIEA provisions, AML/CFT law and current supervisory requirements. The second asks whether the same legal entity, product, customer flow, outsourcing structure and revenue model will remain viable once the enacted FIEA framework commences. Registration under the current regime should not be assumed to grandfather every business line, product or control into the future framework.

A practical transition register should identify, for each material business function, the current legal basis, the enacted future legal basis and the matters that remain dependent on Cabinet Orders, Cabinet Office Ordinances, supervisory guidance or self-regulatory rules. FSA explanatory materials contain important implementation intentions—including future details on investor limits, eligible crypto-assets, capital and reserve requirements and large-scale trading thresholds—but those intended details must be distinguished from final subordinate legislation.

2. Classification Comes Before Licensing: Crypto-Assets, Stablecoins, Security Tokens and NFTs Remain Different Legal Products

Using a blockchain does not create a single “digital asset” regulatory category in Japan. The classification turns on the substantive rights and economic function of the token: whether it is denominated in or redeemable for fiat currency, whether a holder has a claim against an issuer, whether it represents a security or investment interest, whether it can be used as a broadly transferable means of payment, and what rights arise upon ownership or transfer.

Certain fiat-linked stablecoins are regulated as Electronic Payment Instruments under the Payment Services Act rather than as crypto-assets. The Payment Services Act amendments effective June 1, 2026 also changed aspects of the legal infrastructure for trust-type Electronic Payment Instruments, including permissible management of specified backing assets and treatment of certain foreign trust beneficiary interests. Security tokens, by contrast, can already constitute securities under the FIEA, including Electronically Recorded Transferable Rights where the statutory conditions are met. Those rules are separate from the 2026 migration of crypto-asset regulation.

“NFT” is likewise a technological label rather than a statutory safe harbour. A scarce digital art token or in-game item may fall outside the crypto-asset and securities regimes, while a token designed for payment, fungible economic use, profit participation or broad investment trading may require a different analysis. A reliable classification opinion should reconcile the legal documents with smart-contract functionality, supply, redemption, marketing, trading venues and the rights actually exercised by holders.

3. Under Current Law, the Regulatory Perimeter Must Be Mapped by Function Rather Than Product Branding

As of October 2, 2026, the Payment Services Act remains the principal statute for spot crypto-asset exchange services. The current perimeter can capture the purchase and sale of crypto-assets, exchange between crypto-assets, intermediation, agency or brokerage, specified handling of customer money connected with those transactions, and management of crypto-assets for another person. A wallet, OTC desk, matching service, API, payment interface or custody product can therefore require registration analysis even if the business does not call itself an exchange.

Non-custodial design should be tested by control rather than branding. Key shards, multi-party computation arrangements, recovery credentials, whitelisting controls, smart-contract privileges and transaction-approval rights may determine whether the provider can in substance cause or prevent a transfer. The same functional approach applies to the boundary between technology or information provision and regulated intermediation. Interface design, recommendation logic, compensation, order transmission and the contractual relationship with the user and execution provider can be more important than the name given to the service.

The Electronic Payment Instruments / Cryptoassets Service Intermediary Business regime introduced on June 1, 2026 provides a narrower route for a person entrusted by an affiliated Cryptoasset Exchange Service Provider or Electronic Payment Instruments Service Provider to conduct only specified intermediation without holding customer assets. It is not a universal substitute for full registration. A business that becomes principal, receives customer assets, exercises broader execution authority or independently sets material transaction terms may fall outside the limited model. Because the enacted FIEA reform will bring crypto-asset intermediation into the Financial Instruments Intermediary Business framework, businesses entering through the current intermediary route should also plan for the next migration.

4. The Future FIEA Framework Expands the Regulatory Unit from “Exchange” to Product Governance, Advice, Management, Borrowing and Critical Systems

The enacted framework is not simply a change of statutory citation for existing exchanges. FSA materials describe a regime broadly comparable to Type I Financial Instruments Business for crypto-asset transaction businesses, while preserving crypto-specific safeguards such as cold-wallet management. The framework also contemplates standards for eligible crypto-assets, product review, business-management systems, customer suitability, transaction surveillance, outsourcing oversight and financial soundness. An existing Type I Financial Instruments Business Operator that enters crypto-asset transaction business is expected to require an appropriate change to its registration rather than relying on its existing securities permission alone.

Investment advice and investment management involving crypto-assets will become express regulated activities under the relevant FIEA categories. Discretionary mandates, portfolio management, model portfolios, robo-advice, paid signals and recommendation services should therefore be reviewed according to what the provider actually does: who makes the investment decision, whether discretion over positions exists, how the customer contracts, and how compensation is earned. Delivery through software, a chat group or a smart contract does not by itself remove the regulated function.

Customer crypto borrowing is also brought into the crypto-asset transaction business framework. That matters for lending and yield products and for some staking structures. Protocol-level staking of a firm’s own assets is legally different from accepting or borrowing customer crypto, deploying it and assuming a repayment obligation. The latter raises custody, credit, insolvency and disclosure risks that justify separate treatment. In parallel, providers that continuously supply critical systems used to manage customer crypto-assets—including key-management or custody infrastructure—will face a more direct regulatory role, requiring vendor agreements to address audit rights, security standards, incident cooperation, subcontracting and continuity.

5. Token Issuance and Listing Move from White-Paper Review Toward Statutory Disclosure and Documented Due Diligence

For specified crypto-assets with identifiable issuers, the amended FIEA establishes an information-publication regime for public offerings and sales. FSA materials identify issuer identity and financial information, business information and core product matters such as the crypto-asset’s nature, function, supply and underlying technology as examples of information to be made available. Ongoing disclosure is also contemplated through periodic information and event-driven information, with a mechanism under which continuing issuer disclosure may cease in specified decentralization circumstances and the information-publication role shifts to the regulated transaction business.

The future regime should not be summarized as imposing a securities prospectus on every token. The legal responsibility for disclosure differs depending on whether an issuer conducts fundraising or whether a transaction business independently begins handling a crypto-asset without issuer-led fundraising. FSA materials also identify exclusions for certain limited distributions, professional-investor solicitations, free distributions and mining rewards. Where the issuer has not undergone the contemplated financial audit, the FSA has indicated that investor limits will apply in specified offerings; the detailed thresholds and conditions remain to be prescribed in subordinate legislation.

For IEOs and new listings, this means legal, financial and technical diligence should become a single controlled process. Corporate and financial diligence, tokenomics, supply and lock-ups, related parties, intellectual property, smart-contract permissions, use of proceeds, governance, market-making, custody and cybersecurity should be reconciled with the statutory information and public communications. The amended framework introduces civil, criminal and administrative monetary-penalty consequences for false or misleading disclosures. A white paper, website, social-media campaign, technical documentation and code base that tell different stories will become a direct legal exposure rather than merely a communications weakness.

6. Market Integrity Will Extend from Existing Manipulation Rules to a Dedicated Crypto-Asset Insider-Trading Regime

Japan’s current FIEA already contains prohibitions capable of applying to fraudulent means, false rumours and market manipulation involving crypto-assets. What has been missing is a dedicated statutory insider-trading prohibition for crypto-assets. The amended FIEA fills that gap for crypto-assets handled by domestic regulated transaction businesses, using a framework modeled on listed-securities insider trading but tailored to crypto markets.

FSA explanatory materials contemplate important facts relating to issuers, crypto-asset transaction businesses and large-scale traders, supplemented by a catch-all provision. Examples include specified issuer events, commencement or discontinuation of handling by a transaction business and plans for large-scale trading. The regulated persons include insiders connected with those categories and recipients of the information. The reform also restricts specified pre-publication information transmission and trading recommendations made for the purpose of enabling another person to make a profit or avoid a loss.

This will require Web3 organisations to formalize information governance that is often dispersed across Discord, Telegram, Slack, GitHub, developer channels, market-maker communications and venture-investor updates. Insider lists, access controls, personal trading, wallet and exchange-account declarations, publication timestamps and no-recommendation rules should extend beyond senior management. The same governance should capture compensated public promotion. The amended FIEA introduces a transparency requirement where specified persons receive consideration from issuers or regulated businesses and publicly express transaction-relevant views, making influencer, KOL, affiliate and ambassador arrangements a compliance and conflicts issue as well as a marketing contract. The contracts and approval process should cover the form of compensation, token allocations, lock-ups, personal dealing and access to non-public information. Making those relationships visible before commencement also assists current advertising, solicitation and reputational controls.

7. Cybersecurity, AML/CFT and Fraud Controls Are the Operational Core of the Transition

The credibility of Japan’s crypto-asset regime depends less on obtaining a licence than on preventing the loss or criminal misuse of customer assets. In April 2026, the FSA finalized its Policy Approaches to Strengthen Cybersecurity for Cryptoasset Exchange Services, emphasizing governance across firms, industry bodies and public authorities. JVCEA, Japan’s self-regulatory association for cryptoasset and related businesses, subsequently implemented system-governance rules and guidelines effective July 1, 2026. The enacted FIEA reform also contemplates liability reserves, capital requirements and regulation of critical custody-system providers, directly linking cyber risk to prudential and outsourcing governance.

Current operational expectations have also tightened. In August 2026, the FSA and National Police Agency requested stronger fraud-prevention measures, including controls at account opening, temporary withdrawal restrictions after fiat deposits or crypto purchases, pre-registration of withdrawal destinations, withdrawal limits, transaction and access-environment monitoring, enhanced authentication, rapid restriction or freezing after suspicious activity, name matching and stronger information sharing with the police. The Travel Rule was also expanded to additional foreign jurisdictions with effect from August 3, 2026. Technical transferability on-chain is therefore not the same as regulatory permission to transfer.

From October 1, 2026, amendments to supervisory guidelines and administrative guidance also reflect the move to common government reporting forms for cyber incidents, including for crypto-asset exchange service providers, Electronic Payment Instruments service providers and the new intermediary businesses. Incident response should therefore be designed as a legal timeline covering technical containment, regulatory notification, personal-data reporting where relevant, customer communications, asset restrictions, blockchain tracing, police coordination and public statements.

Cross-border market entry belongs in the same operational programme. An offshore licence does not authorize active service to Japanese residents where Japanese registration is required. The FSA continues to issue warnings to unregistered overseas crypto platforms, including a warning in September 2026. A global group should map Japanese-language interfaces, local advertising, affiliates, customer support, yen rails, contracting entities, custody and data flows together with the current and future licensing perimeter. The objective is not a Japan-only compliance appendix, but a single governance model capable of operating through the transition.

Frequently Asked Questions

Q1. Has Japan already transferred crypto-asset regulation from the Payment Services Act to the FIEA?

No. The reform has been enacted and promulgated, but the principal crypto-asset provisions remain pending commencement as of October 2, 2026. Current businesses must continue to comply with the Payment Services Act while preparing for the enacted FIEA framework.

Q2. Will Bitcoin and Ether become securities under the new framework?

Not simply because they will be regulated under the FIEA. The FSA has described crypto-assets as financial instruments distinct from securities. The future rules are tailored to crypto-assets rather than reclassifying all crypto-assets as securities.

Q3. Are stablecoins and security tokens being merged into the same regime?

No. Certain fiat-linked stablecoins remain Electronic Payment Instruments under the Payment Services Act, while security tokens may already be securities under the FIEA. Classification depends on rights, redemption, issuer structure and economic function.

Q4. Will a crypto investment-advice app or paid signal service require registration?

Potentially. The amended FIEA expressly brings crypto-asset investment advice and investment management into the relevant regulated-business categories. The analysis depends on the actual advice, compensation, discretion, customer contract and service flow.

Q5. Will every IEO issuer be required to have audited financial statements?

The reform should not be simplified that way. FSA explanatory materials indicate that specified investor limits will apply where the issuer has not undergone the contemplated financial audit. The detailed thresholds and conditions are to be prescribed by subordinate legislation.

Q6. Are the new crypto insider-trading rules already effective?

No. The dedicated regime has been enacted but the principal provisions are not yet in force as of October 2, 2026. Existing prohibitions on fraudulent conduct and market manipulation can nevertheless already be relevant, and firms should build information and personal-dealing controls before commencement.

Q7. Does an offshore platform need Japanese registration merely because it has a Japanese-language website?

Language alone is not determinative. The analysis considers the overall Japan-facing activity, including solicitation, advertising, affiliates, customer support, yen funding routes, contracting entities and actual services to Japanese residents. A foreign licence does not substitute for Japanese registration.

Q8. Are all staking services regulated in the same way?

No. Staking a firm’s own assets at protocol level differs from accepting or borrowing customer crypto, deploying it for staking or other yield activity and owing repayment. The enacted FIEA specifically brings customer crypto borrowing into the future business-regulation framework.

Q9. Can a token project pay influencers to promote the token?

Payment is not categorically prohibited, but the amended FIEA introduces disclosure of specified compensated relationships where public views relevant to transaction decisions are expressed. Marketing contracts should also address token compensation, personal trading, information access, lock-ups and other conflicts.

Q10. What should a crypto or Web3 business prioritize before commencement?

Map the current legal entities, licences and actual functional flows; classify each digital asset; identify who controls customer assets and keys; and run a gap analysis covering disclosure, product review, advice and management, lending, intermediation, personal trading, marketing, critical vendors, cybersecurity, AML/CFT and fraud controls. The result should be a documented transition plan rather than a one-time legal opinion.

About the Legal Update Series by Kenshiro Michishita

SAKURA Law Office publishes the Legal Update series through the profile of Managing Partner Kenshiro Michishita, addressing major issues in corporate law, M&A, cross-border transactions, international disputes, financial regulation, Web3 and crypto, AI and technology, data protection, intellectual property, corporate crisis management and internal investigations. Legal Updates No. 24 through No. 26 address insider trading, tender offers and large shareholding reporting, and market-integrity regulation. This fully revised No. 27 focuses on the transition from Japan’s current Payment Services Act framework to the enacted FIEA-based crypto-asset regime. Nos. 28 through 30 then provide dedicated treatment of security tokens, stablecoins and the Electronic Payment Instruments / Cryptoassets Service Intermediary Business.

SAKURA Law Office official website — https://sakura-lawyers.jp/en/

Kenshiro Michishita, Managing Partner — Profile — https://sakura-lawyers.jp/en/lawyer/michishita-kenshiro/

How SAKURA Law Office Can Assist

SAKURA Law Office advises Japanese and foreign clients on crypto-asset exchange regulation, Electronic Payment Instruments and stablecoins, the Electronic Payment Instruments / Cryptoassets Service Intermediary Business, security tokens, IEOs and token issuance, Web3 and NFT services, investment advice and investment management, staking and lending, custody, AML/CFT and the Travel Rule, cross-border entry into Japan, FSA and Local Finance Bureau engagement, user terms, outsourcing and technology agreements, marketing, insider-information controls and cyber incidents. For transition projects, we assess both compliance with the law currently in force and the operating, licensing, product and governance changes required by the enacted 2026 FIEA reforms and forthcoming subordinate legislation. In cross-border matters, we coordinate in English with overseas headquarters, foreign counsel, exchanges, financial institutions, investors and technology providers so that Japanese digital-asset requirements are incorporated into the global business model.

Contact

For advice concerning crypto-assets, stablecoins, security tokens, Web3 services or other digital-asset regulation in Japan, please contact SAKURA Law Office.

SAKURA Law Office

4F Ark Hills South Tower, 4-5 Roppongi 1-chome, Minato-ku, Tokyo 106-0032, Japan

Kenshiro Michishita, Managing Partner

Web: https://sakura-lawyers.jp/en/

Principal References

1 Payment Services Act — e-Gov Laws (official Japanese text) https://laws.e-gov.go.jp/law/421AC0000000059

2 Financial Instruments and Exchange Act — e-Gov Laws (official Japanese text) https://laws.e-gov.go.jp/law/323AC0000000025

3 FSA — Bills submitted to the 221st Diet Session: 2026 FIEA / Payment Services Act Amendment https://www.fsa.go.jp/common/diet/221/index.html

4 FSA — Explanatory materials for the 2026 FIEA / Payment Services Act Amendment (Japanese official materials) https://www.fsa.go.jp/common/diet/221/02/03.pdf

5 FSA — Report by the Working Group on Crypto-asset Systems of the Financial System Council (English) https://www.fsa.go.jp/en/refer/councils/singie_kinyu/20260216.html

6. FSA, Access FSA No. 269 (January 2026), Policy Commentary: Outline of the Report of the Financial System Council’s Working Group on Crypto-asset Systems, pp. 19–21 (commentary on the December 2025 report; distinct from the subsequently enacted legislation) — https://www.fsa.go.jp/en/newsletter/accessfsa2026/269.pdf

7 FSA — Cryptoassets / Electronic Payment Instruments portal https://www.fsa.go.jp/policy/virtual_currency02/index.html

8 FSA — Electronic Payment Instruments / Cryptoassets Service Intermediary Business https://www.fsa.go.jp/common/shinsei/denanchuukai/index.html

9 FSA Weekly Review No. 690 — launch of the intermediary regime (English) https://www.fsa.go.jp/en/newsletter/weekly2026/690.html

10 Cabinet Office Ordinance on Electronic Payment Instruments / Cryptoassets Service Intermediary Businesses — e-Gov https://laws.e-gov.go.jp/law/508M60000002050

11 FSA — 2025 Payment Services Act amendment: implementing orders and June 1, 2026 commencement https://www.fsa.go.jp/news/r7/sonota/20260522/20260522.html

12 FSA — Partial enforcement of the 2026 FIEA amendment from August 12, 2026 https://www.fsa.go.jp/news/r8/shouken/20260729/20260729.html

13 FSA — Policy Approaches to Strengthen Cybersecurity for Cryptoasset Exchange Services https://www.fsa.go.jp/news/r7/sonota/20260403/20260403.html

14 FSA — Travel Rule: finalized addition of jurisdictions effective August 3, 2026 (English) https://www.fsa.go.jp/en/news/2026/20260707/20260707.html

15 FSA — Enhanced measures to prevent fraud involving crypto-assets (August 6, 2026, Japanese) https://www.fsa.go.jp/news/r8/sonota/20260806/20260806.html

16 FSA — Revised cyber-incident reporting guidance effective October 1, 2026 (Japanese) https://www.fsa.go.jp/news/r8/sonota/20260918/20260918.html

17 FSA — Comprehensive Guidelines for Supervision of Financial Instruments Business Operators (current) https://www.fsa.go.jp/common/law/guide/kinyushohin/

18 FSA — Registered / supervised crypto-asset materials and forms (Japanese) https://www.fsa.go.jp/common/shinsei/angoshisan.html

19 JVCEA — Rules and Guidelines (Japanese) https://jvcea.or.jp/guidelines/

20 JVCEA — System-governance rules and guidelines for cryptoasset exchange services effective July 1, 2026 (Japanese) https://jvcea.or.jp/information/pc/20260701-002/

21 FSA — 2026 Strategic Priorities (Japanese; English materials available from the page) https://www.fsa.go.jp/news/r8/202609/260915.html

22 SAKURA Law Office — Official Website https://sakura-lawyers.jp/en/

23 SAKURA Law Office — Kenshiro Michishita, Managing Partner https://sakura-lawyers.jp/en/lawyer/michishita-kenshiro/

24. House of Councillors, legislative history and summary of the FIEA / Payment Services Act Amendment Bill, 221st Diet, Cabinet Bill No. 57 (enacted July 15, 2026; promulgated July 23 as Act No. 64) — https://www.sangiin.go.jp/japanese/joho1/kousei/gian/221/meisai/m221080221057.htm

Disclaimer

This article provides general information based on Japanese laws, enacted amendments, official FSA and other public materials and general practice publicly available as of October 2, 2026. It does not constitute legal advice or a legal opinion concerning any specific token, business, solicitation, transaction, registration or regulatory matter. In particular, the principal crypto-asset provisions enacted by Act No. 64 of 2026 have been enacted and promulgated but remain pending commencement as of October 2, 2026, and Cabinet Orders, Cabinet Office Ordinances, public notices, supervisory guidance, self-regulatory rules and transition measures will further determine the detailed implementation. The classification of a crypto-asset, Electronic Payment Instrument, security token, NFT or other digital asset, and the application of registration, disclosure, investment advisory and management, intermediation, borrowing, custody, AML/CFT, market-abuse and other rules, depend on the token design, rights, parties, customers, distribution locations, control of assets and keys, and the actual service structure. Specific matters should be assessed under the laws and official materials in force at the relevant time with appropriate Japanese legal advice.