If the unused balance of prepaid payment instruments exceeds 10 million yen as of March 31, you must file a report with the Financial Services Agency!

To all companies that issue points when users make in-app purchases in games and other apps: March 31, the reporting deadline for the unused balance of prepaid payment instruments, has arrived. If the unused balance of points (total issued minus total redeemed) exceeds 10 million yen, you are required to submit a notification of issuance of prepaid payment instruments to your local Regional Finance Bureau. Our firm has extensive experience handling notifications of issuance of prepaid payment instruments (in-house type). In addition to issuance notifications, we also handle the preparation and submission of business reports and change notification forms, so please feel free to contact us for a consultation.

Issuance Notification：3,000$

Business Report：500$

Notifiation of Change：500$ (Excl. Tax)

The fee may seem a bit high at first glance, but there is a good reason for it. Not only is gathering the necessary documents a daunting task, but communicating with the Bureau of Finance also requires a significant amount of time and effort. From the time you submit your application until the review is complete, the process generally takes six to nine months. During this period, you must maintain frequent contact with the Bureau of Finance, and if your company handles this internally, there is a risk that other business operations could fall behind. We recommend leaving the tedious work to the experts so that you can focus on your day-to-day operations.

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Introduction of Attorney

Tomoharu Ogawa

Attorney at Law (California) / Certified Administrative Procedures Legal Specialist in Japan

Work Experience:

November 2025: President & CEO, TomOgawa Law Corporation

October 2019: Established OGAWA GYOSEISHOSHI JIMUSHO

September 2016: Joined OPTIMUS GROUP Co., Ltd.

April 2008: Joined Sumitomo Real Estate Sales Co., Ltd.

EDUCATION:

Temple University Law School, Beasley School of Law (August 2022)

Keio University Faculty of Law (March 2008)

CREDENTIALS:

Attorney at Law (California)

Certified Administrative Procedures Legal Specialist (Japan)

Issuance notification

1. What is a prepaid payment method (self-issued)?

(1) The issuer issues gift certificates, prepaid cards, IC cards, points on the app, etc. (hereinafter referred to as "Issuances"),

(2) The customer pays the issuer the consideration for the issue in advance;

(3) When the customer uses the publication,

(4) The issuer provides its own products and services.

refers to the issuance of publications in cases where

2. What is the unused balance on the base date?

(1) What is the reference date?

Refers to March 31st and September 30th of each year.

(2) What is the unused balance on the base date?

The remaining amount after subtracting the amount used by the customer up to the reference date from the amount issued by the issuer of the prepaid payment instrument up to the reference date.

3. Necessity of notification

If the unused balance on the record date in 2(2) exceeds 10 million yen, submit the issuance notification form for the prepaid payment instrument to the issuer's principal office or business office within two months* from the record date. It is necessary to submit it to each financial (branch) bureau.

*If the reference date is March 31st, it will be until May 31st, and if it is September 30th, it will be until November 30th.

4. Notification matters/attached documents

When filing a notification for in-house issuance,Attached form No. 1” and submit it along with the attached documents.

(1) Notification matters

①Name, trade name or name, and address

②For corporations, the amount of capital or investment

③Name and location of the office/office that issues prepaid payment instruments

④In the case of a corporation, the name of the representative

⑤ Unused balance on the relevant record date

⑥ Type, name, etc. of prepaid payment method

⑦ Contents of issuance of prepaid payment instruments

⑧ If part of the work of issuing prepaid payment instruments is outsourced to a third party, the details of the outsourcing and the name and address of the outsourcing company.

⑨Location and contact information of the office or office that responds to complaints or consultations

⑩ Names, locations, and relationships of closely related parties

⑪ Types of other businesses

⑫Name of the certified payment service provider association to join

(2) Attached documents

①Residency card if you are an individual

②For corporations, articles of incorporation (copy) or certificate of all historical matters

③In the case of a corporation, the resident card of the representative

④For corporations, the most recent balance sheet and income statement

⑤If the company is a corporation and has an accounting auditor, the accounting audit report for the most recent business year.

⑥ If part of the issuance of prepaid payment instruments is outsourced to a third party, a copy of the outsourcing contract.

⑦If there is a closely related person, a copy of the family register, shareholder list, securities report, or other documents proving the close relationship as prescribed in Article 3, Paragraph 1 of the Ordinance.

⑧Document containing other reference information

Notification of Change

1. when there is a change in the notified items

When there is a change in the matters notified in the issuance notification of prepaid means of payment (self-issuance), a "Notification of Change" prepared in accordance with "Appendix Form No. 2" must be submitted without delay together with the relevant side of the "Appendix Form No. 1" (for replacement by the Finance Bureau) of the issuance notification after the change and the attached documents listed in 2. below. In the case of a notification of change of matters other than those described in 2. below, the attached documents are not required.

Matters subject to notification of change and attached documents

(1) Name, trade name or corporate name

Attached document: In the case of a corporation, a certificate of registered matters stating the matters pertaining to the change

(2) Change in the amount of capital or investment

Attached document: Certificate of registered matters stating the matters pertaining to such change or any document in lieu thereof

(3) Establishment, change of location, or abolition of a business office or office

Attached document: In the case of a corporation, a certificate of registered matters stating the matters pertaining to said change

(4) Change of representative

Attached documents: Certificate of registered matters stating the new representative and the representative's certificate of residence

(5) Change in the type, name and amount payable, etc. of the prepaid means of payment

(6) When there is a period or a time limit within which the payment may be used to pay for the purchase or lease of goods or the provision of services, or within which the payment may be requested for the delivery of goods or the provision of services, said period or time limit

(7) Changes in the contents and methods of the business of issuing prepaid means of payment

(8) Changes in the location and contact information of the business office or office that responds to complaints or consultations from users concerning the issuance and use of prepaid means of payment

(Attachments to (5)-(8): A document stating matters of reference pertaining to said changes

(9) When a part of the business of issuing prepaid means of payment is entrusted to a third party, a description of the business pertaining to such entrustment and the name or trade name and address of such entrusted party

Attached document: Contract document pertaining to such entrustment

(10) Change in the closely related person or the close relationship prescribed in Article 3, paragraph (1) of the Order with such person

Attached document: a copy of the family register, list of shareholders, securities report or other document certifying the close relationship as prescribed in Article 3, Paragraph 1 of the Enforcement Order after such change

(11) Change in business conducted elsewhere

Attached document: Certificate of registered matters or a document in lieu thereof that describes the matters pertaining to such change

(12) Joining or withdrawing from an association of certified fund settlement service providers

Attached document: A document that can confirm the fact that the applicant has joined or withdrawn from an approved fund settlement operators association.