There are no restrictions on who can issue a prepaid payment instrument for their own business. However, as with a prepaid payment instrument for third-party business, a foreign corporation may not solicit persons in Japan for the acquisition of a prepaid payment instrument issued outside Japan. Notifications to Local Financial Bureau It is required to submit a notification to the Director-General of the Local Finance (Branch) Bureau if, after the start of issuance of prepaid payment instruments for their own business, the unused balance as of the record date (March 31 and September 30 each year) exceeds a certain amount (currently 10 million yen) (Article 5 of PSA). Unlike a prepaid payment instrument for a third-party business, there is no application screening process, but if there is anything inappropriate about the content or manner of the issuing business, it may be requested to make changes. Therefore, it is still necessary to ensure compliance with the requirements under PSA. A foreign corporation that wishes to submit a notification must have a place of business or office in Japan and should submit the notification to the Director-General of the Local Finance (Branch) Bureau with jurisdiction over its principal place of business in Japan. In order to issue a prepaid payment instrument for a third-party business, a business must register with the Director-General of the relevant Local Finance (Branch) Bureau (Article 7 of PSA). The applicant must be a Japanese stock company, limited liability company (Godo Kaisha), or other corporation, or a foreign corporation which has a place of business or office in Japan (Article 10(1)(i) of PSA). A foreign corporation that wishes to register as an issuer of a prepaid payment instrument for third-party business under PSA should do so with the Director-General of the Local Finance (Branch) Bureau with jurisdiction over its principal place of business in Japan. A foreign corporation may not solicit persons in Japan for the acquisition of a prepaid payment instrument issued outside Japan (Article 36 of PSA). The amended PSA, which is scheduled to come into force in 2023, requires notification of a business implementation plan stating statutorily required matters in the case of issuing a "large-amount electronically transferable prepaid payment instrument" (Article 3-(8) of the amended PSA) which enables topping-up and transfers in large amounts (Article 11-2(1) of the amended PSA). Outline of registration procedures The statutorily required application form, with the necessary documents attached is submitted to the Director-General of the Local Finance (Branch) Bureau. The application will be reviewed, and registration as an issuer of a prepaid payment instrument for third-party business will be granted unless there are grounds to refuse registration, or there is a material false statement or material omission in the application form or the attached documents (Article 9(1) of PSA). b. Prepaid Payment Instruments for Own Business c. Prepaid Payment Instruments for Third-Party Business 61
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