2025-10-26 — Ian Irizarry
Japan's Banks May Be Cleared to Hold Digital Assets: What Institutions Need to Know
Japan's Financial Services Agency (FSA) is reviewing rules that would allow banks to hold and trade digital assets — including Bitcoin — under defined capital requirements and risk controls. If enacted, the reforms represent a material shift in how Japanese financial institutions can participate in digital asset markets, with implications for institutional capital deployment, custody infrastructure, and programmable asset issuance.
The regulatory shift
Under rules established in 2020, Japanese banks are prohibited from directly holding or investing in digital assets, primarily on grounds of price volatility and balance-sheet risk. Japan May Let Banks Hold Crypto Under New FSA Proposal
The FSA is now reviewing amendments that would permit banks to purchase and hold digital assets, subject to capital adequacy requirements and defined risk-management frameworks designed to contain systemic exposure. Japan May Let Banks Hold Crypto Under New FSA Proposal
The proposed reforms would also allow banking groups to register digital asset exchange subsidiaries and operate trading and custody services — broadening the range of financial institutions that can participate directly in these markets. Japan May Let Banks Hold Crypto Under New FSA Proposal
Implications for the institutional capital landscape
Expanded institutional participation. Bank authorisation to hold digital assets would open balance-sheet capital to direct investment in programmable asset markets — including tokenised funds, structured products, and digital securities.
Improved liquidity conditions for asset issuers. Banks cleared to support digital asset offerings, secondary markets, and collateralised lending against digital assets would reduce the cost of capital for issuers operating in these markets.
Custody and infrastructure demand. Banks entering this space will require robust custody, risk management, and settlement infrastructure. Institutions with existing capabilities in these areas are well positioned to serve as counterparties or service providers.
Regulatory integration reduces issuer risk. As digital assets are brought within standard banking oversight, the regulatory risk premium that funders and investors currently attach to these instruments is likely to compress.
How institutions are already positioning
Nomura Holdings is preparing to apply for a licence to offer digital asset trading services to institutional clients — indicating that major Japanese financial institutions are building capacity in anticipation of regulatory change. Nomura Holdings Preparing to Apply for a Licence to Offer Digital Asset Trading Services
Daiwa Securities Group has begun offering yen-denominated lending against Bitcoin and Ether as collateral, demonstrating existing demand for structured products that incorporate digital assets. Daiwa Securities Group Offering Collateralised Lending Against Digital Assets
MUFG, SMBC, and Mizuho — Japan's three largest banking groups — are jointly developing a yen-pegged stablecoin intended to accelerate and reduce the cost of corporate settlements. Japan Plans to Allow Banks to Trade Bitcoin and Other Digital Assets
What asset managers and issuers should do now
Establish banking-grade governance and risk disclosure
As banks become potential investors and counterparties, they will apply credit and risk standards consistent with prudential regulation. Issuers should ensure risk disclosures, governance frameworks, and custody arrangements meet those standards — not as a future aspiration, but as a present operational baseline.
Align instruments with established legal classification
Instruments that carry their own transfer rules, eligibility conditions, or coupon logic should be structured and documented in alignment with Japan's Financial Instruments and Exchange Act (FIEA) and equivalent frameworks. Early classification certainty reduces execution risk for both issuer and investor. Crypto Regulations in Japan
Engage financial institutions on infrastructure roles
Banks entering digital asset markets will require settlement, custody, audit, and compliance infrastructure. Institutions that can offer these capabilities — or integrate with those that do — are positioned to participate in the first wave of bank-led activity in this market.
Track the legislative timeline
Proposed amendments — including reclassification of digital assets under the FIEA — are expected to take legislative form as early as 2026. The window between regulatory intent and enactment is the appropriate time to structure products, align documentation, and establish counterparty relationships. Japan to Give Crypto Assets Legal Status in Financial Products, Nikkei Says
Risks that warrant monitoring
Balance-sheet volatility. If capital requirements are set at insufficient levels, price movements in held assets could create instability. The adequacy of the FSA's proposed risk controls will be a key variable.
Tax treatment lags regulation. Japan currently taxes gains on digital asset holdings at comparatively high rates. Until tax rules are amended to reflect the new regulatory status of these instruments, the after-tax economics of bank holdings may be constrained. Tax rules may lag regulatory change
Implementation uncertainty. Until legislation is enacted, institutions should treat the proposals as indicative, not operative. Conservative institutions may defer activity until the legal framework is settled.
Key questions
When might these changes take effect? Legislative amendments, including reclassification of digital assets under the FIEA, are expected by early 2026 based on current reporting. Reuters: Japan to Give Crypto Assets Legal Status in Financial Products
Which assets would banks be permitted to hold? Major liquid assets such as Bitcoin and Ether are the most likely initial candidates. Other instruments would likely be assessed individually against liquidity and volatility criteria. Japan May Let Banks Hold Crypto Under New FSA Proposal
Would banks be permitted to distribute digital assets to retail clients? Current proposals suggest retail access would be more restricted in the first instance, with banks likely engaging institutional clients directly or through licensed exchange subsidiaries. Japan Times: FSA Banks Crypto
How does Japan's approach compare internationally? Several global banks — including Standard Chartered — already offer institutional digital asset trading. Other jurisdictions are expanding approved instruments to include exchange-traded products and tokenised securities. Japan's approach is notable for the extent of its legal guardrails, prioritising regulatory integration over speed of access. FT: Global Banks and Digital Assets
The FSA's proposal marks a considered step toward integrating digital assets into Japan's regulated financial system. For asset managers, issuers, and infrastructure providers, the priority now is operational readiness: governance that meets institutional standards, instruments structured within existing legal frameworks, and the counterparty relationships needed to operate at scale when the rules change.