Japan FSA promulgates multiple Cabinet Office Orders and

Cresthaven AnalyticsIntelligence Brief

Headline

Japan FSA promulgates multiple Cabinet Office Orders and amends supervisory guidelines across banking, securities, and investment sectors

Executive Summary

Japan's Financial Services Agency (FSA) published Weekly Review No. 704, covering regulatory activity from September 14 through September 25, 2026. The week's output includes several Cabinet Office Orders, amendments to supervisory guidelines for major banks and investment management operators, and a revised inter-ministerial cyberattack reporting framework.

Bottom Line

Major banks subject to FSA supervision operate under a revised cyberattack incident-reporting template set, replacing prior FSA-specific forms with common inter-ministerial forms. Investment management business operators face forthcoming guideline amendments on liquidity risk management for publicly offered investment trusts, based on IOSCO's 2025 revised recommendations.

Key Regulatory Signals

Cyberattack Reporting Forms Standardized Across Agencies: The inter-ministerial agreement on cyberattack damage reporting, originally reached on May 28, 2025, was revised on September 15, 2026. The revision adds a third common reporting form covering cyberattack types beyond DDoS and ransomware. The FSA has amended its Comprehensive Guidelines for Supervision of Major Banks to adopt these common forms in place of its own prior forms. Cresthaven reading: major banks subject to FSA supervision face an updated incident-reporting template set and should verify their internal notification procedures align with the revised common forms.
In-Kind ETF Establishment Rules Amended: A Cabinet Office Order promulgated on September 18, 2026 addresses in-kind ETF constituents where the applicant's ownership exceeds 30%. The order introduces provisions allowing that portion to be established with cash. This change applies to the regulatory framework under the Act on Investment Trusts and Investment Corporations.
Financial Instruments and Exchange Act Digitalization Orders Promulgated: A Cabinet Office Order promulgated on September 16, 2026 accompanies enforcement of two acts amended in 2023, covering digitalization of trial procedures for administrative monetary penalty payment orders under the Financial Instruments and Exchange Act and the Certified Public Accountants Act.
Liquidity Risk Management Guidelines for Investment Trusts to Be Amended: Following IOSCO's May 2025 revised recommendations on liquidity risk management for collective investment schemes, the FSA has published results of a public consultation on draft amendments to its Comprehensive Guidelines for Supervision of Financial Instruments Business Operators. The amendments are intended to encourage investment management business operators to take appropriate measures on liquidity risk management for publicly offered investment trusts.
Digital Corporate Bonds and Foreign Venture Fund Rules Eased: A Cabinet Office Order promulgated on September 15, 2026 amends definitions under the Financial Instruments and Exchange Act on three points: easing solicitation restrictions on digital corporate bonds by group companies of issuers, easing investment management rules for collaboration with foreign venture funds, and designating rights on uncertificated depository receipts as securities.
Financial Statements Regulation Open for Comment: The FSA has opened a public consultation on draft amendments to the regulation governing terminology, forms, and preparation methods of financial statements. Public comments are accepted until 5:00 p.m. Japan Standard Time on October 16, 2026.

Regulatory Delta

The revised inter-ministerial cyberattack reporting framework extends a coordination structure first established in May 2025. The FSA has replaced its own supervisory-guideline forms with the common inter-ministerial set, a structural alignment, not a reversal of prior posture.
The Cabinet Office Order promulgated on September 16, 2026 accompanies the enforcement of the 2023 amendments to the Financial Instruments and Exchange Act and the Act on Book-Entry Transfer of Company Bonds, Shares, etc.
The liquidity risk management guideline amendments align the FSA's supervisory approach with IOSCO's May 2025 revised recommendations, consistent with the FSA's stated participation in international standard-setting bodies.

Materiality Classification

MEDIUM — Multiple promulgated Cabinet Office Orders and supervisory guideline amendments affect FSA-regulated banks, investment management operators, and securities firms, requiring compliance posture review across several concurrent rule changes, though no single item carries a sub-30-day sector-wide effective date triggering the HIGH threshold.

Time Horizon

comment_close — 2026-10-16

Intelligence Outlook

Monitor the FSA for publication of Japanese-language full text and official English translations of the promulgated Cabinet Office Orders, and for finalization of the draft financial statements regulation amendments following the October 16, 2026 comment close.