This 5th entry in the series "FIBO Managers Beware" by Japan Asset Management Platform Group (JAMP) covers a change in submission method from paper to digital for certain notifications and reports.

FIBOs (financial instruments business operators) are required to file a variety of notifications and reports.  Notable examples include a registration of change (Article 31, Financial Instruments and Exchange Act) regarding changes in officers and other personnel, and accident notifications in cases of “problematic conduct, etc.” (Article 199, Paragraph 1, Items 7 and 8 of the Cabinet Office Order on Financial Instruments Business, etc.).  In order to improve operational efficiency and in response to Covid concerns, a recent directive announced that future filings will be made electronically.

On June 21, 2021, the Securities Supervision Division 2 of the Kanto Local Finance Bureau notified FIBOs under its jurisdiction that applications and notices must now be filed digitally and that paper transactions would be discontinued.*  Starting in October, for example, the bureau will no longer provide stamped duplicates of paper submissions as proof of receipt, regardless whether the original was filed on paper.  Paper documents may still be accepted in some instances, but FIBOs must now submit documents via the FSA (Financial Services Agency) Electronic Application and Notification System using a gBizID, a new electronic system which became available this spring.  The current wait for a gBizID is about three weeks, so FIBOs without one are advised to apply as soon as possible.  For more information, please refer to this link:

Annual business report filings are unaffected and will continue to be submitted via the "Integrated System for Business Support of the FSA”.


* FIBOs were notified in an e-mail:  Notice “Regarding the Operation of the FSA Electronic Application and Notification System”, with attached documents “Start of the Use of the FSA Electronic Application and Notification System and Termination of Applications and Notifications by E-mail” and “Termination of the Handling of Applications, Notifications, and Return of Copies of Business Reports”.