Detailed Information About the Payment Services Act

Cashless law Q&A

Q. What is the Payment Services Act?

A. It is a set of rules for making e-money, remittance services, and similar services safer and more convenient to use

• This is the Japanese law officially titled the Act on Payment Services.
• It sets rules so that services related to payment services, such as e-money and remittance services, can be used more safely and conveniently.
• Depending on the type of service, several categories are defined, such as Prepaid Payment Instruments and fund transfer services.

Q. What kind of e-money can be created with Pokepay?

A. It is a Prepaid Payment Instrument

• A Prepaid Payment Instrument is a payment method where money is paid in advance and then used for settlement when purchasing products or services.
• Well-known examples include prepaid cards and transit e-money.
• Charged Balance issued through Pokepay is charged in advance and used for settlement when purchasing products or services, so it falls under Prepaid Payment Instruments.

Q. What rules need to be followed for Prepaid Payment Instruments?

A. If the Payment Services Act applies, you need to follow its rules

• Whether the Payment Services Act applies depends on the e-money specifications and usage status.
• First, use the following to check whether it applies.

Chart: Check Whether the Payment Services Act Applies ▼

(Tap the image to enlarge)

Q. What are the specific rules?

A. If the Payment Services Act applies, the following administrative procedures are required.

• If the chart above indicates “third-party type”
  • Administrative procedures are required as a third-party type Prepaid Payment Instrument.
    • Notification to the Director-General of the Local Finance Bureau before service launch is required.
    • Depositing an issuance security deposit may be required.
• If the chart above indicates “self-issued type”
  • Administrative procedures are required as a self-issued type Prepaid Payment Instrument.
    • Notification to the Director-General of the Local Finance Bureau is required.
    • Depositing an issuance security deposit may be required.

✅ In the following case, the chapter on Prepaid Payment Instruments under the Payment Services Act does not apply. Administrative procedures under that chapter are not required.

• The expiration date of the e-money is less than six months

✅ In the following case, administrative procedures related to Prepaid Payment Instruments are not required.

• As of the reference date*, the combined unused balance of all members does not exceed JPY 10 million for self-issued e-money
  • *Twice a year: the end of March and the end of September

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Frequently Asked Questions

Q. Does Pokepay support third-party type e-money issuance?

A. Pokepay for Shops does not support it

As of July 2025, Pokepay for Shops, which is available for broad use, does not support third-party type e-money issuance.

Regardless of whether the Payment Services Act applies, you can issue e-money as self-issued e-money.

If you are considering issuing third-party type e-money, consider contacting Pokepay Enterprise.

Q. Are there any exceptions?

A. There are exceptions such as the following

ℹ️ The Payment Services Act does not apply in the following cases.

• The issuer is a special entity such as a local public body.
  • Example: You are a city office staff member and want to create “City Pay” for use within the local area.
• Other exclusion grounds apply.
  • Example: You want to create “Company Cafeteria Pay” for use in Company X’s cafeteria.

Q. Can refunds be provided?

A. As a general rule, refunds cannot be provided

• For Prepaid Payment Instruments, Refunds are generally prohibited.
• This is because, under Japanese law, entities other than banks cannot accept deposits.
• Charged Balance issued through Pokepay also falls under Prepaid Payment Instruments.
• Therefore, balance charged by members cannot be refunded in cash.

ℹ️ However, there are exceptions such as the following.

• When discontinuing the business
• When the refund amount is small
• When there are unavoidable circumstances for the user, such as moving or relocating overseas

Q. I want to learn more about “self-issued type”

A. For example, e-money used only at your own shops falls under this category

• A Prepaid Payment Instrument that is issued by “yourself or a closely related person” and can be used to purchase products or services is called a self-issued Prepaid Payment Instrument.
• For example, e-money used only at your own shops falls under this category. Franchises and similar arrangements do not fall under it.
• Common examples include services that can be used at specific shops, such as a cafe’s or gas station’s own prepaid card.
• Closely related persons include the following.
  • Corporation: holds more than 50% of voting rights, whether directly or indirectly
  • Individual: relatives, generally within the third degree of kinship
• For details, check the website of the Japan Payment Services Association.

s-kessai.jp

Q. I want to learn more about “third-party type”

A. For example, e-money that can be used broadly, including at other companies, falls under this category

• A service that can be used broadly, including not only at your own company but also at other companies, is called a third-party type Prepaid Payment Instrument.
• Common examples include transit e-money and various QR code payment services that can be used broadly in many places.
• Because the number of users and shops tends to increase, and the transaction volume also tends to increase, several rules apply.
• Specific rules include the following.
  • Only corporations can issue it.
  • Notification to an administrative agency
  • Accumulation of a security deposit
  • Preparation and display of terms regarding Refund procedures if the e-money service ends
    • …and others
• Because the scale becomes larger and the number of users increases, coordination with administrative agencies is important.
• If you are considering issuance, first contact your nearest administrative agency.

Reference: Kanto Local Finance Bureau, Ministry of Finance: List of third-party type Prepaid Payment Instrument issuers

lfb.mof.go.jp

More Detailed Information

For more detailed or latest information, contact the nearest Local Finance Bureau or other administrative agency desk, or check the website of the supervisory ministry or agency.

Financial Services Agency website

fsa.go.jp