{"id":139918,"date":"2026-04-22T08:56:14","date_gmt":"2026-04-22T08:56:14","guid":{"rendered":"https:\/\/my.legal500.com\/guides\/?post_type=comparative_guide&#038;p=139918"},"modified":"2026-04-22T08:56:14","modified_gmt":"2026-04-22T08:56:14","slug":"japan-insurance-reinsurance","status":"publish","type":"comparative_guide","link":"https:\/\/my.legal500.com\/guides\/chapter\/japan-insurance-reinsurance\/","title":{"rendered":"Japan: Insurance &amp; Reinsurance"},"content":{"rendered":"","protected":false},"template":"","class_list":["post-139918","comparative_guide","type-comparative_guide","status-publish","hentry","guides-insurance-reinsurance","jurisdictions-japan"],"acf":[],"appp":{"post_list":{"below_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">CHUO SOGO LPC<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2019\/03\/clo_logo-v-En01.png\"\/><\/span><\/div>"},"post_detail":{"above_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">CHUO SOGO LPC<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2019\/03\/clo_logo-v-En01.png\"\/><\/span><\/div>","below_title":"<span class=\"guide-intro\">This country specific Q&amp;A provides an overview of Insurance &amp; Reinsurance laws and regulations applicable in Japan<\/span><div class=\"guide-content\"><div class=\"filter\">\r\n\r\n\t\t\t\t<input type=\"text\" placeholder=\"Search questions and answers...\" class=\"filter-container__search-field\">\r\n\t\t\t<\/div>\r\n\r\n\t\t\t\r\n\r\n\r\n\t\t\t<ol class=\"custom-counter\">\r\n\r\n\t\t\t\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How is the writing of insurance contracts regulated in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Writing of insurance contracts is regulated by the Insurance Business Act and the Financial Services Agency (the \u201cJFSA\u201d) supervises insurance companies. O\ufb00ering new insurance products requires approval from the JFSA, (\u201cInsurance Product Approval\u201d \u2013 regular processing takes 90 days, standardised 45 days). However, regarding certain types of insurance where there is little fear of insu\ufb03cient policyholder protection, such as \ufb01re insurance, a noti\ufb01cation system to the regulatory authorities has been adopted, although noti\ufb01cation may not be required in cases where insurance companies state in the statement of business procedures that special provisions related to business insurance are to be established or modi\ufb01ed without noti\ufb01cations. (\u201cFlexible Provision System\u201d).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are types of insurers regulated differently (i.e. life companies, reinsurers?)<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Life insurers and non-life insurers are both regulated by the Insurance Business Act. Reinsurers are regulated in the same way as non-life insurers. Engaging in the underwriting of life insurance and non-life insurance entails obtaining from the regulatory authorities a life insurance business licence and a non-life insurance business licence, respectively. Companies may not run both businesses concurrently.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are insurance brokers and other types of market intermediary subject to regulation?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Unless otherwise permitted by any other laws, the Insurance Business Act prohibits any person from acting as an agent or intermediary to solicit insurance contracts, an activity which falls under the de\ufb01nition of \u201cinsurance solicitation\u201d under the Act.<\/p>\n<p>In the case of a life insurance company, only registered life insurance agents (i.e, o\ufb03cers and employees of a life insurer; or life insurance agencies (agents) as well as their o\ufb03cers, employees and other personnel) may conduct \u201cinsurance solicitation.\u201d In principle, in the current legal system, life insurance agents operate within the so-called \u201cone-company exclusive system\u201d, meaning they may deal with the insurance products of only one insurance company. However, by ful\ufb01lling the prescribed legal requirements (such as enrolling two or more life insurance agents), it is possible to deal with the insurance products of multiple insurance companies, with quite a number of independent agencies currently doing so.<\/p>\n<p>The situation involving non-life insurance companies (including reinsurance companies) is as follows:<\/p>\n<ul>\n<li>O\ufb03cers (other than auditors) and employees of a non-life insurer may engage in \u201cinsurance solicitation\u201d without being registered nor any notice thereof.<\/li>\n<li>Registered non-life insurance agencies as well as their o\ufb03cers (with the exception of auditors) and employees may engage in \u201cinsurance solicitation.\u201d No o\ufb03cers or employees of non-life insurance agencies are required to be registered, but they are required to give notice of such a fact.<\/li>\n<\/ul>\n<p>Registered insurance brokers may also engage in \u201cinsurance solicitation\u201d (limited to mediating conclusions of insurance contracts). The Insurance Business Act has assigned special duties to such insurance brokers, including the duty to deposit a security guarantee (JPY10 million at the time of commencement of their business (lowered from JPY20 million effective June 1, 2026), which payment can be exchanged for an insurance brokers&#8217; liability insurance policy), the duty to disclose fees and commissions, the duty to prepare bought and sold notes, the duty of loyalty (the duty of \u201cbest advice\u201d), and other special duties that have not been imposed on insurance agents.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is authorisation or a licence required and if so how long does it take on average to obtain such  permission? What are the key criteria for authorisation?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Engaging in the underwriting of life insurance and non-life insurance entails obtaining from the regulatory authorities a life insurance business licence and a non-life insurance business licence, respectively. The JFSA endeavors to complete its review of licence application procedures within 120 days after a licence application reaches the JFSA (which is a standard processing period under Article 246 of the Order for the Enforcement of the Insurance Business Act). Insurers who lay out a plan for obtaining a licence, however, cannot normally rely on this standard processing time, \ufb01rst, because it only obligates the JFSA to make an e\ufb00ort to meet that deadline, and second, because their negotiations with the JFSA begin by an exchange of drafts preceding the formal \ufb01ling of documents for the licence application \u2013 in fact, it is common that no formal documents for the licence application are \ufb01led before obtaining an acknowledgement from the JFSA.<\/p>\n<p>The key criteria for licencing under the Insurance Business Act are, among other things, as follows:<\/p>\n<p>(i) the person filing application for the insurance licence has a sufficient financial basis to perform insurance services soundly and efficiently, and has good prospects for income and expenditures in connection with those services;<\/p>\n<p>(ii) in light of such points as its personnel structure, the applicant has the knowledge and experience to perform insurance services appropriately, fairly, and efficiently, and has sufficient social credibility;<\/p>\n<p>(iii) the contents of the insurance contracts have no risk of lacking in protection for the policyholders, the persons to be insured, beneficiaries of insurance proceeds, and other relevant persons;<\/p>\n<p>(iv) no specific persons are subject to unfair or discriminatory treatment under the contents of the insurance contracts;<\/p>\n<p>(v) the contents of the insurance contracts pose no risk of encouraging or inducing conduct that is harmful to public policy and good morals;<\/p>\n<p>(vi) the rights and obligations of the Policyholders, etc. and other contents of the insurance contracts are specified clearly and simply for the Policyholders, etc.;<\/p>\n<p>(vii) the calculation procedures for insurance premiums and policy reserves are reasonable and proper, based on actuarial science; and<\/p>\n<p>(viii) no specific persons are subject to unfair or discriminatory treatment with regard to insurance premiums.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there restrictions or controls over who owns or controls insurers (including restrictions on  foreign ownership)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Under the Japanese regulatory framework, shareholders who own a certain percentage of voting rights in insurers are subject to oversight by the regulator.<\/p>\n<ul>\n<li>A shareholder with more than 50% voting rights in an insurance company is required to obtain approval from the JFSA in advance of acquiring such voting rights (Insurance Holding Company; Article 271-18-1 of the Insurance Business Act). Insurance Holding Companies are subject to strict regulations, including those regulating the scope of business and imposing subsidiary restrictions, and, in certain instances, reporting obligations.<\/li>\n<li>Apart from Insurance Holding Companies, a shareholder with 20% or more voting rights in an insurance company requires approval from the JFSA in advance of acquiring such voting rights (Major Shareholder of Insurance Companies; Article 271-10-1), even if such investor resides overseas. The JFSA oversees Major Shareholders of Insurance Companies by imposing reporting obligations and taking administrative dispositions.<\/li>\n<li>A shareholder with more than 5% voting rights in an insurance company is required to report the acquisition of such voting rights to the JFSA within \ufb01ve days (or one month in the case of foreign investors) (Shareholders with Large Voting Rights in Insurance Company; Article 271-3-1 of the Insurance Business Act). That shareholder has to submit a report if their percentage of voting rights changes by 1% or more (either as an increase or decrease). The JFSA may take administrative dispositions against Shareholders with Large Voting Rights in an Insurance Company if it \ufb01nds that the submitted report includes false information, or lacks important or necessary information, thus causing a potential misunderstanding.<\/li>\n<\/ul>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is it possible to insure or reinsure risks in your jurisdiction without a licence or authorisation?  (i.e. on a non-admitted basis)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>For the following insurance contracts, foreign insurers may conclude insurance contracts without obtaining the applicable licence:<\/p>\n<p>(i) Reinsurance contracts;<\/p>\n<p>(ii) Marine insurance contracts pertaining to objects such as vessels with Japanese nationality used for international maritime transportation;<\/p>\n<p>(iii) Aviation insurance contracts pertaining to aircrafts with Japanese nationality used for commercial aviation;<\/p>\n<p>(iv) Insurance contract pertaining to launching into outer space;<\/p>\n<p>(v) Certain insurance contracts covering cargo located within Japan which is in process of being shipped overseas; and<\/p>\n<p>(vi) Overseas travel insurance.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is a branch of an overseas insurer, insurance broker and\/or other types of market intermediary in  your jurisdiction subject to a similar regulatory framework as a locally incorporated entity?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A Japanese branch of an overseas insurer is subject to the similar regulatory framework as a Japanese incorporated insurance company, except some points such as a governance structure requirement. An overseas insurer is required to conduct insurance businesses through its Japanese branch with licence from the Japanese government, and may not undertake insurance contracts directly from foreign countries. Overseas insurance brokers are subject to the registration requirements under the Insurance Business Act to the extent they conduct \u201cinsurance solicitation\u201d in Japan.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any restrictions\/substance limitations on branches established by overseas insurers?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><ul>\n<li>To engage in insurance business in Japan, an overseas insurance company must establish a legal entity such as a branch office in Japan and obtain a business licence from the Prime Minister of Japan.<\/li>\n<li>In addition to having physical presence as a sales base, a branch office is required to comply with supervisory regulations under the Insurance Business Act. For example, a branch office should (i) maintain books for independent accounting calculation, and (ii) process the required administrative work related to the underwriting of insurance policies in Japan.<\/li>\n<li>Except in certain cases, a foreign insurance company will have to underwrite insurance policies pertaining to persons either domiciled or residing in Japan or to property located in Japan at its Japanese branch office or some other Japanese legal entity.<\/li>\n<li>Licencing criteria for overseas insurance companies are generally the same as those for domestic insurance companies.<\/li>\n<li>The licencing criteria include the following:\n<ul>\n<li>In the case of a foreign life insurance business licence, the applicant must have positive net income for one business year in Japan within ten business years after commencement of business.<\/li>\n<li>In the case of a foreign non-life insurance business licence, the applicant must have positive net income for one business year in Japan within five business years after commencement of business.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What penalty is available for those who operate in your jurisdiction without appropriate  permission?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A person who engages in the business of insurance without a licence is subject to punishment by imprisonment with work for not more than three years or a \ufb01ne of not more than 3,000,000 yen (cumulative imposition thereof as the case may be) (Article 315, item 1 of the Insurance Business Act).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How rigorous is the supervisory and enforcement environment? What are the key areas of  its focus?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Based on the Insurance Business Act, the regulatory authorities have the power to issue administrative dispositions to insurance companies, including orders mandating (a) changes to basic documents, (b) improvements to business operations, (c) suspension of business, or (d)\u00a0cancellation of a licence. In fact, a broad discretion has been given to the regulatory authorities, and the administrative dispositions against insurance companies invoked by the regulatory authorities are not necessarily based on the assumption that violations of law by insurance companies have taken place.\u00a0 As a matter of fact, entities targeted for supervision not only have to make sure that laws and regulations are being observed but also must follow the guidelines o\ufb03cially promulgated by the regulatory authorities (see <em>Comprehensive Guidelines for the Supervision of Insurers; the \u201cGuidelines\u201d<\/em>).<\/p>\n<p>On 29 August 2025, the FSA announced \u201cThe FSA Strategic Priorities July 2025\u2013June 2026.\u201d According to these priorities, the policy for administering insurance supervision for fiscal year 2025 can be summarised as follows.<\/p>\n<ul>\n<li>In view of the drastic changes companies are undergoing in the business environment, the FSA will encourage them to focus on risk management by utilizing non-life insurance. These days, for companies operating both domestically and abroad, the increase in frequency and severity of natural disasters, emerging geopolitical risks, and other factors resulted in increased risks of business interruptions as well as risks of greater losses due to litigation and inflation-driven damage cost surges. From the perspective of allowing companies to manage such risks appropriately and promote growth-oriented investments at the same time, it is important to develop a market for them to trade non-life insurance products that incorporate the individual risks for each company and project. To this end, in collaboration with relevant ministries and agencies, the FSA will make efforts to encourage mutual communication between business companies and non-life insurance companies, to share each other\u2019s specific needs and risk management insights, thereby fostering a common understanding among the parties concerned. In addition, in the context of growing severity of natural disasters, the FSA will provide leadership for international discussions, such as the G20 Meetings, on the issue of the insurance protection gaps where existing insurance does not provide sufficient coverage for the risks.<\/li>\n<li>Efforts will also be made to prevent the recurrence of fraudulent insurance claims and premium adjustment cases that could undermine trust in the non-life insurance industry, thereby ensuring customer-oriented business operations and realizing a healthy competitive environment.<\/li>\n<li>To ensure that insurance companies have appropriate information management systems that take precautions against the information leakages occurring in the industry, the FSA will conduct relevant supervision and inspections.<\/li>\n<li>In preparation for the enforcement of the revised Insurance Business Act (enacted in May 2025), the FSA will develop ordinances and revise supervisory guidelines to ensure appropriate comparative rater-based insurance sales by multi-agency brokers (ie, non-life insurance agents and life insurance agents) handling products from multiple insurance companies, strengthen the obligation of large-scale multi-agency brokers to establish systems, and promote the utilization of insurance intermediaries.<\/li>\n<\/ul>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How is the solvency of insurers (and reinsurers where relevant) supervised?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Insurance companies are required to accumulate policy reserves and appoint an insurance administrator with a predetermined actuary\u2019s licence, who gets involved in work related to actuarial science.<\/p>\n<p>Regulations on the solvency margin ratio were introduced in 1996, and the solvency margin index has become an assessment standard for the supervisory authorities to execute early corrective actions, with broad supervisory reach against targeted companies, including orders to submit an improvement plan. The solvency margin ratio has been introduced on a consolidated basis.<\/p>\n<p>Field tests of economic value-based solvency regimes have been conducted three times in the past, and the most recent \ufb01eld test \u2013 the results of which were announced in March 2017 \u2013 was conducted in accordance with the ICS \ufb01eld test speci\ufb01cations of IAIS (as of June 2016). In March 2016, the European Union announced its adoption of the equivalence recognition between Solvency II with temporary equivalence and the Japanese reinsurance supervision and group solvency. In March 2026, an economic value-based solvency regulatory framework was introduced in Japan, comprising three pillars: (i) solvency regulation, which sets a common Economic Solvency Ratio (&#8220;ESR&#8221;) standard and prescribes graduated supervisory intervention measures (including orders to submit an improvement plan, corrective measures, and business suspension orders at progressively lower ESR levels); (ii) internal management and supervisory review, which captures risks not fully addressed under the first pillar and promotes the sophistication of insurers&#8217; internal risk management; and (iii) disclosure requirements designed to facilitate appropriate dialogue between insurers and external stakeholders. The ESR replaces the former solvency margin ratio as the key indicator of insurers&#8217; financial soundness, with both assets and liabilities valued on an economic basis.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the minimum capital requirements?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The minimum amount of capital of an insurance company is 1,000,000,000 yen (Article 6 of the Insurance Business Act, Article 2-2 of Order for Enforcement of the Insurance Business Act).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a policyholder protection scheme in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The following policyholder protections are available:<\/p>\n<p>(i) Procedures allowing to change insurance policy terms by voluntary agreement between an insurance company and a policyholder in cases where it would be di\ufb03cult for such insurance company to continue its insurance business.<\/p>\n<p>(ii) Procedures allowing the Prime Minster to order<\/p>\n<ul>\n<li>\u00a0an insurance company to take necessary measures, such as suspending its business or consulting on the transfer of insurance contracts, or<\/li>\n<li>the management of an insurance company\u2019s business and property by an insurance administrator in cases where it would be di\ufb03cult for such insurance company to continue its insurance business.<\/li>\n<\/ul>\n<p>(iii) Procedures allowing the Prime Minister to designate another insurance company and recommend that such insurance company accept consultations on the transfer, etc. of insurance contracts in the event of a bankruptcy of an insurance company.<\/p>\n<p>(iv) Procedures allowing the Life Insurance Policyholders Protection Corporation of Japan to provide \ufb01nancial assistance for the transfer, etc. of insurance contracts or underwrites insurance contracts for an insurance company in the event of a bankruptcy of such insurance company.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How are groups supervised if at all?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>An Insurance Holding Company and an insurance company&#8217;s major shareholders (i.e., shareholders holding 20% or more of the insurance company\u2019s voting rights) are required to obtain approval from, and the large holders of the insurance voting rights (i.e., holders holding 5% or more of the insurance company\u2019s voting rights) are required to make noti\ufb01cation to, the JFSA supervising such regulations.<\/p>\n<p>The scope of business that subsidiaries of insurance companies may engage is restricted and is stipulated by law. Provided, however, that an insurance holding company\u2019s subsidiary may, with the approval of the JFSA, engage in any business that is not prescribed by law.<\/p>\n<p>The arm\u2019s length rule applies to inter-group transactions of an insurance company.<\/p>\n<p>Supervision of the JFSA for an insurance company group is based on laws and regulations as well as the <em>Guidelines<\/em> and the Financial Conglomerate Supervision Guidelines.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do senior managers have to meet fit and proper requirements and\/or be approved?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Article 8-2 of the Insurance Business Act requires directors who are engaged in the business of running an insurance company to have the knowledge and experience to appropriately, fairly, and e\ufb03ciently manage such business and to have adequate social trust (\u201cFit and Proper Principle\u201d). These matters are dealt in more detail in the <em>Guidelines<\/em>.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent might senior managers be held personally liable for regulatory breaches in  your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There are certain criminal penalties for breaches of regulations. Besides, the Prime Minister may, if an Insurance Company has come to fall under any of the following items, order the dismissal of its director, executive officer, accounting advisor, company auditor or financial auditor:<\/p>\n<p>(i) if it is in violation of laws and regulations, disposition of the Prime Minister pursuant to laws and regulations, or particularly important particulars among those prescribed in the documents listed in the items of Article 4, paragraph (2) of the Insurance Business Act;<\/p>\n<p>(ii) if it is in violation of the conditions attached to the relevant licence; and<\/p>\n<p>(iii) if it engages in conduct prejudicial to the public interest.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there minimum presence requirements in order to undertake insurance activities in  your jurisdiction (and obtain and maintain relevant licenses and authorisations)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Overseas insurers may conduct insurance business in Japan only if they have opened a branch in Japan and obtained the applicable licence from the JFSA. The procedure to apply for the licence is mostly the same as that for Japanese insurance companies. Since overseas insurers do not have capital inside Japan, they are required to deposit a minimum of JPY200 million to the deposit office to protect policyholders.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there restrictions on outsourcing services, third party risk management and\/or  operational resilience requirements relating to the business?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>In principle, outsourcing of insurance companies\u2019 business is not restricted. However, the <em>Guidelines<\/em> govern the management of outsourcees.<\/p>\n<p>Moreover, when an insurance company receives business outsourced by another insurance company, it is necessary to obtain approval from the JFSA (Article 98, Paragraph 2 of the Insurance Business Act), and in the case of a group company, a noti\ufb01cation must be submitted.<\/p>\n<p>Furthermore, it is generally understood that the core business of an insurance company, such as deciding whether to pay insurance claims, cannot be outsourced due to the licencing system of the insurance business.<\/p>\n<p>As for the operational resilience, the JFSA has published the draft of the discussion paper titled \u201cBasic Principle for Securing Operational Resilience\u201d for public consultation. The JFSA will use this paper for the discussion with insurance companies.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there restrictions on the types of assets which insurers or reinsurers can invest in or  capital requirements which may influence the type of investments held?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The asset management method of an insurer is limited to the scope to the assets set forth in Article 97-2 of the Insurance Business Act and Article 47 of the Ordinance for Enforcement of the Insurance Business Act, including such assets as securities, real property, loans, and deposits.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there requirements or regulatory expectations regarding the management of an insurer's reinsurance risk, including any restrictions on the level \/ type of reinsurance utilised?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The <em>Guidelines <\/em>provide no quantitative criteria for the management of an insurance company\u2019s reinsurance risks; rather, it calls for a supervision of a qualitative risk assessment.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How are sales of insurance supervised or controlled?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Solicitation of insurance is subject to a registration as well as various regulations, such as the duty to provide information and the duty to check the customer\u2019s intent. In addition, the Insurance Business Act has introduced other measures, such as the Cooling-o\ufb00 System, or the Financial ADR System.<\/p>\n<p>Apart from those regulations, the Insurance Act \u2013 which deals with insurance-related contract law (private law) \u2013 contains several mandatory provisions designed for the protection of consumers, which insurers cannot remove by agreement.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent is it possible to actively market the sale of insurance into your jurisdiction  on a cross border basis and are there specific or additional rules pertaining to distance selling or  online sales of insurance?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Unlicenced overseas insurers may not conclude insurance contracts with persons having an address or residence in Japan, property located in Japan, or vessels or aircrafts with Japanese nationality (Restriction on Foreign Direct Insurance; Article 186-1 of the Insurance Business Act) other than the insurance contracts listed below:<\/p>\n<ul>\n<li>reinsurance contracts;<\/li>\n<li>marine insurance contracts pertaining to objects such as vessels with Japanese nationality used for international maritime transportation;<\/li>\n<li>aviation insurance contracts pertaining to aircrafts with Japanese nationality used for commercial aviation;<\/li>\n<li>insurance contracts pertaining to launching into outer space;<\/li>\n<li>certain insurance contracts covering cargo located within Japan which is in the process of being shipped overseas; and<\/li>\n<li>overseas travel insurance.<\/li>\n<\/ul>\n<p>The restriction does not apply when an applicant who wishes to purchase insurance from unlicenced overseas insurers has obtained a permission from the JFSA in advance of their applications for insurance as set forth in Article 186-2 of the Insurance Business Act. This exception is provided for policyholders\u2019 benefit to purchase insurance products that are most beneficial to them. Provided, however, that such permission may not be provided in the following cases:<\/p>\n<ul>\n<li>the insurance product in question violates laws or is unfair;<\/li>\n<li>it is easy to conclude insurance contracts with licenced Japanese or foreign insurers for comparable insurance products on equal or more advantageous conditions;<\/li>\n<li>the terms and conditions of the insurance product in question are significantly unbalanced compared to the typical terms and conditions of the same type of insurance products with licenced Japanese or foreign insurers;<\/li>\n<li>concluding such insurance contracts would unjustly deprive the insured and other related persons of their benefits; and<\/li>\n<li>concluding such insurance contracts would likely negatively impact the development of the Japanese insurance business or be harmful to the public interest.<\/li>\n<\/ul>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are insurers in your jurisdiction subject to additional requirements or duties in respect of  consumers? Are consumer policies subject to restrictions, including any pricing restrictions? If  so briefly describe the range of protections offered to consumer policyholders<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Consumer policies are restricted pursuant to several laws. For example, mandatory or unilaterally mandatory provisions in the Insurance Act (the latter is a series of provisions making void any agreement that, contrary to such provisions, adversely a\ufb00ects policyholders); and invalid provisions under the Consumer Contract Act.<\/p>\n<p>For example, Article 10 of the Consumer Contract Act provides that:<\/p>\n<p>\u201cAny consumer contract clause that restricts the rights or expands the duties of the consumer beyond the application of provisions unrelated to public order in the Civil Code, the Commercial Code (Act No. 48 of 1899) and any other laws and regulations, and that unilaterally impairs the interests of the consumer in violation of the fundamental principle provided in the second paragraph of Article 1 of the Civil Code, is void\u201d.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a legal or regulatory resolution regime applicable to insurers in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><ul>\n<li>One relevant regime, which exists under the Insurance Business Act, is in charge of matters such as making changes to contract terms, or issuing dispositions with respect to business and property administration; another regime exists under the Bankruptcy Act and is in charge of corporate reorganization procedures.<\/li>\n<li>Still another body, called the Policyholders Protection Corporation, plays an important role in the process of bankruptcy of insurance companies by providing financial assistance for transfers of insurance contracts and other related matters pertaining to insurance companies undergoing bankruptcy, management of the business of successor insurance companies, underwriting of insurance contracts, provision of financial assistance for the payment of covered insurance proceeds, and purchase of insurance claims.<\/li>\n<\/ul>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are the courts adept at handling complex commercial claims?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There are no special courts for resolving commercial insurance disputes. Commercial insurance disputes are generally resolved in district courts or summary courts depending on the value of the dispute. In general, Japanese courts are adept at handling commercial claims even if they are complex.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is alternative dispute resolution well established in your jurisdictions?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A \ufb01nancial ADR system was introduced in 2010 to encourage fast, simple and \ufb02exible dispute resolutions. ADR institutions have been established with the designation and supervision of the JFSA. Mediators in the ADR institutions are selected from the professionals in the \ufb01nancial sectors. A \ufb01nancial ADR system obligates insurance companies to cooperate in the dispute resolution, wherein insurance companies are required to appear at hearings and provide certain information requested by the mediators unless there are reasonable grounds. As such, a \ufb01nancial ADR system is advantageous to customers compared to lawsuits in the courts. The number of ADRs handled through \ufb01nancial ADR systems remains stable in recent years.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a statutory transfer mechanism available for sales or transfers of books of  (re)insurance? If so briefly describe the process<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>An insurance company may transfer insurance contracts to other insurance companies by obtaining the authorisation of the Prime Minister pursuant to the Insurance Business Act. The mechanism of such transfer is as follows:<\/p>\n<ul>\n<li>Special resolution of shareholders meeting of both transferor company and transferee company in relation to such transfer.<\/li>\n<li>A transferor company must make a public announcement within 2 weeks after the resolution of the shareholders meeting as well as notifications to each policyholders that will be affected by the transfer (the \u201cAffected Policyholders\u201d).<\/li>\n<li>The Affected Policyholders may raise an objection within certain period. The transfer must not be carried out where the number of the Affected Policyholders who have stated their objections exceeds one tenth (one fifth, in case of transfer of insurance contracts pertaining to all insurance contracts) of all Affected Policyholders, and the amount specified by Cabinet Office Order as the credits belonging to the insurance contracts of the Affected Policyholders who have thus stated their objections exceeds one tenth (one fifth, in case of transfer of insurance contracts pertaining to all insurance contracts) of the amount prescribed as the credits belonging to all Affected Policyholders.<\/li>\n<li>In case where a transferor company obtains an authorisation of the Prime Minister, and where any Affected Policyholder raised an objection and manifested their intention to cancel the contract if the transfer of the contract takes place, the transferor company must refund to the relevant Affected Policyholder the amount of money reserved for the insured, any unearned premium and any other amount of money specified by Cabinet Office Order.<\/li>\n<\/ul>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the primary challenges to new market entrants? Are regulators supportive (or  not) of new market entrants?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Obtaining a required licence from the JFSA is the primary challenge for new market entrants. As it may take a long time to complete the licence procedure, new market entrants should commence discussions with the JFSA 1.5-2 years before the launch of business.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent is the market being challenged by digital innovation?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>In Japan, the emergence of digital innovation in the \ufb01nancial sector, so-called FinTech, was most pronounced in the banking sector at \ufb01rst.<\/p>\n<p>Indeed, the Japanese government \ufb01rst responded to FinTech by amending the Banking Act so that banks could own technology companies as their subsidiaries \u2013 something which was previously restricted to some extent (the \u201cAmended Banking Act\u201d). In 2021, the Insurance Business Act was amended in the same way for insurance companies to own subsidiaries that provide IT and other technology to enhance insurance activities and bene\ufb01t the insurance companies\u2019 customers.<\/p>\n<p>Embedded insurance \u2014 the integration of insurance into various products and services \u2014 is gaining momentum through cross-industry collaborations. For example, some automakers now bundle car insurance with their car-sharing offerings, enabling users to access coverage effortlessly. This approach enhances customer convenience and delivers practical, timely protection tailored to users&#8217; needs.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How is the digitization of insurance sales and\/or claims handling treated in your  jurisdiction, for example is the regulator in support (are there concessions to rules being made) or  are there additional requirements that need to be met?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>JFSA has indicated its position to continue promoting digitization as a sound and sustainable business model for insurance companies.<br \/>\nSpecifically, the following deregulatory measures have been implemented with regard to the provision of information by insurance companies to customers at the time of sales of insurance products:<\/p>\n<p>(i) Explanatory documents related to \u201cvariable insurance\u201d and \u201cforeign currency-denominated insurance\u201d that were not permitted to be issued by electromagnetic means can now be provided by electronic means after obtaining the customers\u2019 consent.<\/p>\n<p>(ii) With regard to the obligation to deliver documents to customers other than the documents referred to above in item (i), while the provision of information by electronic means had been permitted after obtaining prior customers\u2019 approval, the method of transmission was limited to e-mail, downloading, and CD-ROM only. However, with the implementation of this deregulatory measure, electronic means now include post on customer-only pages (e.g., pages requiring IDs and password-based authentication) and publicly-accessible pages (e.g., the company\u2019s home page).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent is insurers' use of customer data subject to rules or regulation?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The Insurance Business Act requires an insurance company to establish an internal management system for proper handling of customer data, including preparation of company rules, training for employees\/officers, controlling access to customer data. In addition, the Act on the Protection of Personal Information (\u201cAPPI\u201d) provides a personal data mechanism, which is applicable to insurers&#8217; use of data in relation to individual customers. Under the APPI, customer data can be utilised within the purpose of use that an insurance company notifies upon its acquisition.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent are there additional restrictions or requirements on sharing customer data  overseas\/on a cross-border basis?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Article 27 of the Act on the Protection of Personal Information (\u201cAPPI\u201d) provides that transfer of personal data to a third party requires the person\u2019s advance consent.\u00a0 Exceptions for this requirement include (i) opt-out scheme, (ii) outsourcing personal data management within the purpose of use of the data, (iii) transfer of business; and (iv) joint-use scheme.<\/p>\n<p>However, such exceptions are not applicable to overseas transfers of personal data and, hence, the person\u2019s consent will be required for it unless the country where the transferee of the data exists has the same level of personal data protection regime as Japan or the transferee has sufficient internal system for personal data protection. In obtaining such consent, certain information is required to be provided, including the information on the personal data protection system of the foreign country, and on the actions the transferee takes for the protection of personal data.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent are insurers subject to ESG regulation or oversight? Are there regulations\/requirements, including in connection with managing climate change and climate  change related financial risks specific to insurers? If so, briefly describe the range of measures  imposed.<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There are no such regulations in Japan.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a legal or regulatory framework in respect of diversity and inclusion to which  (re)insurers in your jurisdiction are subject?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The Corporate Governance Code to which the listed insurance companies should refer includes the diversity related principle. In particular, the principle 2.4 \u201cEnsuring Diversity, Including Active Participation of Women\u201d provides that \u201cCompanies should recognize that the existence of diverse perspectives and values reflecting a variety of experiences, skills and characteristics is a strength that supports their sustainable growth. As such, companies should promote diversity of personnel, including the active participation of women.\u201d It should be noted that a third revision of the Corporate Governance Code is currently underway. Under the proposed revision, the diversity-related provisions currently contained in the supplementary principles are to be elevated to full principle status, thereby strengthening their position within the comply-or-explain framework.<\/p>\n<p>The Tokyo Stock Exchange amended its listing regulations in 2023 to incorporate specific numerical targets for female officer ratios among Prime-listed companies. Prime-listed companies are expected to endeavour to appoint at least one female officer by 2025, and to aim for a female officer ratio of 30% or above by 2030. Companies are also encouraged to formulate action plans to achieve these targets.<\/p>\n<p>In addition, the JFSA amended the disclosure requirements for the listed companies regarding sustainability. The amended rule requires the listed companies to disclose their gender-related matters, such as the \u201cratio of female managers\u201d, the \u201cratio of male employees taking childcare leave\u201d, and the \u201cgender wage gap\u201d.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Over the next five years what type of business do you see taking a market lead?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The Cabinet Office&#8217;s Annual Report on the Ageing Society projects that the proportion of the population aged 65 and above will reach 33.3% by 2037. It is also estimated that the Japan\u2019s population will fall below 100 million to 99.65 million by 2056, and further decline to 87 million by 2070. These trends underscore expanding demand for health, long-term care, and life insurance products tailored to an ageing society.<\/p>\n<p>Cybersecurity has concurrently emerged as a critical management challenge. The Ministry of Economy, Trade and Industry issued the Cybersecurity Management Guideline in 2015, revised to Version 3.0 in March 2023, clarifying that cybersecurity constitutes a business-level executive responsibility. The General Insurance Association of Japan&#8217;s 2025 SME Risk Survey documented that cyber insurance awareness among small and medium-sized enterprises has risen to 56.4%, while the subscription rate has nearly doubled from 4.8% in 2023 to 8.8% in 2025. 79.5% of firms that experienced cyber incidents acknowledged that their preparedness had been insufficient \u2014 the highest figure of any risk category surveyed. Cyber-related damage now affects 16.8% of firms reporting any incident, a continuing upward trend from 5.8% in 2021.<\/p>\n<p>The regulatory environment is also evolving. The JFSA&#8217;s revised Insurance Business Act, passed in May 2025 with enforcement due by May 2026, mandates strengthened compliance systems for insurers and agents, and is expected to reshape industry relationships.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\r\n<div class=\"word-count-hidden\" style=\"display:none;\">Estimated word count: <span class=\"word-count\">6013<\/span><\/div>\r\n\r\n\t\t\t<\/ol>\r\n\r\n<script type=\"text\/javascript\" src=\"\/wp-content\/themes\/twentyseventeen\/src\/jquery\/components\/filter-guides.js\" async><\/script><\/div>"}},"_links":{"self":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide\/139918","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide"}],"about":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/types\/comparative_guide"}],"wp:attachment":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/media?parent=139918"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}