The Financial Services Agency said on 6 November 2026 that its revised supervisory guidelines on bank services offered through APIs and partner apps apply from that day. It published the results of a public comment round that ran from 30 July to 31 August 2026 and drew 21 comments from nine individuals and groups.
What users must be told
When a bank and another business deliver a service through an app or website, supervisors are now directed to check whether users are told who provides the app, what the bank service is and which bank provides it, how the bank and the partner relate, who is responsible and what compensation applies after an accident, and whom to contact.
If the service carries a "[Name] Bank" style label, the guidance adds three points to explain. The label names a joint service. Deposits, remittances and account transfers are the bank's services, and users must open an account with that bank. The partner cannot provide bank services and does not do so. The information must be given where and how users can easily find it. Where customer data is received, supervisors are to check that the recipient and purpose are stated and that safeguards stop the data being diverted to other uses without the customer's consent.
The same wording appears in the guidelines for regional and smaller banks, and a matching provision was added for financial service intermediaries. The cooperative-system and fishery-cooperative credit guidelines were also revised.
Where bank agency begins
The revision says online displays can count as intermediation, which normally needs a bank agency licence, if they amount to inducing a specific person to sign a contract with a bank. A firm that sends its users to a bank is not treated as intermediating if it states in advance that the bank is the counterparty and that the bank provides the explanations. It must also avoid adding information, reworking explanations, soliciting or recommending, or negotiating terms. The guidance adds that the judgment rests on the whole course of conduct.
For comparison sites, republishing bank-supplied content is fine. Processing it, or building a design or algorithm that pushes the site's own recommended products to the top, may count as intermediation.
What the FSA said to commenters
On most questions the FSA declined to set a uniform standard, saying intermediation depends on the facts of each case, including where API or AI tools are used. Asked whether ranking by an objective measure such as deposit rate is safe, it said such ranking can still trigger a licence requirement depending on how it is displayed and what else is on the page. On pay-per-click arrangements and efforts to raise the visibility of bank banners, it said these could be one factor in the assessment.
One commenter asked for at least six months before the rules apply. The guidelines apply from publication, but the FSA said firms taking appropriate steps to improve will not be treated as a problem at once, and those whose arrangements are still inadequate should move quickly. It also said disclosures need not appear on every screen, though users must be able to find them easily.
The change to the section on financial products and services in the major banks guideline (III-6-1) did not go through public comment, because the FSA classed it as a minor change under Article 39(4)(8) of the Administrative Procedure Act.