The Ministry of Health, Labour and Welfare is taking public comment until 16 November 2026 on a second edition of its guideline for fund transfer providers that want to be designated to receive employees' wages. Comments opened on 16 October, must be in Japanese and go through the e-Gov form, email or post to the ministry's wage division.
The framework the draft builds on
Under the draft, an employer may pay wages into a designated provider's account only with the worker's consent. The worker's balance must be kept at or below ¥1mn, either through a deposit cap or by sweeping the excess the same day to a bank or brokerage account the worker has named.
A private guarantee institution must also stand behind the full balance. If the provider files for bankruptcy or a similar proceeding, the institution must repay workers "promptly", which the draft defines as within six business days of the worker's claim, or of the filing where repayment needs no claim.
What the comparison table changes
The ministry's old-and-new comparison table shows several edits to the current text.
- Cap set per provider. A new sentence says the deposit cap is set at the level of the fund transfer provider.
- Guarantee sizing. The guarantee a guarantor must be able to fund is assumed to be ¥1mn (or the lower cap, if one is set) multiplied by the maximum number of accounts. The draft drops "in principle" from the line saying that maximum will be set as a condition of designation. A new sentence says this is meant to secure repayment of full balances within six business days of a failure.
- Definition of maximum accounts. The draft says the figure covers accounts already opened and accounts actually planned. A provider need not pre-fund growth. It can instead track new accounts accurately and arrange extra guarantee equal to each account's cap before the first deposit.
- Certification. The privacy mark or ISMS certification requirement now also accepts "other equivalent" certification. An applicant with a certification pending can file, but cannot be designated until it is complete.
- Worker disclosure. Employers explaining the scheme must say the guarantor repays the full balance. The current text says only that the balance is repaid.
What remains open
The draft leaves its own date blank, and the notice gives no date for when the revised guideline would take effect. The guideline says actual designations will be decided case by case on each provider's application. The ministry says it will not reply to comments individually and may publish them, apart from names and contact details.