The Financial Services Agency's study group on digital and decentralized finance heard three industry presentations on 2 November 2026, and two of them want the ¥1mn per-transfer limit on stablecoins loosened. The third, from the Japanese Bankers Association, warns against it. The agency's note on the meeting says the companies' materials reflect their own views, not the FSA's.
Where the cap bites
The FSA secretariat's paper explains the mechanics. Yen stablecoins issued by second-type fund transfer providers face a ¥1mn limit per transfer, and foreign stablecoins handled by licensed intermediaries are held to the same ¥1mn per-transfer limit. Trust-type stablecoins, the third category of electronic payment instrument, have no cap. The secretariat's discussion item asks members only how to think about the limit.
JPYC Inc. says the limit bites at issuance, not at transfer between users. A municipality converting ¥5bn into JPYC to pay ¥50,000 to each of 100,000 residents would need 5,000 separate issuances, in JPYC's example, because a bulk issuance counts as one remittance. JPYC proposes treating bulk issuance as the sum of individual allocations, and lifting or ring-fencing the cap for public bodies, banks and brokers, and verified corporates, alongside extra user-protection measures.
SBI VC Trade handles two dollar stablecoins, USDC and RLUSD, that carry the cap, and the yen trust-type JPYSC, which does not. Customers can move or sell only about ¥1mn at a time and hold up to ¥1mn. If a balance stays above that at month-end for six straight months, the firm buys the excess back. SBI VC Trade asks the agency to scrap the limit and buyback rule first for foreign instruments that must meet equivalence with Japan's regime, arguing the cap exists to let lightly regulated transfer providers handle remittances.
The banks' objection
The Japanese Bankers Association says scrapping or easing the ¥1mn limit while leaving the second-type framework unchanged should be considered "extremely" cautiously. Its paper gives four reasons. Collateral for a second-type provider can lag a surge in issuance, with more than 10 calendar days possible when holidays intervene. Repayment after a provider's failure through the traditional deposit route could take at least 170 days. Redemptions on a 24-hour instrument could bunch into a "digital run" that hits bank liquidity. And large, freely circulating tokens raise money-laundering risks. The association says high-value instruments belong with the licensed first-type providers.
Lending, without a rulebook
SBI VC Trade also described its stablecoin lending service. Customer loans stand at about ¥10.7bn, of which JPYSC is ¥7.65bn and USDC ¥3.06bn. Terms are fixed at one, three or six months with no early cancellation, and the firm says the product is not covered by deposit insurance or segregation. SBI VC Trade says rules for stablecoin lending are undecided and that crypto-style oversight would reassure customers. The secretariat paper confirms there is no comprehensive regulation of the business and asks members how it should be handled.