On 31 March 2026, IBA Japan submitted a proposal requesting the relaxation of statutory ledger requirements under the Financial Instruments and Exchange Law (FIEL) and related regulations. The proposal calls for a transition from the current obligation to prepare and store ledgers in prescribed formats to an obligation to retain and manage requisite transaction information and data in a database, provided that robust processes are in place to supply relevant information to clients and authorities upon request. The submission argues that such a framework would be consistent with the FSA's digitalisation policy direction, would reduce the operational burden on foreign securities firms and asset management firms in Japan, and would bring Japan's approach in line with record retention practices in comparable jurisdictions. The full text of the submission is attached below.
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