On 5 October 2026, the IBA Japan submitted recommendations to the Ministry of Justice (MoJ) on the proposed introduction of a shareholder identification regime under the Companies Act.
The MoJ is considering the introduction of two complementary shareholder identification mechanisms: an issuer-initiated identification system and a large shareholder reporting system. The proposal includes provisions for monetary fines and the suspension of voting rights as penalties for non-compliance.
While the IBA Japan welcomes this initiative towards greater transparency in the investment chain, the Association encourages the MoJ to reconsider certain aspects of the proposal, particularly those concerning the suspension of voting rights. The IBA believes that any new regime should be proportionate, predictable and consistent with established practices in other major jurisdictions, while taking into account the practical realities of the international investment and custody chain.
The full text of the submission is attached below.
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