Japan’s Financial Services Agency published its “FY2027 (Reiwa 9) Tax Reform Request Items” on August 31, 2026, asking the government to exempt trust-type stablecoins from tax reporting rules that currently apply whenever a token’s beneficiary changes.
The request falls under the FSA’s “Promotion of Financial Innovation” category and targets what Japanese law calls “specified trust beneficiary rights,” the legal structure behind yen-backed trust-type stablecoins.
What the FSA Is Actually Asking For
Under current inheritance tax law, a trust’s trustee must file a “beneficiary statement” with the tax office whenever a trust takes effect or its beneficiary changes, listing the beneficiary’s name and the trust asset’s value.
Separately, income tax law requires trustees to file a “trust calculation statement” covering the beneficiary’s name and the income and expenses attributed to the trust, according to the FSA’s published request document.
The FSA argues those rules don’t fit how trust-type stablecoins work. Because the tokens function as a payment method pegged to fiat currency and circulate frequently among an unspecified group of users, trustees have no practical way to track who holds the tokens or when that changes.
The agency is asking that both filing requirements be waived for these instruments when beneficiaries change.
How Trust-Type Stablecoins Are Structured
In the FSA’s diagram of the arrangement, a trust bank acts as trustee while an electronic payment instrument provider serves as the trust’s settlor and initial beneficiary. The provider pays yen into the trust, the trust bank issues the stablecoin, and the provider sells it to users, who then transfer it among themselves.
When a user wants to redeem, the provider buys back the token and requests redemption from the trust bank, which pays out in yen.
That structure is why the FSA says trustees can’t realistically comply with beneficiary reporting requirements as written, since tokens move between users without the trust bank’s direct involvement in each transfer.
Part of a Broader Set of Requests
The stablecoin item was the only proposal listed under the FSA’s financial innovation category this year. The broader request package also includes a separate ask covering how certain foreign-issued trust-type stablecoins should be classified as electronic payment instruments under Japanese law, alongside unrelated items on NISA investment account rules and tax treatment for bank-affiliated investment subsidiaries.
Why This Matters for Stablecoin Adoption in Japan
For readers following how different jurisdictions are adapting tax and reporting frameworks to fit blockchain-based payment tools, this request is a concrete example of a regulator trying to close the gap between existing law and how a token circulates.
It’s worth tracking alongside broader crypto news, particularly as more countries work through similar questions about applying legacy tax rules to instruments that weren’t designed with blockchain-based transfers in mind.
Japan currently has two categories of licensed electronic payment instruments circulating domestically: fund-transfer-type tokens and trust-type tokens like the ones this request addresses. Tax reform requests like this one typically move through Japan’s annual budget and tax code review process before taking effect, so any changes would not be immediate.
What this means for you: If you’re tracking how national regulators treat stablecoins for tax purposes, Japan’s proposal shows one approach, exempting the technology from reporting rules built for traditional trusts rather than for tokens that circulate constantly among unnamed holders, though this remains a request rather than enacted law.
This is not financial advice. Tax reform requests are proposals subject to government review and may change substantially or not be adopted, so consult a qualified tax professional for guidance specific to your situation.
