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Japan's Financial Services Agency (FSA) is set to implement mandatory liability reserve requirements for cryptocurrency exchanges, aiming to shield investors from losses due to hacks, fraud, and operational errors. The rules, expected to be introduced in the 2026 ordinary legislative session, will compel licensed exchanges to maintain reserves proportional to their trading volume and historical incident records
. This move follows high-profile collapses like Mt. Gox in 2014 and DMM in 2024, which left victims uncompensated and exposed regulatory gaps .Under the proposed framework, exchanges will no longer be exempt from reserve requirements by storing assets in cold wallets. Instead,
to immediately reimburse customers in case of breaches. The FSA is also considering allowing insurance policies to offset cash burdens, a provision that could ease compliance for smaller platforms . The reforms are part of a broader effort to reclassify cryptocurrencies as financial instruments under the Financial Instruments and Exchange Act, subjecting exchanges to stricter oversight .The mandate aligns Japan with global peers such as the European Union and Hong Kong, which already impose capital and insurance requirements on crypto firms
. However, Japan's approach is unique in its emphasis on parity with traditional finance.
Industry experts argue the rules will enhance trust but may increase operational costs. Musheer Ahmed of Finstep Asia compared the reserve requirement to bank insurance, noting it could restore confidence but make exchanges "relatively more expensive to operate"
. Larger firms like bitFlyer and Coincheck, which already maintain voluntary reserves, are better positioned to comply than smaller operators . The FSA's working group is finalizing formulas to calculate reserve sizes, balancing risk mitigation with market viability .The regulatory overhaul also addresses vulnerabilities in third-party custodians and wallet providers, which were implicated in recent breaches
. For instance, DMM Bitcoin's 2024 hack traced back to compromised software from a third-party vendor . The FSA's new rules will require such providers to register with regulators, reflecting a shift toward treating crypto infrastructure with the same rigor as traditional financial systems .Japan's approach signals a maturing market where innovation and regulation coexist. While the FSA's 2026 timeline faces potential delays, the direction is clear: cryptocurrencies are being integrated into the mainstream financial framework. This could position Japan as a global leader in crypto regulation, attracting institutional capital while setting a benchmark for Asia's competitive crypto hubs
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