How to Verify a Japanese Company for Free: Step-by-Step Guide

Japan has the most privacy-protective corporate disclosure regime in the developed world — and it's almost entirely intentional.

There is no public beneficial ownership register. There is no public shareholder data for any entity type — not even for joint stock companies. The optional UBO register that opened in January 2022 is voluntary, only available to Kabushiki Kaisha, and accessible only to the company itself or authorised third parties. The country runs three separate registry systems, all in Japanese, none of which gives a foreign obliged entity a clean line of sight to a natural-person UBO.

This is not an oversight. Japan's Companies Act treats shareholder identity as private information, kept in an internal register at the company itself (the kabunushi meibo) rather than filed with the State. The result, for foreign verification, is a legal opacity that doesn't exist in any major Western jurisdiction.

FATF flagged Japan's beneficial ownership transparency in its 2021 Mutual Evaluation. Japan has been improving — the 2022 optional UBO register, the 2024 amendments to the Act on Prevention of Transfer of Criminal Proceeds, the 2024-26 National AML/CFT/CPF Action Plan — but the architecture remains decentralised, voluntary, and Japanese-only. By 2024, FATF had upgraded Japan to "largely compliant" on six recommendations, but the structural privacy preference has not changed.

This guide explains the three Japanese registry systems, the optional UBO register, the KK-vs-GK transparency divide, the keiretsu cross-shareholding problem, and how foreign obliged entities verify a Japanese UBO when the formal infrastructure is designed to protect shareholder privacy. For a comparison of how Japan's framework sits alongside other major jurisdictions, see our global UBO regulations index.

Three Systems, None of Them a UBO Register

Japan operates three separate, interconnected systems for corporate transparency. None is a beneficial ownership register in the sense used elsewhere. Knowing which one applies to which question is the first step.

The takeaway: Touki and NTA give you identity. EDINET gives you partial shareholder data for listed companies. The optional UBO register sits behind a request gate. There is no Japanese equivalent of the UK PSC Register, the Quebec REQ, or even China's NECIPS shareholder data.

Touki: The Commercial Registry

Touki (登記) is Japan's commercial register, operated by Legal Affairs Bureaus (Homukyoku, 法務局) under the Ministry of Justice. Every Japanese company files with Touki at incorporation and on every change of registered details. Touki is the legally authoritative register of corporate existence in Japan.

What Touki holds

For each registered entity, Touki records:

• Legal name in Japanese (and English where registered)
• 12-digit Commercial Registration Number
• Registered head office address
• Date of incorporation
• Capital amount
• Business purpose (jigyou mokuteki, 事業目的)
• Directors and representative directors (with reappointment dates)
• Statutory auditors (kansa-yaku, 監査役) where appointed
• Share class structure (number and types of shares authorised)
• Branch office details
• Reorganisations, mergers, dissolution

Touki does not hold shareholder data. The shareholder register (kabunushi meibo, 株主名簿) is maintained by the company internally and is not filed with the Legal Affairs Bureau. This applies to every entity type — KK, GK, and the legacy YK.

Access and fees

The online Touki Information Service (登記情報提供サービス) at touki.moj.go.jp is the primary public access point. Following the Ministry of Justice's April 2025 fee revision:

All Touki documents are in Japanese. There is no official English-language version. Foreign obliged entities typically work with translation services or specialist data providers that normalise Touki into English.

What a Touki extract actually shows

For a typical Japanese stock company, a Touki certified extract returns the following structure. Below is a representative example showing what's there — and crucially, what isn't.

Notice what's there and what isn't: directors, capital, registered address, representative director, even the statutory auditor — all visible. Shareholders are deliberately absent. The kabunushi meibo (shareholder register) is held internally at the company itself, not filed with the State.

What Touki tells you and what it doesn't

For UBO verification, Touki gives you:

• Confirmation the entity exists and is in good standing
• Directors and representative directors (typically the legal representative for service of process)
• Capital structure and share classes
• Statutory auditor (often a useful person to identify in cross-border investigations)

What Touki does not give you:

• Shareholders, by name, address, or shareholding
• Beneficial owners or any natural-person ultimate controller
• Audited financial statements (held in different filings)

For foreign obliged entities running KYC, this means the standard "pull a registry extract and trace upward" workflow used in most jurisdictions does not work in Japan. Touki gives you the floor — entity confirmation and directors — but the shareholder layer is missing entirely.

NTA Corporate Number: The Identity Layer

Introduced in 2015, the Corporate Number (法人番号, hōjin bangō) is a 13-digit identifier assigned by the National Tax Agency (NTA) to every corporation registered in Japan. It is the closest thing Japan has to a unified national entity identifier.

The NTA Corporate Number Publication Site at houjin-bangou.nta.go.jp is publicly searchable, free of charge, with no registration required. It supports search by name (Japanese or English where registered), by Corporate Number, and bulk lookup of up to 10 numbers at once.

What NTA gives you

For each registered entity, the NTA database returns:

• 13-digit Corporate Number
• Registered legal name (Japanese; English where filed)
• Head office address
• Industry classification (JSIC code, when available)
• Change history — including name changes, address changes, status changes
• Date of corporate number assignment (effectively the date NTA recognised the entity)

The Corporate Number is mathematically related to the 12-digit commercial registration number used in Touki — the Corporate Number is the commercial registration number prepended with a 1-digit check digit calculated by the NTA. This makes the two systems cross-referenceable.

What NTA doesn't give you

The Corporate Number database is identity-only. It does not include:

• Directors
• Capital
• Shareholders
• Beneficial owners
• Financial information of any kind

For UBO verification, NTA is the entry point — confirm the entity exists, get its Corporate Number, then move to Touki for directors and EDINET for listed-company shareholder disclosures. NTA is not a verification tool by itself.

EDINET: The Listed Company Disclosure System

EDINET (Electronic Disclosure for Investors' NETwork, 金融商品取引法に基づく開示書類等提出システム) is operated by the Financial Services Agency (FSA). It is the primary disclosure system for Japanese listed companies and certain regulated entities. For listed Kabushiki Kaisha, EDINET is the most reliable source of shareholder and beneficial ownership data publicly available in Japan.

What EDINET holds

• Yukashoken Hokokusho (有価証券報告書) — annual securities reports with full audited financial statements, typically due late June for the standard April-March fiscal year
• Quarterly reports (kessan tankishin, 四半期報告書)
• Major shareholder disclosures (5%+ rule) — natural persons or legal entities holding 5% or more of voting shares must file Large Shareholding Reports
• Tender offer documents
• Shareholder meeting notices and resolutions
• Insider trading reports

EDINET is at edinet.fsa.go.jp. Free, no registration required, in Japanese with voluntary English versions for many major listed companies.

What this means for verification

For listed Japanese companies, EDINET gives foreign obliged entities the closest equivalent of UBO data available in Japan:

• Major shareholders at the 5% threshold
• Audited financial statements
• Director and senior officer compensation
• Cross-shareholdings disclosed in the securities report

Two important limits. First, EDINET only covers listed entities — for the millions of private KK and GK, EDINET shows nothing. Second, the 5% threshold means small natural-person shareholders are not disclosed, even where they collectively control the company. For ownership chains that resolve through a publicly listed parent, EDINET is the verification anchor. For everything else, it is silent.

The Optional UBO Register (Since January 2022)

On 31 January 2022, the Ministry of Justice opened a voluntary UBO register at Legal Affairs Bureaus. The system is unique among major jurisdictions: it is opt-in for the company, not mandatory.

How it works

The register is available only to Kabushiki Kaisha (KK). A KK that wishes to use the system files a list of its UBOs with the local Legal Affairs Bureau. Once registered, the KK or its authorised representative (typically a legal scrivener, certified administrative scrivener, or attorney) can request a certified list of registered UBOs.

The certified UBO list serves a specific purpose: it allows the KK to demonstrate UBO information to third parties — banks, regulators, counterparties, government agencies — in a single document with State authentication. Without the register, the same information has to be assembled from internal company records each time.

What's filed

For each UBO, the company files:

• Name
• Date of birth
• Address
• Nationality
• Nature of ownership or control (shareholding percentage or other basis)
• Date of becoming a UBO

The UBO test follows the FATF approach: a natural person who directly or indirectly holds 25% or more of voting rights, or otherwise exercises control over the company.

Why it matters less than you'd think

Three problems limit the practical value of the optional register for foreign verification:

• Voluntary uptake. Companies that are most likely to opt in are those with simple, clean ownership structures who want a State-stamped document for banking purposes. Companies with complex ownership — keiretsu cross-holdings, foreign holding chains, family trusts — are less likely to use the register.
• Limited access. The register is not publicly accessible. Only the company itself, or persons authorised by the company, can request the certified list. A foreign obliged entity cannot query it directly.
• KK only. Godo Kaisha — the legal form chosen by Apple Japan, Amazon Japan, Goldman Sachs Japan, and many other major foreign subsidiaries — cannot use the register. For one of the most commercially important entity types in Japan, the optional UBO register doesn't apply.

KK vs GK: The Transparency Divide

Japan's Companies Act recognises four corporate forms. For UBO verification, the most important distinction is between the two dominant types: Kabushiki Kaisha (KK) and Godo Kaisha (GK). The transparency gap between them is structural.

The implication for verification: when a Japanese counterparty is a GK, the public information available is genuinely minimal. Touki gives you directors and address. NTA gives you the Corporate Number. EDINET shows nothing. The optional UBO register does not apply. For the financials, you need a credit bureau report (Teikoku Databank, Tokyo Shoko Research) or direct disclosure from the entity.

This is not accidental. The GK form was designed to be lighter-touch than KK. Foreign investors increasingly use GK precisely for its disclosure economy.

The Keiretsu Problem

Even when EDINET gives you partial shareholder data for a listed Japanese KK, you often hit the same problem: the shareholders are themselves Japanese corporations — typically other listed KK, in a network of cross-shareholdings known as keiretsu (系列).

Keiretsu structures emerged from Japan's post-war industrial groups. The classic example is Mitsubishi: Mitsubishi UFJ Financial Group holds shares in Mitsubishi Corporation, which holds shares in Mitsubishi Heavy Industries, which holds shares back into the financial group. Mitsui, Sumitomo, Fuyo, Sanwa, Dai-Ichi Kangyo all maintain similar networks. Toyota, Honda, Sony, and Canon all sit inside or around these networks.

For UBO verification, what matters is what this looks like on the page. Below is what a typical major Japanese listed KK reports as its top-10 shareholders in its EDINET annual securities report (Yukashoken Hokokusho). The shareholder names and percentages are anonymised but match the standard pattern of large-cap Japanese listed companies.

The pattern is consistent across major Japanese listed companies: the top two holders are trust banks holding shares as nominees for pension funds and ETFs (Master Trust Bank, Custody Bank), followed by keiretsu group affiliates and life insurers, with foreign nominees rounding out the top 10. No single holder reaches 25%. No combined keiretsu group reaches 25%. The senior managing official fallback applies under FATF's UBO test.

For UBO verification, this means foreign obliged entities should treat "no concentrated UBO" as the normal case for major Japanese listed companies, not an anomaly or a verification failure. The chain genuinely does not resolve to a small set of natural persons — it resolves to a distributed network of institutional holders. To trace any one of those institutional holders to its underlying UBO requires a separate trace through that institution's own structure (most of which are themselves listed KK with their own keiretsu networks). A single Japanese listed KK can require 4–6 layers of upstream tracing before the chain ends — and most often, it ends in another distributed network rather than a natural person.

The AML Law and 2024 Reforms

Japan's anti-money laundering framework runs on three legal pillars: the Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法, the "APTCP"), the FSA's AML/CFT guidelines, and the Inter-Ministerial Council coordination through the National AML/CFT/CPF Action Plan.

The 2024 amendments

The April 2024 amendments to the APTCP (Act No. 22 of 2007, as amended) and accompanying guidelines made several material changes:

• Expanded CDD obligations. Beyond the previous baseline of name, address, and date of birth, certain transactions now require verification of transaction purpose, client identity beyond ID document, business nature, and beneficial ownership where applicable.
• Substantial controller identification. For some transaction types, identifying "substantial controllers" (実質的支配者) — the Japanese parallel to UBO — became a specific obligation rather than a general expectation.
• Wider DNFBP scope. Designated non-financial businesses and professions — administrative scriveners, certified public accountants, tax accountants — gained explicit AML obligations and became subject to FSA supervisory guidance.
• Enhanced due diligence for PEPs. Politically exposed person identification became a structured EDD trigger.
• Travel Rule for crypto. Crypto-asset exchange service providers and electronic payment instruments service providers became subject to the FATF Travel Rule for transfers above ¥100,000.
• Records retention. Transaction records and verification documents must be retained for seven years from the date of transaction or contract termination.

The National Action Plan FY2024-26

In April 2024, the Inter-Ministerial Council (chaired by NPA and MOF) formulated the National AML/CFT/CPF Action Plan covering FY2024 to FY2026. Priorities include:

• Improving beneficial ownership transparency for legal persons
• Strengthening DNFBP supervision
• Aligning with FATF Recommendations 24 (legal persons) and 25 (legal arrangements)
• Preparing for the FATF fifth round of mutual evaluation

In its 2024 follow-up assessment, FATF upgraded Japan to "largely compliant" on Recommendations 7, 8, 12, 22, 23, and 25. Japan is now compliant or largely compliant on all 40 Recommendations — but the structural decision to keep beneficial ownership privacy-protected remains. The optional UBO register is the policy compromise: information is collected when the company chooses, accessible to authorities in an investigation, but not opened to public verification.

Japanese Trusts: A Civil-Law Trust Regime

Japanese trusts operate under the Trust Act (信託法, last revised 2006) and Trust Business Act (信託業法). Unlike common-law trusts, Japanese trust law is codified — settlor, trustee, and beneficiary roles are statutorily defined under specific articles. For UBO verification, the regime adds a layer of complexity that doesn't appear in any other major Asian jurisdiction except for trust-receiving structures.

The trust structure

A Japanese trust has three roles. Each is statutorily defined under specific articles of the Trust Act:

Unlike a corporation, a trust has no separate legal personality and no Corporate Number from the NTA. The trust property is legally owned by the trustee but held for the benefit of the beneficiary. For UBO purposes, the natural-person beneficiary is normally the UBO — but identifying the beneficiary requires direct disclosure from the trustee or the company involved.

J-REITs and the Investment Trust Act

J-REITs (real estate investment trusts) are not trusts in the strict legal sense — they are investment corporations established under the Act on Investment Trusts and Investment Corporations (ITA). A J-REIT is a Kabushiki Kaisha-style entity that invests primarily in real estate. Listed J-REITs file annual securities reports through EDINET and disclose 5%+ unit holders.

However, J-REITs often hold real estate through trust beneficial interests (TBIs) — meaning the underlying real estate is held by a licensed trust bank as trustee, and the J-REIT is the beneficiary. This is a common structural choice that minimises real estate acquisition tax.

Trust beneficial interests (TBIs) in real estate

Real estate investment in Japan frequently uses trust beneficial interests rather than direct title. Under this structure:

• The original property owner places real estate in trust with a licensed trust bank.
• The trust bank issues trust beneficial interests (信託受益権).
• The investor acquires the TBI rather than direct title to the real estate.
• The trust bank manages the property; the TBI holder receives economic benefit.

For UBO verification, this matters because the public real estate registry (touki) shows the trust bank as legal owner — not the actual investor. To identify the natural-person UBO, you need to trace through the TBI holder, which is often a Special Purpose Company (GK-TK structure) with its own anonymous investor base.

Tokumei Kumiai: The Anonymous Partnership Structure

Of all Japanese corporate structures, Tokumei Kumiai (匿名組合, "TK") is the single most opaque for foreign UBO verification. The literal translation is "anonymous partnership". The legal structure is designed to keep investor identity private.

What a TK is

Tokumei Kumiai is governed by the Commercial Code of Japan, Articles 535 through 542. A TK is a bilateral contractual relationship between:

• Operator (営業者, eigyōsha) — typically a GK established as a special purpose vehicle. Holds legal title to all assets. Manages the business.
• Silent partners (匿名組合員, tokumei kumiai-in) — investors who contribute capital and receive a share of profits. Their names are not disclosed.

Critically, a TK has no legal personality. It does not appear in the commercial registry, has no Corporate Number, and the TK agreement itself is not filed or made publicly available. The silent partners have no operating or voting rights. They have no co-ownership interest in the operator's assets. Their participation creates no permanent establishment in Japan for tax purposes.

The GK-TK structure

The dominant Japanese real estate investment vehicle is the GK-TK structure. It looks like this:

The structure achieves three things at once: tax efficiency (TK distributions are deductible from the GK's taxable income — pass-through taxation), bankruptcy remoteness (the ISH layer isolates the GK from operational creditors), and investor anonymity (the silent partners under the TK contract are never disclosed publicly).

What this means for UBO workflows

Under the 2024 APTCP amendments, regulated operators (FIBOs and Article 63 Exempted Operators) must identify the "effectively controlling person" (実質的支配者) of investors at the time of fund subscription. For TK arrangements, this means the operator must collect KYC on each silent partner — but this information stays with the operator, not in any public register.

For a foreign obliged entity dealing with a TK arrangement:

1. Confirm whether the counterparty is a TK operator or a TK silent partner.
2. If the counterparty is the operator (a GK), obtain the TK agreement and silent partner list directly. The operator is required to maintain this for AML purposes.
3. If the counterparty is a silent partner, the TK structure itself adds no UBO information — verify the silent partner directly.
4. For real estate transactions involving GK-TK structures, the senior managing official of the GK is typically filed as the UBO under the fallback rule. The actual economic UBOs (the silent partners) are not in any public register.
5. Apply Enhanced Due Diligence by default. The TK structure was designed for investor anonymity — that's not a verification failure, it's the structural intent.

The Designated Financial Institution Channel

For foreign obliged entities frustrated by Japan's lack of public BO data, a partial workaround exists: the Designated Financial Institution (DFI) channel under the APTCP.

How it works

Under the Act on Prevention of Transfer of Criminal Proceeds, "specified business operators" (特定事業者) — which include banks, securities firms, insurance companies, money service businesses, and certain non-financial professionals (lawyers, certified public accountants, real estate brokers in scope, dealers in precious metals) — have a statutory obligation to identify beneficial owners as part of customer due diligence.

To meet this obligation, specified business operators can require the customer (the Japanese company being onboarded) to provide identification documents, beneficial ownership declarations, and supporting evidence. Refusal by the customer to provide this is grounds for rejecting the relationship under the APTCP.

The cross-border angle

For a foreign obliged entity onboarding a Japanese counterparty, two practical workflows use the DFI channel:

• Through a Japan-licensed group affiliate. A foreign bank with a Japanese branch or licensed Japanese subsidiary is itself a "specified business operator" under the APTCP. It can request UBO information from the Japanese counterparty under its own statutory obligation. The information collected can then be shared internally within the group, subject to data protection rules.
• Through a Japanese AML-obligated intermediary. A Japanese law firm, accountancy firm, or trust bank can be retained to perform CDD on the counterparty and produce a verification report. This is slower but provides an independent, statutorily-grounded source.

Limits

The DFI channel is not a public access route. The information collected is held by the specified business operator and may only be shared in compliance with Japanese data protection law (the Act on the Protection of Personal Information, "APPI"). Foreign obliged entities without a Japan-licensed affiliate or appointed Japanese agent cannot invoke the DFI channel directly. The seven-year retention requirement applies to all CDD records collected under the APTCP.

Yugen Kaisha: The Legacy Structure

Yugen Kaisha (有限会社, "YK") is Japan's pre-2006 limited liability company form. The Companies Act revision of 2006 abolished new YK registrations — every new LLC since that date must be registered as a Godo Kaisha (GK). However, existing YK entities continue to operate, and many still appear in commercial dealings.

YK characteristics

• Cannot be newly registered (since 1 May 2006)
• Existing YKs continue to exist indefinitely as "Special Limited Liability Companies" (特例有限会社)
• Can convert to KK (most common path) or GK
• Name remains "Yugen Kaisha" or "YK" until conversion
• Legacy registry data — some YKs have not updated their Touki record since the 2006 transition
• Often family-owned small businesses or older holding structures

Verification implications

For UBO verification on YK entities:

• Touki data may be stale. Director information could be outdated by years if no triggering filing has been made. Confirm director currency by cross-referencing with credit bureau data.
• Optional UBO register does not apply. The 2022 voluntary register is for KK only. YK companies cannot use it.
• Conversion is a verification trigger. If a YK is converting to KK or GK, fresh registration generates current data. Conversion paperwork can be obtained for a fuller picture.
• Treat YK as a closed structure. Most YKs are small private holdings with limited disclosure pathways. Self-disclosure plus EDD is the standard approach.

FEFTA: Foreign Investment Reporting

The Foreign Exchange and Foreign Trade Act (外国為替及び外国貿易法, "FEFTA" or "Forex Act") regulates foreign investment into Japan. While not a UBO disclosure regime, FEFTA generates UBO-adjacent data for foreign-owned Japanese entities — and for some sectors, the rules have tightened significantly since 2020.

The two-track system

Foreign investors making "inward direct investments" into Japan must file either:

• Prior notification (事前届出) — for investments in sensitive sectors. Filed through the Bank of Japan to MOF and competent ministries before the transaction. 30-day standard waiting period (often shortened to 2 weeks for low-risk transactions).
• Post-transaction report (事後報告) — for non-sensitive sectors. Submitted within 45 days of closing.

The threshold for prior notification of a listed-company share acquisition was lowered from 10% to 1% in the 2020 amendments. For unlisted companies, there is no threshold — even one share triggers notification if the target is in a designated business sector.

What's collected

FEFTA filings include:

• Foreign investor identity and country of domicile
• Ultimate parent identification (the May 2025 amendments tightened scrutiny of investors under foreign government control)
• Acquisition structure and purpose
• Target company business activities and designated-sector classification
• Investor classification (Type A — under foreign government influence; Type B — partial restrictions; General investor)

Recent expansions

FEFTA's scope has expanded dramatically since 2019. The trajectory:

What FEFTA gives a foreign verification team

FEFTA filings are not publicly accessible. Bank of Japan and MOF hold the data; the public can see annual aggregate statistics but not individual filings. For a foreign obliged entity verifying a Japanese subsidiary of a foreign group, FEFTA filings cannot be directly queried. However, the existence of the filing system means:

• Foreign investors must have filed identification documents with MOF/BOJ for any non-trivial Japanese investment
• The Japanese target company knows its foreign owner's filing status and can produce filing documents on request
• For listed entities, FEFTA-driven shareholding moves above 1% appear in EDINET large-shareholding reports

The penalty for FEFTA non-compliance is severe — implementing a transaction without required clearance can lead to imprisonment up to three years or a fine up to ¥1 million or three times the investment amount, whichever is higher. This means foreign-owned Japanese entities are highly likely to have current FEFTA documentation, which can be requested as part of CDD.

Sanctions and Asset-Freeze Measures

Japan operates a sanctions framework that combines UN Security Council resolutions, autonomous Japanese measures, and G7-aligned actions. For UBO verification on Japanese counterparties, three sanctions touchpoints matter.

UN-aligned sanctions

Japan implements UN Security Council sanctions through the Foreign Exchange and Foreign Trade Act (FEFTA) and dedicated implementing regulations. Designated persons and entities are listed by MOF in public asset-freeze notices. The list aligns with UN Security Council consolidated lists and includes designations under DPRK, Iran, ISIL/Al-Qaida, and other UN-mandated regimes.

Autonomous Japanese sanctions

Japan maintains independent designation power through MOF's Foreign Asset Freeze List (外国為替及び外国貿易法による経済制裁措置) — published and updated by the Ministry of Finance. The MOF list incorporates UN designations plus Japan-specific designations, including Russia/Belarus sanctions aligned with G7 measures since 2022 and selected designations connected to North Korea, Russia evasion networks, and terrorism.

G7-aligned Russia sanctions

Since February 2022, Japan has implemented progressively tighter sanctions on Russia and Belarus in coordination with G7 partners. Measures include asset freezes against named oligarchs and officials, restrictions on financial transactions with Russian banks, export controls on dual-use goods, and prohibitions on certain investments.

Implications for UBO workflows

• Screen against the MOF Foreign Asset Freeze List as a baseline for any Japanese UBO verification. The list is the authoritative Japanese sanctions source.
• Cross-reference with OFAC SDN, UK OFSI, EU Council, and UN consolidated lists. Japanese designations align with UN, but not all OFAC or EU designations are reciprocated.
• For foreign-owned Japanese entities, run sanctions screening on the parent jurisdiction shareholders disclosed via FEFTA filings or EDINET large-shareholding reports.
• For Russia-connected entities, additional caution applies — Japan has been an active sanctions enforcer in coordination with G7 partners.
• The FEFTA prior notification regime acts as a sanctions filter — designated persons cannot generally complete inward direct investments without triggering MOF review.

What This Means for Cross-Border UBO Verification

For a foreign obliged entity verifying a Japanese counterparty in 2026, the practical position is:

1. NTA Corporate Number is your entry point. Free, comprehensive, returns identity and change history. Use this to confirm the entity exists and get its 13-digit identifier.
2. Touki for directors and capital. ¥330 per online view, ¥480-600 for certified extracts. Documents are in Japanese — budget for translation.
3. EDINET if listed. Free. 5%+ shareholder disclosures, full audited financials, major shareholding reports. Best Japanese source for any listed company UBO trace.
4. The kabunushi meibo from the company itself. The internal shareholder register is held at the company. Foreign obliged entities can request it as part of CDD onboarding. The company is not legally obliged to provide it to a third party in most circumstances, but typically does as a commercial relationship matter.
5. Optional UBO register if cooperative. If the entity is a KK that has registered UBOs, request a certified extract through the company's authorised representative. This is the most authoritative single document available.
6. Credit bureau reports (TDB or TSR) for private financials. Teikoku Databank and Tokyo Shoko Research maintain commercial credit databases that include shareholder data sourced from direct company surveys, audited filings, and bank disclosures. Paid, but the only realistic source for private KK and GK financial and ownership data.
7. Apply Enhanced Due Diligence by default for GK. The absence of public financial disclosure for GK companies is a structural information gap. EDD is the prudent baseline for any GK counterparty.
8. Treat keiretsu listed entities as having no concentrated UBO. For a major listed KK with a typical Japanese shareholder distribution, the senior managing official fallback applies under the standard FATF UBO test.

A worked example: Tokyo KK with a foreign parent

A typical structure for a Japanese subsidiary of a foreign group. Names anonymised. Compliance team is a Singapore bank onboarding the Japanese subsidiary as a corporate customer.

What this shows in practice:

1. Touki and NTA confirm the Japanese entity exists. Directors and Corporate Number are visible. No shareholders.
2. The kabunushi meibo (internal register) is requested from the company as part of CDD. The company provides it — naming the Singapore parent as 100% shareholder.
3. Singapore ACRA breaks it open. ACRA's public registry shows the shareholders of the Singapore entity — including the natural-person UBO.
4. Sanctions/PEP/AdvMedia screening on the identified UBO completes the verification.

For Japanese verification specifically, the parent jurisdiction usually does the work. Where the parent is in a transparent regime (UK, Singapore, Quebec, Luxembourg post-2025), the chain resolves at the parent level. Where the parent is itself in an opaque regime (Cayman, BVI, Panama), the verification often relies on entity self-disclosure backed by EDD.

Common Failure Points in Japanese UBO Verification

Where teams typically get this wrong:

• Assuming Touki shows shareholders. It does not — for any entity type. Compliance teams familiar with EU registers often expect to find shareholder data in the commercial registry. Japan's commercial registry is genuinely silent on ownership.
• Treating the optional UBO register as a primary source. The 2022 register is voluntary and not publicly accessible. Even where a KK has registered, foreign obliged entities cannot query it directly.
• Searching by English company name. Both Touki and NTA index by Japanese characters and Corporate Number. English names are unreliable search keys. Always confirm the Japanese legal name and Corporate Number first.
• Forgetting GK has no financial disclosure. The GK form is increasingly used by major foreign subsidiaries. Apple Japan, Amazon Japan, and Goldman Sachs Japan all operate as GK. For these entities, no public financials exist — credit bureau data or direct disclosure is the only path.
• Not applying EDINET to the right entity. EDINET covers listed KK only. For a private KK or any GK, EDINET shows nothing. Don't waste time searching it for non-listed entities.
• Treating keiretsu cross-shareholdings as a UBO trace failure. Major Japanese listed companies frequently have no concentrated natural-person owner. The senior managing official fallback under FATF is the correct outcome — not a verification error.
• Skipping the kabunushi meibo request. The internal shareholder register, requested directly from the company at onboarding, is often the most reliable disclosure for private KK. Make it a CDD requirement, not an afterthought.
• Ignoring the seven-year retention requirement. Under the 2024 APTCP amendments, transaction records and CDD documentation must be retained for seven years. This is longer than the EU and most other jurisdictions — set retention policies accordingly.