Results of Public Comments on Proposed Insurance Law Revisions

The Financial Services Agency published proposed amendments to Cabinet Office Ordinances related to the 2025 Insurance Business Act revisions and to the Comprehensive Supervisory Guidelines for Insurance Companies and other guidelines, and solicited comments from December 17, 2025, to January 30, 2026. As a result, a total of 759 comments were received from 133 individuals and organizations. Similar comments were summarized as appropriate, and comments concerning multiple matters were organized by dividing them into separate items; consequently, they may not appear in the order in which they were submitted.

The amendments are based on recommendations set out in the June 25, 2024, report of the Expert Panel on Structural Issues and Competition in the Non-Life Insurance Business and the December 25, 2024, report of the Financial System Council Working Group on Systems and Other Matters Concerning the Non-Life Insurance Business and Related Areas. Based on these recommendations, the necessary amendments will be made to Cabinet Office Ordinances and supervisory guidelines concerning comparative explanations and recommendation-based sales by multi-insurer insurance agents.

Taking into account the many comments and inquiries submitted from practical perspectives, the Financial Services Agency has explained, in its responses to the public comments, the purpose of the framework and points requiring attention for improving comparative explanations and recommendation-based sales as specifically as possible.

Going forward, many multi-insurer insurance agents may consider and implement revisions to their operations aimed at improving comparative explanations and recommendation-based sales in light of the public comment results.

When applying the amended Cabinet Office Ordinances and supervisory guidelines, an appropriate application period will be provided in consideration of the time multi-insurer insurance agents need in practice to develop their systems and make other preparations. In light of guidance from insurance companies and other factors, multi-insurer insurance agents are expected to conduct appropriate comparative explanations and recommendation-based sales through their obligation to develop systems under Article 294-3 of the Insurance Business Act.

From the perspective of conducting business operations that take customers' best interests into account, multi-insurer insurance agents are encouraged to proceed as promptly as possible, without waiting for the enforcement and application dates, with system development and comparative explanations and recommendation-based sales based on the content and purpose presented by the Financial Services Agency.

The amended Cabinet Office Ordinances were promulgated on August 28, 2026, and will take effect from March 1, 2028. From the same date, the amended Comprehensive Supervisory Guidelines for Insurance Companies will also apply. Related materials include an overview of the comments and the Financial Services Agency's views, comparison tables showing the provisions before and after amendment for the Ordinance for Enforcement of the Insurance Business Act and the Cabinet Office Ordinance on Financial Services Intermediaries and related entities, and comparison tables concerning amendments to both sets of supervisory guidelines.

The framework development concerns comparative explanations and recommendation-based sales by multi-insurer insurance agents. Regarding the comments received, the Financial Services Agency organized them for ease of reference by summarizing similar content and dividing comments covering multiple matters into separate items. Comments not directly related to this matter will be used as a reference for future financial administration.

The duty to disclose authority under Article 294, Paragraph 3 of the Insurance Business Act and the duty to ascertain customer intentions under Article 294-2 of the same Act are outside the scope of this amendment. However, the Financial Services Agency has cautioned that timely and appropriate responses to these matters are still necessary at present.