Japan FSA Proposes Revisions to Insurance Supervisory Guidelines on In-House Agents and Antitrust Co

Key Takeaways

• Japan's Financial Services Agency has published draft amendments to the Comprehensive Supervisory Guidelines for Insurance Companies and is soliciting public comments until October 13, 2026.
• The draft restructures regulations on in-house agents, establishes antitrust compliance system expectations, and enhances monitoring of non-life insurance products for corporations.
• Non-life insurers and related agencies should assess the impact now and decide whether to submit comments.

Deep Dive

Japan's Financial Services Agency has published draft amendments to the Comprehensive Supervisory Guidelines for Insurance Companies and is soliciting public comments until October 13, 2026. The draft restructures regulations on in-house agents, establishes antitrust compliance system expectations, and enhances monitoring of non-life insurance products for corporations. Non-life insurers and related agencies should assess the impact now and decide whether to submit comments.

The draft follows two sets of recommendations: the "Expert Panel on Structural Issues and Competition in the Non-Life Insurance Industry" report (June 25, 2024) and the FSA Working Group report on systems and regulations for the non-life insurance industry (December 25, 2024). The amendments cover three areas: restructuring regulations on in-house agents (likely the oversight of agents tied to or embedded within insurers or corporate groups), establishing compliance systems for antitrust laws, and enhancing monitoring of non-life insurance products for corporations. The release does not describe the specific requirements. Those are in Attachment 1 (old and new comparison table, 211KB) and Attachment 2 (summary of amendments, 823KB), which we have not reviewed here.

Timelines are limited. Comments must arrive by 5:00 PM on Tuesday, October 13, 2026, by mail or through the e-Gov portal, and telephone submissions are not accepted. Submissions must include the name, industry, contact details, and reasons for the opinion. Submitted opinions and the submitter's name may be disclosed on request, so anonymity must be requested at the start of the comment. The FSA will not respond to comments individually. No enforcement date is set. Implementation will follow after the comment period ends and the necessary procedures are completed.

Recommended actions: (1) obtain and review both attachments to identify the specific changes; (2) map the changes against current agent management, sales practices, and corporate product governance; (3) assess the adequacy of existing antitrust compliance frameworks, including training, monitoring, escalation, and reporting; (4) evaluate how corporate non-life products are currently monitored, including pricing, coverage terms, and distribution practices; (5) coordinate with industry associations and decide whether to submit comments, mindful of disclosure rules; and (6) set up an internal workstream to track the final revisions and the enforcement date.

Risk implications: the changes signal increased supervisory scrutiny of agent relationships, competitive conduct, and corporate-client product outcomes in Japan's non-life market. Insurers with significant in-house agent structures or corporate-group business face the greatest impact, and they may need to change governance, controls, and documentation. Antitrust compliance is explicitly emphasized, so weak controls could bring both regulatory and enforcement exposure. The final impact cannot be fully assessed until the details are reviewed and the enforcement date is announced.

Source: Financial Services Agency (Japan)