Opening a Corporate Bank Account in Japan as a Foreign Company: The Nominee Director Option Explained
目次
1. Why Is Opening a Bank Account in Japan So Difficult for Foreign Companies?
Japan’s corporate bank account market has tightened dramatically since the mid-2010s. Following the Panama Papers (2016) and subsequent international financial scandals, Japanese banks significantly strengthened their AML and KYC procedures.
For a foreign-owned company, the specific hurdles are:
Resident director requirement: Most major banks now informally require the representative director to be a Japan resident with a valid visa. Non-resident directors face near-automatic rejection at many institutions.
Detailed documentation in Japanese: Business plans, revenue projections, ownership structure charts, and client lists are typically required — in Japanese.
No second chance: If a bank rejects your application, you generally cannot reapply to the same bank. A failed application at a major bank can complicate future applications elsewhere.
My Number integration: Since 2025, banks have integrated Japan’s corporate identification system more deeply into the account-opening process, adding further complexity for new entrants.
Without a Japanese bank account, your subsidiary cannot receive payments from Japanese customers, process payroll, pay taxes electronically, or conduct routine banking. Delays of weeks or months are common, often blocking hiring and revenue generation.
Strict AML; resident director usually required; interview often mandatory
Regional banks
Varies by region
High
More flexible than mega-banks but still require strong local connection
Online banks
SBI Sumishin, Rakuten, Paypay
Moderate
More accessible for foreign companies; fewer services; limited credit
Japan Post Bank
ゆうちょ銀行
Moderate
Sometimes more flexible; useful as a secondary account
Credit unions / Shinkin
Varies by region
Lower (with introduction)
Relationship-based; introduction from a trusted local contact helps significantly
For most new foreign subsidiaries, online banks or regional banks are the most realistic starting point. A major bank relationship can often be established later, once the company has 1–2 years of operating history in Japan.
3. What Is a Nominee Director, and How Does It Help?
A Nominee Director (also called a resident director or local director) is a Japan-resident individual who is registered as a director of your Japanese subsidiary on the official corporate registry (登記簿). Their role is to provide the local presence that banks and other institutions require — not to manage the business.
In the context of bank account opening:
The Nominee Director can attend the bank interview in person as a registered director
Their Japanese residency and identification documents satisfy the bank’s resident-director requirement
The actual business decisions remain entirely with the parent company and its designated management
Important: A Nominee Director does not guarantee bank account approval. Having a resident director is a necessary condition at most banks, but not a sufficient one. The bank’s approval depends on many factors including the business plan, industry, country of origin of the parent company, and the company’s overall profile. We do not and cannot guarantee that your application will be approved.
4. Risks and Responsibilities of a Nominee Director
This is a point we are very transparent about: being a Nominee Director carries real legal responsibility under Japanese law. A director of a Japanese corporation is subject to:
Director’s liability: Legally responsible for the company’s compliance with Japanese corporate law, including tax filings, social insurance contributions, and labor regulations
Third-party liability: May face personal liability to creditors or third parties if the company causes harm through unlawful acts or negligence
AML exposure: If the company is found to be involved in money laundering or illegal activities, the Nominee Director may face criminal or civil consequences
Reputational risk: The Nominee Director’s name appears on the public corporate registry and is visible to anyone
These risks mean that we approach each Nominee Director request with significant care. We are not a nominee directory service that provides directors on demand — we act as Nominee Director only for companies we have thoroughly evaluated and are comfortable with.
5. How Probitas Approaches Nominee Director Requests
We conduct a due diligence review before agreeing to act as Nominee Director for any company. This is not a formality — it reflects our genuine responsibility as a registered director under Japanese law.
✓ Factors that make us more likely to proceed
✗ Factors that lead us to decline
Established parent company with verifiable operating historyClear and legitimate business purpose in JapanIndustry in mainstream sectors (technology, manufacturing, professional services, retail, etc.)Country of incorporation with strong regulatory standardsTransparent ownership structure (no unexplained multi-layer holding structures)Willingness to engage Probitas for ongoing tax compliance
Industries with elevated AML risk (cryptocurrency, certain financial services, gambling)Countries subject to FATF grey/black lists or heavy sanctions regimesComplex or opaque ownership structures that cannot be clearly explainedInability or unwillingness to provide standard KYC documentationRequest for Nominee Director only, with no ongoing tax compliance relationshipBusiness purpose that is unclear or inconsistent with the company’s stated activities
We will be direct with you during our initial consultation if we have concerns. Not every inquiry results in us agreeing to act as Nominee Director, and we prefer to decline early rather than create a relationship that is not the right fit.
Our approach: due diligence first, then a decision. If we proceed, you can expect ongoing transparency — we remain informed of the company’s activities and maintain a genuine director relationship, not a name-only arrangement.
6. The Process: From Inquiry to Account Opening
Step
Action
Timeline
Who is involved
1
Initial consultation (free) — discuss background, business purpose, industry, bank account needs
Immediate
You + Probitas
2
Due diligence review — KYC documents, ownership structure, business plan, beneficial owners
1–2 weeks
Probitas reviews
3
Decision and engagement — formal agreement covering Nominee Director scope and tax compliance
Within 1 week of DD
Both parties
4
Director registration — judicial scrivener registers Nominee Director on corporate registry
1–2 weeks
Judicial scrivener + Probitas
5
Bank account application — prepare package, select bank, attend interview as resident director
The exact requirements vary by bank. The following are most commonly requested:
Certificate of incorporation and articles of incorporation (apostilled if required)
Corporate registry certificate (登記事項証明書) of the Japanese subsidiary
Passports and identification of all directors and beneficial owners (≥25% shareholding)
Proof of Japan residence for the resident director (residence card)
Business plan in Japanese (we assist with preparation)
Projected revenues and operating plan for Japan
Parent company financial statements (most recent 1–2 years)
Ownership structure chart (showing all entities up to ultimate beneficial owner)
Office lease agreement or virtual office contract
Sample contracts or letters of intent with Japanese customers (if available)
Banks may request additional documents at any point during their review. We manage this process on your behalf and communicate all requests to you in English.
8. Frequently Asked Questions
Q: Can you guarantee that the bank will approve our application?
A: No. Bank account approval is entirely at the bank’s discretion. We cannot and do not guarantee approval. What we can do is prepare the strongest possible application, select the most appropriate bank for your situation, and attend the interview as your resident director. Approval rates vary significantly by industry and company profile.
Q: Which banks do you work with?
A: We work with multiple banks depending on the company’s profile, including online banks (which are more accessible for new foreign subsidiaries) and regional banks. We advise on the most appropriate starting point based on your specific situation. We do not have guaranteed introductions to specific major banks.
Q: How long does the whole process take?
A: From initial inquiry to account opening, the typical timeline is 6–12 weeks: 1–2 weeks for due diligence, 1–2 weeks for director registration, and 2–8 weeks for bank review. Major banks tend to take longer than online banks.
Q: Our company is in the cryptocurrency / fintech sector. Can you help?
A: These are industries where we exercise particular caution due to elevated AML risk and the corresponding director liability. Please contact us to discuss your specific situation. We assess each case individually and will be upfront if we are unable to proceed.
Q: We only need the Nominee Director for bank account opening. Can we end the arrangement afterwards?
A: We require an ongoing relationship — typically our standard tax compliance services — as a condition of acting as Nominee Director. A name-only arrangement with no ongoing involvement is not something we are comfortable with, as it does not allow us to properly fulfill our director responsibilities under Japanese law.
Q: How do we remove the Nominee Director if the relationship ends?
A: Removal of a director requires a shareholders’ resolution and a corporate registry update (registered by a judicial scrivener). This is a straightforward process. We include transition procedures in our engagement agreement from the start, so there is a clear exit path if needed.
9. Contact Probitas
If your company is entering the Japanese market and needs help navigating the bank account opening process, we are happy to discuss your situation. Please be prepared to share basic information about your parent company, business purpose, and industry during our initial consultation.
Assessment of your company’s bank account options
Due diligence review for Nominee Director consideration
Bank application preparation and interview support
Corporate tax and consumption tax compliance (ongoing)
