Japan Ends Photo-Based eKYC on 1 April 2027: Moving Onboarding to the IC Chip

From 1 April 2027, a business covered by Japan's Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法, or 犯収法) can no longer open an account online on the strength of a photo of an ID card and a selfie. The National Police Agency put it in one sentence on 23 July 2026: from that date, identity checks for account opening and similar transactions require reading the IC chip of a My Number card or similar document (JAFIC notice).

Online onboarding has to read the chip of a My Number card, driver's licence or other chip-bearing ID, or take a JPKI electronic signature from the My Number card. The Act covers banks, insurers, securities firms, crypto exchanges, money lenders, funds transfer operators and card issuers, among others. Mobile carriers face a matching change under their own law on the same day.

This is for the product and compliance leads who own onboarding at those firms, including foreign companies operating in Japan.

What the Ordinance Changes

The change is an amendment to the Act's enforcement ordinance (犯罪による収益の移転防止に関する法律施行規則), promulgated on 24 June 2025 and in force on 1 April 2027. The public comment result gives the reasoning: any method built on receiving images of an ID document carries a high risk of impersonation with forged or altered documents. Comments asked for both an earlier and a later date; the authorities kept 1 April 2027 to give businesses time for system changes.

What follows uses the consolidated text as it will read on 1 April 2027, published on e-Gov. It covers individual customers who are residents of Japan.

What ends

• Selfie plus a photo of the ID. The method the industry calls ホ方式: the customer photographs their face and their photo ID through your app. Abolished outright.
• Photo of the ID plus a bank link. Today a photo of the ID can be combined with a check against another regulated firm's verification record, or with a deposit into the customer's existing bank account. The photo option goes; only the chip version survives.
• The ID, or a photo of it, plus registered mail. Sending in an ID or its image, then mailing account documents by non-forwardable registered mail (転送不要郵便), is gone. One paper route is left: posting the original of an official certificate such as a residence record (住民票の写し) or a seal registration certificate.
• Copies of two documents plus registered mail. Now available only for people outside Japan's residents' register: non-residents and people who have moved abroad. Narrow exceptions remain, such as certain salary accounts opened through an employer.

What remains for online onboarding

• JPKI signature. The customer signs with the signing certificate on their My Number card, and you receive the certificate and the signed data.
• Selfie plus chip. Your software captures the customer's face and reads the chip of a photo ID that stores name, address, date of birth and photo.
• Chip plus a bank link. Your software reads the chip, then you either confirm another regulated firm has already verified the customer, or deposit money into their existing bank account and receive a copy of the passbook entry.
• Chip plus registered mail. Chip data first, then account documents by non-forwardable registered mail to the address on the chip.
• The smartphone My Number card. The card's attributes sent from the customer's phone through a program certified under the My Number Act.
• Electronic certificates from accredited or certified certification businesses, with the signed data.

At the counter too

A further amendment, promulgated on 6 March 2026 and also in force on 1 April 2027, brings face-to-face checks into line. A chip-bearing photo ID is presented and its chip is read on a device that shows the data on screen. An ID without a chip still works, but only with registered non-forwardable mail afterwards.

The NPA's customer leaflet adds two details for your support team: reading a driver's licence chip needs two PINs, and some financial institutions may switch before 1 April 2027.

Who Has the Work

If you run a vendor's hosted onboarding or SDK, much of the chip reading and JPKI handling is theirs. Ask when their chip flows go live, which remaining methods they support, and what they hand back for your records. Your job is the switch, the fallbacks and the data.

If you built photo capture yourself, or wrapped a vendor's image API in your own screens, the change lands on your team: capture screens, the review queue built around document images, and the record format.

JPKI verification itself is not something you build. The Digital Agency's JPKI page describes two routes. A business can obtain ministerial certification and check certificate validity with J-LIS itself, which takes "6か月から1年程度" (six months to a year) from receiving the technical specifications to certification. Or it can act as a service provider and delegate the check to a certified platform operator, whose fees vary. Starting in October 2026, only the second route fits the deadline.

The same page lists contact details for 25 platform operators (only those who agreed to be listed; not all serve other businesses) and counts 1,411 private businesses using JPKI as of 31 August 2026.

Second-hand dealers fall under the Act as dealers in precious metals and stones. The everyday check for buying second-hand goods sits in the Antique Dealings Act rules (古物営業法施行規則), for which e-Gov showed no amendment scheduled for 1 April 2027 when we checked in October 2026.

What Changes in the App

Reading the chip over NFC

On iOS, Core NFC reads these cards as ISO 7816 tags through an NFCTagReaderSession. The app needs the NFC tag reading entitlement and has to list the application identifiers it will select in Info.plist; the session sends a SELECT for each in order. On Android, the IsoDep class gives you a raw transceive channel and leaves the protocol on top to you.

Most teams will take that APDU layer from a vendor SDK rather than write it. The screens are yours either way: where to hold the card, for how long, and what happens when the read drops halfway. Test on real phones with real cards; antenna position differs between models.

PINs and passwords

JPKI and driver's licence reads depend on the customer remembering a PIN or password, and this is where completion rates are won or lost. According to J-LIS, the My Number card's user certificate PIN is four digits and locks after three wrong attempts. The signing certificate password is 6 to 16 alphanumeric characters and locks after five. A driver's licence needs two PINs.

Show the remaining attempts before the last try, and link to the reset routes J-LIS describes (a smartphone app plus a convenience store kiosk, or the municipal office). Never log or store what they type.

The JPKI flow

The app reads the signing certificate, the customer enters the password, and the card signs your application data. Your back end passes the certificate and signature to the platform operator, which checks validity against J-LIS revocation data. The signing certificate carries name, address, date of birth and sex, so you can prefill the form from it. The Digital Agency notes that JPKI does not use the 12-digit My Number itself.

The certificates also live on phones: on Android since May 2023, and on iPhone since 24 June 2025 for an iPhone XS or later on iOS 18.5 or above, according to the Digital Agency. The agency says support differs by service and tells users to keep the physical card. It also plans to replace the Android service around autumn 2026, so test against whatever is live in February.

Selfie plus chip, where face matching stays

If you keep a face check, its reference changes. The selfie has to be taken through your own software (a camera-roll upload does not count) and is compared with the photo stored on the chip, not a picture of a printed card. Liveness and face matching may survive; document-image capture, glare detection and the card-thickness check do not.

Fallbacks

Plan for the customer with no NFC phone, an ID without a chip, or a locked password. Without NFC, they can post an original residence certificate and receive registered mail, or visit a counter. A locked password goes to the reset route or another method you offer. Non-residents keep the image and copy methods, which matters for foreign firms with customers abroad. Route every case somewhere rather than ending the session.

Back End and Records

The record obligation stays: Article 6 of the Act requires the verification record (確認記録) to be kept for seven years. What goes into it changes with the method. Under Articles 19 and 20 of the amended ordinance:

• Selfie plus chip: attach the selfie and the chip data (name, address, date of birth, photo), and record the date you received each.
• Chip plus bank link: attach the chip data, and record when you received it and when you made the bank check or deposit.
• Chip plus registered mail: attach the chip data or posted certificate; record when you received it and sent the documents.
• JPKI and other certificates: attach an electronic record showing the check was done this way. Keep the certificate, signed data and operator's validity response together.
• Smartphone card: attach the electronic record received from the phone.

Every record names the method used: store it as a field, not inferred from the attachments. When customer details change, you add to the record and do not erase what was there.

If the chip shows an address that is no longer current, you can confirm the new one with a supplementary document, such as a utility receipt from the last six months. For residents that means the original, not a photo.

Then the cut. The June 2025 amending ordinance has a one-line supplementary provision setting the start date, with no transitional rule for applications in progress. Put the photo-based paths behind a switch you can turn off at 00:00 Japan time on 1 April 2027, and ask compliance how to treat sessions that straddle it.

Mobile Carriers Run in Parallel

Mobile carriers verify subscribers under a separate act on mobile voice contracts and its ordinance from the Ministry of Internal Affairs and Communications. According to e-Gov, the selfie plus photo of ID method had already left that ordinance by 1 April 2026.

The next step is Ordinance No. 94 of 2026 (令和8年総務省令第94号), promulgated on 27 July 2026 and in force on 1 April 2027. It brings in the shop counter: a chip-bearing photo ID is presented and its chip is read. With an ID that has no chip, the SIM, handset or contract documents go out by registered non-forwardable mail. Online, the main routes are a selfie plus a chip read, or a chip read plus registered delivery.

For carriers and MVNOs, the April 2027 work is mostly at the counter: chip reading in every shop, and staff who can talk a customer through a PIN. The Digital Agency publishes a face-to-face checking app for the My Number card (マイナンバーカード対面確認アプリ); ask compliance whether it fits your flow before building your own.

A Six-Month Plan

Working back from 1 April 2027:

1. October 2026: inventory. List every path by which a customer gets verified (app, web, shop, partner, post) and map each to the remaining methods. Anything relying on an ID image goes on the cut list.
2. October to November: choose methods and a partner. JPKI, selfie plus chip, or both. Pick a platform operator or confirm your vendor's dates, and get sandbox access early, since contracting can take longer than coding.
3. November: design. NFC screens, PIN handling and lockout copy, fallbacks, the record schema and the switch.
4. December to January: build. NFC flows on iOS and Android, the back-end integration with the operator, record storage, and views for the compliance team.
5. February: test. Real cards on real phones across your device base, smartphone cards on both platforms, lockout and reset paths, and the mail fallback end to end. Compliance signs off on the record contents.
6. March: launch and cut. Make the chip methods the default early in the month and watch completion rates. Brief support on PINs and resets. Turn the photo paths off on 1 April.

If your banking partners move earlier, as the NPA leaflet says some may, so does the plan.

Where to Get Help

Europe is moving the same way, from document images to cryptographic identity; our EU Digital Identity Wallet guide covers that side.

We build the parts on your side of the line: NFC chip reading in iOS and Android apps, the onboarding flow and its fallbacks, the integration with your chosen platform operator, and the records your compliance team has to keep. The JPKI verification itself stays with a certified Japanese platform operator. If you need engineers for the next six months, see our staff augmentation service, or write to office@c9group.dev.