In June 2025, amendments to the Payment Services Act were enacted and promulgated. Under the amended Act, a new category of regulated business—Electronic Payment Instruments and Crypto-Asset Service Intermediary Business (the “Intermediary Business”)—will be introduced by June 2026, one year after the promulgation.
The Intermediary Business covers entities that solely engage in intermediary activities, namely matching users who wish to buy or sell electronic payment instruments or crypto-assets with registered Crypto-Asset Exchange Service Providers or Electronic Payment Instruments Service Providers, without themselves conducting the sale or exchange of such assets.
Under the previous regulatory framework, even entities engaging only in intermediary activities were required to register as Crypto-Asset Exchange Service Providers or Electronic Payment Instruments Service Providers, and were therefore subject to stringent regulatory requirements, including financial requirements, user asset management obligations, and customer due diligence obligations under the Act on Prevention of Transfer of Criminal Proceeds.
By registering as an Intermediary Business, these regulatory obligations are significantly eased compared to those applicable to Crypto-Asset Exchange Service Providers and Electronic Payment Instruments Service Providers.
KPMG provides advisory services to support registration applications for the Intermediary Business, leveraging its extensive knowledge of the amended legislation and related regulations, as well as best practices accumulated across relevant industries.
