Japanese
June 26, 2025
Financial Services Agency

Finalisation of Japan’s Stewardship Code (Third revision)

1. Revised Stewardship Code and the result of the public consultation

The Expert Panel on the Stewardship Code (hereafter, the “Panel”) (Chairman: Hiroyuki Kansaku, Professor, Gakushuin University, Faculty of Law), discussed to review the “Principles for Responsible Institutional Investors ≪Japan’s Stewardship Code≫” (hereafter, the “Code”) starting from October 2024.

The Financial Services Agency (hereafter, the "FSA") then published the draft revisions to the Code for a public consultation between 21 March, 2025 and 20 April, 2025.

The FSA received comments on the Japanese draft from 31 individuals/entities and from 15 individuals/entities on the English translation. The FSA expresses its gratitude to those who submitted comments.

Based on the received comments, the FSA finalised the revised Code (hereafter, the “revised Code”). The final version of the revised Code (English translation) is provided in Appendix 1. The revised Code with track changes from the previous version of the Code (English translation), is provided in Appendix 2.

The background, key revisions and results of the consultation are in Appendix 3. The summary of comments received and FSA's responses to them are in Appendix 4. In addition, we have received some comments that are not directly related to this revision, but these will be used as reference in the future policy making.

2. How to sign up with the revised Code

2.1 To institutional investors/institutions who are currently signatories of the previous version of the Code

Institutional investors/institutions who are currently signatories of the previous version of the Code are expected to update disclosure items based on the Principles, including Guidances, of the Code (hereafter, the “disclosure items”), in accordance with the revised Code within 6 months after the third revision of the Code (by the end of December 2025). Subsequently, institutional investors are expected (to disclose and) to notify the FSA (jstewardship★fsa.go.jp) of such updates if they take place.

2.2 To institutional investors/institutions who intend to newly sign up with the revised Code

Institutional investors who support the revised Code and are prepared to accept it are expected to publicly disclose their intention (Aims of the Code 9. of the revised Code).

The FSA adds names of institutional investors who have notified the FSA of their intention to accept the revised Code to the published list when it receives notifications of acceptance of the revised Code from institutional investors. Those who intend to newly sign up with the Revised Code are invited to notify the FSA (jstewardship★fsa.go.jp) of their intention as well as the information below.

• the institution’s name:
• name of the person in charge:
• contact information (telephone number and email address):
• the URL where the announcement of the acceptance of the Code have been released:
• the URL where the disclosure items described in the Code have been released:
• whether you disclose your policy on how to respond to requests from investee companies on how many shares you own/hold, and its website address (if disclosed):
• whether you disclose the stewardship activity reports, and its website address (if disclosed):

(Appendix 1)

Principles for Responsible Institutional Investors ≪Japan’s Stewardship Code≫ (English translation of the Revised Code)

(Appendix 2)

Revised Code with track changes from the previous version of the Code

(Appendix 3)

Revision of the Stewardship Code

(Appendix 4)

Summary of comments received at the public consultation process and FSA’s responses

Contact

Corporate Accounting and Disclosure Division, Policy and Markets Bureau, Financial Services Agency

Tel +81-(0)3-3506-6000 (Ex. 3849, 3624)