The Japan Financial Services Agency published minutes from the third meeting of its Study Group for the Advancement of Corporate Risk Management, which reviewed a draft report and its summary and exchanged views on how corporate risk management and insurance-based risk transfer are working in practice. Discussion on revising the draft report focused on clarifying the role of internal agents in global programmes, reflecting the reality that risks can remain in captives when reinsurance is not obtainable due to limited underwriting information and insufficient disaster-prevention measures, and positioning overseas risk transfer methods as limited and secondary to mainstream insurance structuring. Members also noted gaps in how Japanese firms link enterprise risk management to insurance decisions, underwriting frictions with foreign non-life insurers tied to data availability and differences in risk standards (including factory protection equipment), and the growing relevance of overseas direct insurance and captives amid constrained domestic underwriting capacity. On disclosure, participants cautioned that more formalised risk disclosures could confuse investors given wide differences in company risk profiles and non-comparability of figures such as premiums across varying terms, while stressing dialogue on how risks are integrated into strategy. Views were also raised that policy responses could be accelerated through guideline revisions rather than legislative change, alongside urgent operational fixes in areas such as intermediary fee payments and duplicated costs in captive-based global insurance programmes.
Japan Financial Services Agency 2026-04-17
Japan Financial Services Agency publishes minutes of corporate risk management study group discussing draft report revisions and the use of captives
Japan’s Financial Services Agency released minutes from the third meeting of its Study Group for the Advancement of Corporate Risk Management, which reviewed a draft report on corporate risk management and insurance-based risk transfer. Members discussed clarifying internal agents’ roles in global programmes, the limited role of overseas risk transfer, gaps in how Japanese firms link enterprise risk management to insurance decisions, and frictions with foreign non-life insurers. They also raised concerns over the comparability of formalised risk disclosures and urged prioritising guideline revisions and operational fixes—such as intermediary fee payments and duplicated costs in captive-based global insurance programmes—over legislative change.