抄録
Japan has been implementing and updating financial regulations on digital money ahead of other countries to address risks involved in various types of digital money, including refundable e-money, non-refundable e-money, stablecoin and cryptocurrency. This article firstly categorizes each type of digital money from the perspective of legal definitions of “prepaid payment instrument”, “fund transfer”, “electronic payment instrument” and “crypto-asset”. Secondly, this article illustrates how e-money users’ assets are protected by comparing each regulation on each type of digital money. Thirdly, based on such analysis, this article discusses whether such financial regulations for protecting users’ assets are appropriate enough and also well-balanced from the perspective of facilitating innovation and protecting users. Upon such discussion, the author views that regulations of protecting assets of non-refundable e-money users are too relaxed compared to the regulations applicable to other types of e-money. Meanwhile, the author views that regulations of protecting assets of electronic payment nstrument (a.k.a. fiat-backed stablecoin) users may be too strict and lack of balance to carry on businesses related to stablecoin in Japan.