This alert reviews the impact of the Government of Japan’s recent state of emergency declaration due to the coronavirus (COVID-19) global pandemic on the practices of the Kanto Local Finance Bureau, which has switched to rotating shift work resulting in the anticipation of longer filing times.

Based on Japan’s April 7, 2020, state of emergency declaration, the Kanto Local Finance Bureau (KLFB) switched to rotating shift work beginning April 8, 2020. Under this approach, only 25% of the KLFB’s officers are now working at KLFB offices, and certain types of filings will continue to be handled by an officer in charge on the relevant day.

Despite the emergency declaration, however, the KLFB again confirmed that it will only accept originals for all filings—and will not accept PDFs. Because of this policy, filings are anticipated to take more time to complete and filing parties should provide as much lead time as possible to ensure timely filings.

In practice, the KLFB continues to operate relatively smoothly, accepting filings and applications, and commenting on pending matters in a manner similar to its normal practices. The same is true for other Japanese government agencies viewed as “essential services” during the current emergency conditions in Tokyo, including the Ministry of Finance, Bank of Japan, and Financial Services Agency. 

This is our third alert in a series from Morgan Lewis’s investment management team in Tokyo that summarize how the COVID-19 pandemic has impacted investment fund-related businesses in Japan. For more, read our earlier alerts: COVID-19’s Impact on Notification Filings in Japan and COVID-19’s Impact on Annual Report Filing Requirements in Japan.

Coronavirus COVID-19 Task Force

For our clients, we have formed a multidisciplinary Coronavirus COVID-19 Task Force to help guide you through the broad scope of legal issues brought on by this public health challenge. We also have launched a resource page to help keep you on top of developments as they unfold.