Extension of Filing Deadlines for Disclosure Documents in Response to the COVID-19 Outbreak

Author: Takashi Tsukioka

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Publisher: Nagashima Ohno & Tsunematsu

Journal / Book: NO&T Japan Legal Update No.22 (May, 2020)

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*Please note that this newsletter is for informational purposes only and does not constitute legal advice. In addition, it is based on information as of its date of publication and does not reflect information after such date. In particular, please also note that preliminary reports in this newsletter may differ from current interpretations and practice depending on the nature of the report.

I. Introduction
In a response to the COVID‐19 outbreak, the Financial Services Agency (FSA), the Japanese governmental agency in charge of maintaining the stability of Japan’s financial system, announced an extension of the deadlines to file certain mandatory disclosure documents including annual securities reports. For those documents that were originally required to be filed between April 20 and September 29, 2020 based on Japanese securities regulations, issuers now can file them by September 30, 2020. This update explains this unprecedented measure taken by the Japanese authority in recognition of issuers’ difficulties in preparing their disclosure documents in light of the current COVID‐19 outbreak crisis.

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