FSA seeks comments on draft electronic disclosure system specifications

The Financial Services Agency (FSA) announced in the Official Gazette Extra (Government Procurement Notice Edition) dated October 19, 2026, a request for comments on two draft specifications for the Electronic Disclosure System (EDINET) regarding disclosure documents such as annual securities reports: one for design and development tasks and another for operational tasks. The deadline for submitting comments for both is November 9, 2026, at 17:00, and submissions by mail must arrive by this date. The certifying officer is Yoshitaka Wada, Director of the Secretariat Division of the Financial Services Agency.

The notices were published as No. 1 and No. 2 of the “Public Notice Regarding Request for Comments,” as separate procurement projects. Both clearly state, “The preparation of the draft specifications for the procured items has been completed, and we are requesting comments on the draft specifications,” with the item classification numbers listed as 71 and 27, the procurement agency number as 011, and the location number as 13. The period for delivery of the draft specifications is from October 19 to November 9, 2026, and the delivery location is the Procurement Section 1, Administration Office, Secretariat Division of the Financial Services Agency (Room 1212), 12th Floor, West Building, Central Government Building No. 7.

Simultaneous Request for Comments Split Between Design/Development and Operations

While both No. 1 and No. 2 target the same electronic disclosure system, they separate the nature of the tasks.

• No. 1: Design, development, and related tasks for the Electronic Disclosure System (EDINET) for disclosure documents such as annual securities reports — 1 set
• No. 2: Operation of the Electronic Disclosure System (EDINET) for disclosure documents such as annual securities reports — 1 set
• In the English notation, No. 1 is listed as “Design, development, and related tasks” and No. 2 as “Operation of the system,” both with a quantity of 1 set.
• The item classification numbers for both are 71 and 27, the procurement agency number is 011 (Financial Services Agency), and the location number is 13.

Submission Deadline is November 9 at 5:00 PM; Mail Must Arrive by Deadline

The method for submitting comments follows a common framework for both notices.

• Deadline for submission of comments: November 9, 2026, 17:00 (Must arrive by this date if sent by mail)
• Submission destination: Naoki Shiraishi, Procurement Section 1, Administration Office, Secretariat Division, Financial Services Agency, 12th Floor, Central Government Building No. 7, 3-2-1 Kasumigaseki, Chiyoda-ku, Tokyo 100-8967
• Contact: Tel 03-3506-6000 (Ext. 3131)
• Delivery period for draft specifications: October 19, 2026, to November 9, 2026

System Modification for Regulatory Changes to be Handled via Separate General Competitive Bidding

This request for comments is not the only procurement regarding the electronic disclosure system. In the Official Gazette Extra dated September 29, 2026, the FSA also published a bid notice for “system modification tasks accompanying regulatory changes, etc.” for the same system via general competitive bidding.

• Subject: System modification work for the Electronic Disclosure for Investors’ NETwork (EDINET) accompanying institutional reforms for disclosure documents such as Annual Securities Reports (Full Set)
• Contract Period: From the date of contract conclusion until March 31, 2027
• Bid Briefing: October 14, 2026 (Online meeting format)
• Bid Submission Deadline: December 3, 2026, 17:00; Bid Opening: December 4, 2026, 14:00
• Bidding procedures will utilize the Government Electronic Procurement System (GEPS), and in principle, bid opening will not be conducted via an in-person attendance method.

Impact of the Draft Specifications on Listed Companies and Disclosure Practitioners

EDINET is the infrastructure supporting statutory disclosures such as Annual Securities Reports and Large Shareholding Reports, and the contents of the draft specifications directly affect the preparation formats, submission procedures, and data formats of the submitted documents. Since both design/development and operations have simultaneously become subject to the request for comments, this provides an opportunity for personnel at listed companies and accounting/legal practitioners responsible for disclosure operations to provide input, including changes at the operational stage.

The request for comments is at the draft specification stage, and the contracting procedures will be left to future bidding. Nevertheless, the short submission deadline of November 9 at 17:00, with a requirement that mailed submissions must arrive by the deadline, poses a scheduling constraint for practitioners. As the draft specifications are distributed from October 19 to November 9, interested businesses and practitioners must review the contents within the distribution period and submit their opinions by the deadline.

Sources

• Official Gazette Extra (Government Procurement Notice Edition) dated October 19, 2026, Public Notice regarding Request for Comments No. 1 and No. 2 (Financial Services Agency, Procurement Agency Number 011, Location Number 13, Certifying Officer: Yoshitaka Wada, Director of the Secretariat Division, Financial Services Agency)
• Official Gazette Extra (Government Procurement Notice Edition) dated September 29, 2026, Bid Notice (Financial Services Agency, System modification work for the Electronic Disclosure for Investors’ NETwork (EDINET) accompanying institutional reforms for disclosure documents such as Annual Securities Reports)