[2025 Latest Edition] What are the "Human Resource Requirements" for Registering as an Investment Advisory and Agency Business?

—Considering the 3-year practical experience barrier, the use of outsourcing, and realistic options for small-scale businesses—

　I receive many inquiries daily from individuals or small groups who want to enter the financial industry and aim to register for an investment advisory and agency business. Among these, the content regarding "human resource composition required for registration" and "practical experience requirements" is of particularly high interest.

　In this article, I have reconstructed the essence of "[2025 Edition] Summary of Human Resource Requirements for Registering as an Investment Advisory and Agency Business," which was published on my professional blog, for note.

■ "People" are essential for investment advisory and agency business registration

　In the registration of an investment advisory and agency business, the hurdle for human resource composition is by no means low. In relevant laws and regulations, "substantial practical experience" is emphasized more than "formal titles".

Main personnel required for registration

• Management (Business Execution Manager)

• Analysis and Advisory Personnel

• Compliance Officer

• Internal Audit Personnel

• (Depending on operations) System Personnel

　In all cases, as a general rule, at least about 3 years of practical experience for each is basically required.

■ What is the "experience" specifically required?

● Management experience in the financial industry is emphasized for management

　It would be ideal to have experience as an executive at a former financial instruments business operator, but even for managers in other industries, it may be possible to supplement this through qualification acquisition or the construction of an external support system.

● "Actual advisory experience" is the key for advisory personnel

　In particular, 3 years of advisory and analysis experience regarding the financial products subject to advice is required. While it may be possible to substitute this with self-investment experience or qualifications, whether you can demonstrate business performance is the point of judgment.

■ Is it okay to "outsource" compliance and audit operations?

　This point is something to pay attention to, including recent legal developments.

● Compliance officers must have practical experience since 2007

Experience in compliance operations must be from September 30, 2007, or later (as the rules following the enforcement of the Financial Instruments and Exchange Act apply).

However, even if practical experience is insufficient, there is room for supplementary factors to be evaluated, such as experience as an attorney, holding a sales representative qualification, or having completed training.

■ Registration with a small number of people is possible, but be aware of two conditions

1. At least two people with practical experience in the financial industry are required

2. It is possible for one person to hold multiple roles, but risk management and a check system must be established

　For this reason, when aiming for registration with 2 to 3 people, how to combine practical experience becomes extremely important.

■ The reality of expenses: Fixed costs of at least 10 million yen per year

　Assuming a structure where you hire 1 to 2 employees while receiving support from external experts, it is not uncommon for costs to reach over 10 million yen per year. Furthermore, considering the recent rise in various expenses due to inflation, these costs are expected to increase even further.

If you want to start on a small scale,

• Balance between sales forecasts and costs

• Scope and cost of external support

• Selection of products for advice and associated risks

　calmly estimating factors such as theseis the key to success.

■ More detailed information is explained in this article

　The content introduced here is merely an overview. On my blog, I explain in more concrete detail the practical experience required for each person in charge, how to utilize external support, and recent institutional trends.

▶ [2025 Edition] Summary of Human Resource Requirements for Registering as an Investment Advisory and Agency Business
👉 You can view it here

■ Summary

　The decision to "register as an investment advisory and agency business" is not just a matter of procedure, but an important judgment involving the entire business model. Understanding human requirements, cost structures, and operational design thoroughly before taking the first step is the first step toward avoiding failure.

I hope this will be a helpful reference for those who are about to take on the challenge of the investment advisory industry.

Information on related note articles

Here is an introductory explanation that organizes "What can you do in the investment advisory and agency business?" It explains in an easy-to-understand manner based on practical experience, including specific tasks that become possible upon registration, four representative business models, and things you cannot do even after registration.
👉
What can you do with an investment advisory and agency registration? Explaining business content and business models [Introductory Edition]