The Realistic Baseline for 'Human Resource Requirements' You Must Understand If You Aim for Investment Advisory and Agency Business in Fiscal Year 2026

For businesses considering registration for investment advisory and agency services,
the most important and practically challenging aspect is the 'human resource requirements'.

Common misconceptions include:

• It is enough to just have the right job titles

• You can minimize staff by using outsourcing

• Personal investment experience will be evaluated

While these ideas exist, in actual screening,
the
substantive organizational structure—specifically 'who is responsible for which tasks and with what practical experience'—is scrutinized in detail.

Furthermore, the Financial Services Agency's supervisory guidelines and the screening practices of each local finance bureau
are fine-tuned almost every year.

Based on trends in fiscal year 2025,
fiscal year 2026 is expected to be a year where the 'quality of human resources' is questioned even more rigorouslythan before.

■ What this article covers (Fiscal Year 2026 perspective)

In this article, building on the basic requirements organized in the fiscal year 2025 version,

• Issues of increasing importance for fiscal year 2026

• Realistic challenges that small businesses are likely to face

• A profitability perspective on whether the structure can be maintained after registration

we will organize the
'Fiscal Year 2026 Approach to Human Resource Requirements'.

More detailed checklists and institutional background are explained in my blog post introduced later in this text,
but first, I hope you can grasp the
overall picture and judgment criteriathrough this note.

■ The direction of change for fiscal year 2026 as seen from the fiscal year 2025 version

The framework of human resource requirements itself has not changed significantly.
Practical experience of 'generally about 3 years' continues to be required for each position.

However, the following points are becoming more emphasized for fiscal year 2026.

① The relationship between cybersecurity/customer authentication and 'people'

In recent supervisory guidelines,

• Strengthening customer authentication

• Measures against unauthorized access

• Response structure for system failures

These points are clearly specified.

As a result,

• Who manages the system

• Who is the internal person in charge when using an external vendor

• What is the chain of command in the event of an incident

It has become important to be able to explain points such as in conjunction with the human resource composition.

In particular, if you are planning AI analysis, automated trading, or API integration,

the 'absence of a system manager' tends to become difficult to explain.

(2) 'Independence' and 'Full-time status' of Compliance and Internal Audit

For small-scale businesses,

• Compliance officer

• Internal audit officer

there are cases where the same person holds both positions.

Looking toward fiscal year 2026,

• Customer information management

• Fraud prevention

• Conflict of interest management

from perspectives such as these,
whether that dual-role structure is truly functioning is becoming more strictly scrutinized.

It is not enough to simply have titles on paper;
whether there is a system where check functions actually work is what is questioned.

③ Outsourcing is not a 'cure-all'

Since fiscal year 2025, the trend of
supplementing compliance and auditing through outsourcing has continued.

However,

• having absolutely no experienced staff in-house

• having external experts involved only in a formal capacity

The reality is that such structures are
difficult to evaluate as substantial human resource structures.

For fiscal year 2026, it will be important to be able to explain as concretely as possible a hybrid structure of 'in-house personnel + external experts'.

■ A realistic structural image that small-scale operators can adopt

In practice, one guideline that is relatively easy to get approved is the following composition.

• In-house financial industry experienced personnel: 2 or more people

  • Management (Administration/Supervision)

  • Advisory staff (Analysis/Judgment)

• Compliance/Auditing:

  • Collaboration between in-house staff and external experts

• System:

  • Utilization of external vendors + in-house management staff

Registration is possible even with a small team of 2-3 people, but

• the content of the services provided

• customer base (general investors/professionals)

• IT/system risks

depending on these,
there is a possibility that additional human resources will be required.

■ The balance with 'costs' that is often overlooked

Once you meet the human resource requirements, every year after registration,

• Personnel costs

• Outsourcing costs (compliance, audit, systems)

• Office and administrative expenses

Combined, it is not uncommon for
fixed costs of around 10 million yen per year to be incurred.

The important perspective is not "can I register?" but "can I maintain the structure after registration?"

If you consider human resources and your revenue model separately, the
risk of hitting a wall after registration increases.

■ The detailed checklist for the 2026 fiscal year is explained on the blog

In this note, I have focused on organizing the
approach and overall picture of human resource requirements for fiscal year 2026.

• Required experience for each position

• Feasibility and limitations of outsourcing

• Points that are easily evaluated in practice

The complete version, organized as a role-based checklist for the above, is explained in detail in the blog post below.

Note: This is structured as a practical document to help you judge whether registration is truly realistic for your company's structure.

■ Conclusion | Realistic preparation steps for fiscal year 2026

Looking ahead to the registration screening for fiscal year 2026,

• The basic line for human resource requirements will be maintained

• However, "substance," "independence," and "management systems" will be emphasized more

• Registration with a small number of people is possible, but the difficulty level is increasing year by year

This trend is expected to continue for some time.

If you are aiming for registration,

1. Clarification of service content

2. Design of human resource composition (internal + external)

3. Consistency check with the revenue model

Considering these three points as a set may seem like a detour, but it is the most reliable shortcut.

📘 Related note article

For those who are interested in this article, the following article is also recommended.

The following article is paid, but it provides practical content that answers a wide range of questions and concerns for those interested in the investment advisory and agency business.

✍ Operator Profile

Financial legal consultant. As a former administrative scrivener, I have a proven track record of supporting IFA registration and investment advisory and agency registration.
Currently, I provide information to practitioners interested in the financial business through my blog and note.
The Collect Financial Legal Consultant Office website focuses on providing information on licensing for investment advisory and agency businesses and IFA businesses.