Issues Regarding the Non-Disclosure of Representative Directors' Addresses

　Author's photo: Mitsutoshi Kato   Mitsutoshi Kato

In Japan's commercial registration system, the addresses of representative directors of corporations are, in principle, considered registered information. Consequently, these addresses are generally made publicly available. However, as of October 1, 2024 (Reiwa 6), they may be concealed upon request.

The primary goal of this measure is to protect the privacy of representatives. However, this does not mean that the representative's address can be omitted when submitting information to the Legal Affairs Bureau. Naturally, it is not permissible to register a fictitious person as a representative. The process involves submitting the representative's address to the bureau, having it officially registered, but rendering certain details undisclosed to the public.

For the purposes of this system, "representative directors" includes not only representative directors themselves but also representative executive officers and representative liquidators. The range of addresses subject to non-disclosure is limited to certain sections and not the entirety of the address.

Examples:

1. Tokyo, Minato Ward (non-disclosed) Roppongi, 1 Chome ~

2. Chiba, Kashiwa (non-disclosed) Kashiwa, 1 Chome ~

3. Kanagawa, Kawasaki City, Miyamae Ward (non-disclosed) Miyamae, 1 Chome ~

   
   

　The smallest administrative divisions, such as wards or cities, will still be displayed, but details beyond that—like town names, lot numbers, building names, and room numbers—will be concealed. Individuals with foreign addresses can also benefit from this measure, with the concealed portion of addresses aligned with Japan's administrative divisions.

Next is the timing of the request for non-disclosure. It may be submitted simultaneously with the registration of incorporation, updates to officers' registrations (including reappointments), and other relevant procedures. However, it is also possible to submit the non-disclosure request independently, without waiting for representative-related registration procedures. That said, standalone requests must be done via physical submission and cannot be completed online.

　Regarding the necessary documents for non-disclosure, a power of attorney for requesting judicial scrivener services is, of course, required. Additionally, concealing the representative's address might cause difficulties for stakeholders in contacting the company. Therefore, proof of the company’s existence and its location may be required. For non-public companies, such documentation may include evidence of the headquarters' physical presence, typically confirmed through certified postal mail by a judicial scrivener.

Finally, regarding foreigners using rental offices, non-disclosure measures are possible if the physical presence of the headquarters can be confirmed via certified mail. This means that as long as there is a dedicated company mailbox at the address, even a virtual office should suffice. Similarly, if the reception is staffed and can accept mail, this would also be considered acceptable.