Every Listed Japanese Bank, Measured

Hōwa Bank's foreign holders account for 0.00 percent of its shares. Minami-Nippon Bank, 0.04 percent. The Chikuho Bank, 0.32 percent. Miyazaki Taiyo Bank, 0.52 percent. Those are our own computations from the ownership tables in each bank's most recent annual securities report, taken from EDINET in XBRL, on a trading-unit basis, and they are the four lowest among the 83 listed Japanese banks in our set as of 29 July 2026. The three megabank groups, at 37.11, 41.63 and 37.13 percent, are nowhere near the bottom. The four have a second thing in common. None of them is listed on the Tokyo Stock Exchange. All four are listed on the Fukuoka Stock Exchange, and only there.

At the other end: Resona Holdings, 50.46 percent. That is higher than Mitsubishi UFJ Financial Group at 37.11 percent, higher than Sumitomo Mitsui Financial Group at 41.63 percent, higher than Mizuho Financial Group at 37.13 percent. The three largest groups average 38.62 percent, and their own high and low are 4.52 points apart, which is the kind of tidiness that usually means something and which here we simply record. Behind Resona: Sumitomo Mitsui Trust Group at 45.21 percent, and then a gap.

These are our numbers rather than anyone else's, so the rest of this is partly about how they were made. The population is every listed company EDINET classifies under the industry heading of banking that filed an annual securities report within the past 400 days. That is 83 companies, as of 29 July 2026. We obtained a ratio for all 83. The arithmetic check passed for all 83. There is no sampling here and no missing observation, and we are not claiming that is unusual, only that it is the case.

Construction, in order, so it can be checked. We pulled EDINET's document list for the past 400 days, kept document type code 120, the annual securities report, and kept filers carrying a securities code. Where a company had filed for more than one period, we took the later submission. That leaves 3,167 companies whose shareholder tables reconcile, with a median foreign ownership of 7.31 percent on a trading-unit basis as of 29 July 2026. From that set we kept the banks. EDINET states that its content may be used under the Public Data License, version 1.0, provided the source is cited, which is what this paragraph is doing.

The ratio itself comes from the shareholder-composition table in each filing, read from the XBRL rather than the PDF. Our numerator: units held by foreign corporations and other non-individual foreign holders, plus units held by foreign individuals. Our denominator: the table's own stated total. It is a unit basis. The check is that the table's seven categories sum to that total, and it is our main defense against a mistranscribed tag. Every bank in the population passed it, which is in part by construction, since the population is defined as filings that reconcile; read it as a property of the set rather than a discovery about banks. Listing venue comes from the exchange-name tag in the same filing, not from inference. We used no price data at all.

Now the rule. Article 436-4 of the Tokyo Stock Exchange's listing regulations, added with effect from 1 April 2025, says that when a Prime-market domestic listed company discloses certain corporate information in Japanese, it must disclose in English at the same time, unless doing so would delay the Japanese disclosure. We read it in a 17 December 2025 archived snapshot: the rule registry's authoritative name servers were unreachable on 29 July 2026, from two independent resolvers, and three snapshots across September and December 2025 hash identically.

A distinction that gets lost in summaries. Article 436-4 does not require the English to say the same thing. Its second paragraph states that disclosing a part or a summary of the Japanese content suffices, and the phrase "same content" appears in the article zero times. That phrase lives in the next subsection of the same section, in Article 445-8, which asks Prime-market domestic listed companies to endeavour, as far as possible, to disclose the same content in English at the same time as the Japanese, and which sits in the subsection of things that are desired rather than the subsection of things that must be complied with.

What the obligation covers is a list of article numbers: 402 and 403, 404 paragraphs 1 and 2, 405, 408, 408-3 through 411, 415 paragraph 3, plus information a company voluntarily puts through TDnet. By the article headings: corporate information disclosure, subsidiary-company information, earnings reports for the year and for quarters, revisions to forecasts, plans for meeting listing-maintenance criteria, internal control status, reductions in investment unit, MSCB conversions, controlling-shareholder matters, and responses to exchange inquiries. Reduce that list to two buckets and most of it goes missing. The phrase "annual securities report" appears in Article 436-4 zero times. The exchange's own materials describe expanding the covered documents, securities reports named explicitly, as under continued consideration.

The exchange has also been unusually direct about what the English is for. Disclosing only the summary information of an earnings report, it says, does not constitute a rule violation, though where one Japanese document covers several disclosure items the English must cover them all, and disclosing only some of the items is not permitted. There is no uniform standard for how much of a summary is enough; companies are told to consider it in light of dialogue with overseas investors. Having disclosed a summary at the same time, a company is not later required to produce the full text. And the English is positioned as a reference translation, with its accuracy placed outside the scope of measures for rule violations. PR material and shareholder-meeting notices are optional.

There was a grace mechanism, and it has closed. A company already listed on Prime before the rule took effect on 1 April 2025 could file a form with the exchange between 6 January and 14 March 2025, stating when it intended to start, and have the obligation deferred until 31 March 2026, which is to say to disclosures made on or after 1 April 2026. That date has passed. The exchange published the list of the companies that took the deferral, 114 of them, on 25 March 2025, and the page was still up on 26 March 2026. It is not up now: the address returns a 404 and no longer appears in the exchange's sitemap or its navigation, and we read the list in an archived snapshot taken on 26 March 2026. Whatever the current state of English disclosure among Prime-listed companies is, it is now the steady state of the rule rather than a transition. The exchange publishes the listing regulations themselves in English too, 302 pages in the version as of 21 July 2026, with a line at the front saying that the English version is not an official translation.

Outside all of this sits the annual securities report, the document every number in this piece comes from. The Financial Services Agency's note on it is one sentence and leaves nothing to interpret: translating the securities report into English is not an obligation under the Financial Instruments and Exchange Act, and is done at the filer's discretion. The agency's contribution is a list, published on EDINET, of companies that post English versions on their own websites, created on a recommendation that translation be encouraged. Encouraged is the operative word.

Banking law does not close the gap here either, meaning Article 21 and the ordinance under it. Article 21 requires banks to prepare explanatory documents on their business and assets, keep them at their branches and make them available for public inspection, with the contents specified by cabinet office ordinance. Across all seven paragraphs, the words Japanese, English, language and translation appear zero times. The ordinance that fills in the contents is the same, at least in the provisions that set out what must be stated, though some line items are delegated further to agency notices we have not checked. The one language rule in the vicinity runs the other direction: the Japanese branch of a foreign bank must prepare, keep at the branch and make available for public inspection a document written in Japanese covering three things, the outline of its business, its balance sheet and its profit and loss statement, the interim versions included. Not a summary of the foreign-language originals. Three named documents, produced in Japanese.

The Banking Act does contain the phrase "in Japanese or English," once, in Article 52-2-6, about documents a foreign bank agency bank keeps for inspection on behalf of its principal foreign bank. Once in 218,819 characters, that being our count of the version in force as e-Gov serves it, whitespace removed, supplementary provisions included, as of 29 July 2026; 150,234 characters if the supplementary provisions come out and only the main provisions are counted. The implementing ordinance behaves the same way, specifying language where it means to and staying silent where it does not. This is a fact about how the statutes are written. Whether the silence in Article 21 is deliberate is a question for lawyers, and we are not going to answer it here.

So the frame is this. Of the 83 banks, our reading of the exchange-name tags puts 69 on Prime, 10 on Standard and 4 on Fukuoka only. Article 436-4 names Prime-market domestic listed companies as its addressee; the other market segments fall outside by that limitation rather than by express exclusion. What the rule reaches, in any case, is the enumerated list above, centred on earnings reports and timely disclosure including voluntary filings through TDnet. The annual securities report is not on the list, and translating it is not an obligation under the Financial Instruments and Exchange Act, which the Financial Services Agency states in terms. All 83 banks file one. The document with the shareholder table in it is the document the rulebook does not reach. Then you look at the shareholder tables.

Excluding the three megabank groups, the remaining 80 banks have, in our tabulation, a median foreign ownership of 15.07 percent and a mean of 15.65 percent as of 29 July 2026. The minimum is 0 percent and the maximum is 50.46 percent. That is a spread of just over fifty points among companies in the same industry classification, filing on the same form, under the same supervisory authority. It is not the work of a handful of outliers, and the buckets are how you can tell.

The shape, then. Of the 80, six are above 30 percent. Twenty-three are above 20 percent. Fifty-seven are above 10 percent. Thirteen are below 5 percent. Four are below 1 percent. So the middle of this industry is a bank with roughly one share in seven held from abroad, the top of it is a bank with one in two, and the bottom of it is a bank with one in a hundred or fewer. All three of those banks file the same form, under the same supervisory authority.

Excluding the three megabank groups again, our tabulation puts the upper end at: Resona Holdings 50.46, Sumitomo Mitsui Trust Group 45.21, Yokohama Financial Group 34.09, Rakuten Bank 33.67, Mebuki Financial Group 31.74, Kyoto Financial Group 31.2, Hokuhoku Financial Group 28.6, Suruga Bank 28.05, Fukuoka Financial Group 27.84, Nishi-Nippon Financial Holdings 27.35. All ten are Prime-listed. Put the megabank groups back in, at 41.63, 37.13 and 37.11, and they land in the middle of that list rather than at the top of it.

The lower end, in order: Kochi Bank 3.39, Tottori Bank 2.62, Shimane Bank 1.91, Jimoto Holdings 1.75, Toyama Bank 1.39, Fukushima Bank 1.32, Miyazaki Taiyo 0.52, Chikuho 0.32, Minami-Nippon 0.04, Hōwa 0.00. Six of those are Standard-listed and four are on Fukuoka. To be precise about what this list is: it is a description of who holds the shares. It is not a measure of anything else about these banks, and it should not be read as one.

What the Fukuoka Stock Exchange publishes as its listing regulations is a compilation of eight documents running to 90 pages. The regulations proper and the handling notes end at printed page 64; special rules for restructuring and disaster-hit issuers, the fee schedule and the rest fill the remainder. The characters for "English text" appear zero times anywhere in it, on our count, and the word English appears only in provisions on the language in which a foreign-incorporated issuer submits documents to the exchange, with the handling notes then specifying that timely disclosure materials are among the documents the exchange requires in Japanese. The one English-disclosure sentence in the vicinity is not in the regulations at all but in the corporate governance code, on a comply-or-explain basis, addressed to Prime-market companies. Fukuoka does have a rule about English, though, and where it sits is the point. The exchange runs three markets: the Main Market, Q-Board, and Fukuoka PRO Market, which opened on 16 December 2024. Article 105 of the special enforcement rules for the PRO Market, headed language used in materials, requires a listed company or an applicant preparing disclosure materials to prepare them in English or Japanese or both, and the exchange's guide book for that market sets it out in a table: disclosure language, Fukuoka PRO Market, Japanese or English; Fukuoka's other markets, Japanese. English on its own is permitted on one Fukuoka market, the one for professional investors. Reading the security-by-security list in the exchange's own monthly summary of listed securities for June 2026, all four banks are on the Main Market, and each is listed there and nowhere else.

Nagoya's Securities Listing Regulations, 92 pages: "English text" zero times, "English" four times, three of them about documents submitted to the exchange and the fourth inside the corporate governance code appended at printed page 73, where it is the supplementary principle recommending English disclosure rather than anything about what the exchange will accept. That count is for the regulations themselves. The enforcement rules under them, 172 pages, use "English text" twice, both in Article 101, which gives the English names of Nagoya's three segments, Premier, Main and Next. Sapporo's, 63 pages: "English text" zero, "English" zero, the single character for English zero, and "Japanese," "language" and "translation" zero as well, and zero again across the five other rule sets we checked, the timely disclosure rules among them. Sapporo's regulations do not specify a disclosure language at all. The counts, on the dates each exchange publishes them: Fukuoka 135 listed companies at end-June 2026, 28 of them nowhere else, split 97, 22 and 16 across the Main Market, Q-Board and the PRO Market; Nagoya 314 and 60 on 29 July; Sapporo 16 sole-listed on 29 July; Tokyo's Prime market 1,553 at end-June.

What we have measured is a correlation, across four companies, between the perimeter of one exchange's rulebook and the bottom of a distribution. Four is four. We did not measure which way it runs, and there is a version of the story in each direction, plus a version in which some third thing produces both. Nothing in the shareholder tables distinguishes between them, and nothing in the regulations does either. The correlation is in the data. The causation is not, and we are not going to supply it.

One footnote, quietly. The Financial Services Agency's Regional Finance Strengthening Plan, published 19 December 2025, contains a sentence saying that because constructive dialogue with a diverse set of investors is beneficial, the agency will go on following up on shareholder composition and the state of investor dialogue at regional banks. In the plan's 23 pages the word "investor" appears three times on our count: twice standing alone, and once inside "institutional investors," in a line about regional banks not readily becoming investment targets for them. "Shareholder composition" appears once. The plan carries no figures, no tables and no sources on either. The sentence is not in the working group report the plan followed by one day.