What Finfluencers Reveal About the Boundary Between Finance and Media

How the production, distribution, recommendation, and monetization of financial information are becoming increasingly fragmented across different actors.

In the previous edition of this newsletter, I considered why finance and media are moving closer together. My argument was that it is becoming increasingly valuable to engage with consumers during the information search and decision-making process that takes place before they choose a financial product.

As a continuation of that discussion, I would like to consider the role of influencers who discuss investing and asset management on social media—the people often referred to as “finfluencers.”

My question, however, is not simply whether finfluencers should or should not be subject to financial regulation. Nor, when I use the term “financial intermediation” here, am I arguing that the legal scope of Financial Instruments Business in Japan should be expanded. The question is a more functional one: who now performs the functions involved in producing information, comparing options, making recommendations, distributing content, and ultimately connecting consumers to financial transactions—and how do those functions shape the way people decide where to allocate their assets?

Looking Beyond the Question of “Who Should Be Regulated?”

In September 2026, a Japanese industry group focused on the future of financial education announced that they had begun developing a voluntary certification and support framework for finfluencers. The initiative is expected to include a code of conduct, training, and a certification badge, with a planned launch in April 2027. Importantly, the certification is not intended to guarantee the accuracy of individual posts or investment decisions. Rather, it is intended to recognize efforts to communicate financial information appropriately.

Similar questions are being considered outside Japan. IOSCO, the UK Financial Conduct Authority, and the European Securities and Markets Authority have all addressed issues surrounding financial information and influencers on social media. The FCA’s guidance, for example, did not create a new set of obligations specifically for social media. It clarified how the UK’s existing financial promotion framework applies when financial promotions are communicated through social media.

Japan, too, already has regulatory boundaries relevant to this discussion. The Financial Services Agency’s supervisory guidelines indicate circumstances in which providing investment information broadly to an unspecified number of people does not constitute Investment Advisory and Agency Business requiring registration. At the same time, the guidelines caution that registration may be required where information and communications technology is used to provide highly individualized or one-to-one investment information.

For that reason, I do not think it is sufficient to describe the issue simply as regulation failing to keep pace with the new world of social media. A more interesting question is how functions that existing frameworks have traditionally distinguished—such as information provision, advertising, investment advice, and solicitation—should be understood within a new information-distribution structure in which the party creating the information, the party determining who receives it, and the party monetizing it may all be different.

Is “Free” Financial Information Really Free?

Much of the financial information available on social media can be viewed without the user paying a fee at the point of consumption. But a zero price for the user does not mean no economic value is being created—or that no one is being compensated for providing or distributing the information.

A content creator may receive revenue from the platform itself. Compensation may also come from sponsors, advertising, affiliate arrangements, referrals, or other parties. The user’s attention, viewing time, and subsequent behavior may also be converted into economic value elsewhere.

A 2026 paper published in JSRI Financial Instruments and Exchange Act Studies by the Japan Securities Research Institute examines whether finfluencers who provide investment-related information free of charge could, under certain assumptions, fall within the scope of Investment Advisory Business. One of the paper’s arguments is that although platform revenue is formally paid by a third party, the economic value underlying that revenue may be traced to the attention of followers and other users.

This is an academic argument, not an official interpretation by Japan’s Financial Services Agency. The paper itself describes its analysis as introductory and subject to further research. Even so, the argument raises an important point: whether the user directly paid money may not, by itself, fully describe the economic relationships surrounding the production and distribution of financial information.

Of course, this economic structure is not unique to finance. But financial information differs from many other forms of content because the actions that follow may affect consumers’ own asset allocation and expose them to financial loss. That makes the relationship with existing institutional boundaries—such as advertising, recommendation, advice, and solicitation—particularly important.

The Person Creating the Information May Not Be the Person Delivering It

Another important feature of the current environment is that the “production” and “distribution” of information have become increasingly distinct functions.

There is nothing new about the provider of investment information being different from the party selling a financial product. That was true long before social media. What is more distinctive today is the role of the platform between them. Platforms can determine which information is displayed to which users based on factors such as viewing history and previous engagement, and can therefore perform an important distribution and amplification function.

The fact that different users see different content does not, by itself, mean that personalized investment advice is being provided as a matter of law. The point I find more significant is the functional separation: content may be produced for a broad audience while its distribution is nevertheless selective.

The creator produces the information. The platform distributes and amplifies it. Advertisers or financial firms may then connect the resulting awareness or engagement to referrals, customer acquisition, or transactions. From the consumer’s perspective, this can feel like one continuous information experience. Behind that experience, however, different actors perform different functions and may have different economic incentives.

The JSRI paper mentioned above also identifies algorithmic personalization and the interactive nature of social media as structural characteristics that distinguish social media platforms from traditional publishing and media.

Economic Value and Legal Responsibility Do Not Necessarily Align

Seen this way, the fundamental change is not simply that a new category of actor called the finfluencer has appeared.

The functions involved in producing information, attracting attention, establishing points of comparison, recommending, distributing and amplifying content, referring users, and ultimately selling financial products are increasingly divided among different actors. The places where economic value is generated—and the parties to which that value ultimately flows—are also becoming more dispersed.

That does not mean every party receiving an economic benefit should bear the same legal responsibility. Responsibility should depend on matters such as what each party actually did, how much control it had over the content or its distribution, what economic relationships or conflicts of interest existed, and which legal or regulatory framework applies.

Where economic value accrues and where legal responsibility sits are not determined by the same logic.

Still, if content creation, distribution, recommendation, monetization, and the pathway to a financial transaction are increasingly divided among multiple actors, it is worth asking whether existing boundaries of responsibility continue to reflect each actor’s actual role and incentives after those functions have been separated.

Rethinking the Boundaries of Financial Intermediation

Financial intermediation does not suddenly begin at the exact moment a financial product is sold. But neither does every conversation about investing become financial intermediation.

Between those two points lie a series of functions: producing information, providing comparisons, making recommendations, distributing content, and connecting users to transactions.

Who performs those functions? What do they control? What economic incentives do they have?

As financial information flows through an increasingly fragmented chain of actors, the central question may be less “Who else should be regulated?” and more “How should existing boundaries of responsibility apply to this new division of functions?”

Author: Keiichi Ohara, President & CEO, JAMP Corporation
About This Article
This article is an adapted English edition of JAMP Perspective No. 353, originally written in Japanese by Keiichi Ohara and distributed on October　7. It has been edited and supplemented where necessary to make the discussion and its Japan-specific context clearer to readers outside Japan. It is therefore not a direct translation of the original Japanese newsletter.

This article is provided for informational purposes only and does not constitute investment advice or a recommendation regarding any financial product.