⚠ The Cartel and the Improvement OrdersModerate threat

Tokio Marine Holdings (8766) — threat to the moat

Japan's regulators found the country's non-life insurers fixing prices, and Tokio Marine is one of them.

In December 2023 Japan's Financial Services Agency issued Tokio Marine & Nichido a business improvement order over premium-fixing, and in March 2025 a second order over an information leakage incident1. In October 2024 the Japan Fair Trade Commission issued cease and desist orders and surcharge payment orders against non-life insurers, including Tokio Marine & Nichido, for fixing prices on corporate policies2.

Regulatory actionsDec 2023FSA improvementorder: premium-fixingOct 2024JFTC cease and desistand surcharge ordersMar 2025FSA improvementorder: informationleakageAug 2025report order forthe life companyTokio Marine IR conference, May 2026; JFTC
Four regulatory actions in under two years.

The orders go to the heart of the moat. An oligopoly that coordinates prices is earning its margin from coordination, not from skill. The regulators' response has been to force the companies to compete harder and to unwind the relationships that supported the arrangements.

Tokio Marine's remedies are extensive: it committed to reduce its strategic shareholdings in client companies to zero, and by the end of September 2024, 92.3% of agents and 90.3% of policy owners had agreed to dissolve excessive-cooperation arrangements3. In August 2025 its life company received a report submission order on its relationships with multi-agency brokers4.

The orders have a cost beyond reputation. Unwinding the relationships took time and management attention, and the company's Japanese P&C profit on the business-unit measure fell to ¥99.1 billion in the year to March 2024 before recovering to ¥171.2 billion in 20265.

The measure is the Japanese combined ratio after the changes. Holding below the market average with less coordination would show the underwriting advantage is real.

References
  1. ReportedIn December 2023 Japan's Financial Services Agency issued Tokio Marine & Nichido a business improvement order over premium-fixing, and in March 2025 a second order over an information leakage incident.
    Tokio Marine Holdings, Group Business Strategy IR conference, 26 May 2026 - Japan P&C: market share, combined ratios, auto insurance, premiums, sales channels and the regulatory orders. — 2016-2026 · publ. 26 May 2026 · source ↗
  2. ReportedIn October 2024 the Japan Fair Trade Commission issued cease and desist orders and surcharge payment orders against non-life insurers, including Tokio Marine & Nichido, for fixing prices on corporate policies.
    Japan Fair Trade Commission, 31 October 2024 - cease and desist orders and surcharge payment orders against non-life insurance companies for price-fixing. — October 2024 · publ. 31 October 2024 · source ↗
  3. ReportedTokio Marine's remedies are extensive: it committed to reduce its strategic shareholdings in client companies to zero, and by the end of September 2024, 92.3% of agents and 90.3% of policy owners had agreed to dissolve excessive-cooperation arrangements.
    Tokio Marine Holdings, Business Strategy IR conference, May 2025 - progress on dissolving excessive-cooperation arrangements after the business improvement order. — 2024-2025 · publ. May 2025 · source ↗
  4. ReportedIn August 2025 its life company received a report submission order on its relationships with multi-agency brokers.
    Tokio Marine Holdings, Group Business Strategy IR conference, 26 May 2026 - Japan P&C: market share, combined ratios, auto insurance, premiums, sales channels and the regulatory orders. — 2016-2026 · publ. 26 May 2026 · source ↗
  5. ReportedUnwinding the relationships took time and management attention, and the company's Japanese P&C profit on the business-unit measure fell to ¥99.1 billion in the year to March 2024 before recovering to ¥171.2 billion in 2026.
    Tokio Marine Holdings, Group Business Strategy IR conference, 26 May 2026 - Japan P&C: market share, combined ratios, auto insurance, premiums, sales channels and the regulatory orders. — 2016-2026 · publ. 26 May 2026 · source ↗
Sources
Generated September 24, 2026