TOKYO (Reuters) - Japan's ministry of finance is gauging the appetite of the country's major banks to lend to the government at negative interest rates, people with direct knowledge of the matter said.

The government is asking lenders about the possibility of submitting tender offers with negative rates at the ministry's short-term special accounts borrowing program auctions, according to the sources, who were not authorized to discuss the matter publicly.

In addition to issuing bonds, the ministry raises trillions of yen every year through direct borrowing from banks for short-term financing for special accounts that subsidize programs such as municipal spending, energy projects and state-owned forest projects. Banks, brokerages and insurance companies participate in such tenders.

An official at the ministry's financial bureau, who declined to be named, said the ministry is surveying lenders about lending terms at these tenders, but declined to comment further.

Since the Bank of Japan introduced the negative rates policy in January, the commercial banking industry has resisted lending to private-sector borrowers at negative rates, even after the BOJ started imposing negative rates on the excess reserves lenders park with the central bank.

"We are asking clients to agree to a 'zero floor' on interest rates, so we cannot lend to the government with negative rates," said an official at one of the top three banks, who did not want to be named.

The government's approach to lenders comes after the BOJ's aggressive monetary policy drove yields down to below zero for most of the Japanese government bonds traded in the market.

The Financial Law Board, an independent panel of financial law experts in Japan, has said lenders bear no obligation to pay interest to borrowers unless specified in contracts.

Deposit Insurance Corp of Japan, a government-backed entity, last month raised 96 billion yen ($890 million) with a zero percent interest rate through a tender offer.

(Reporting by Taro Fuse, Sumio Ito, Taiga Uranaka; Editing by Sam Holmes)