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Introduction
On August 26, 2025, the Ministry of Justice commenced a public comment period on the Proposed Ministerial Ordinance to Amend Part of the Ordinance for Establishing the Criteria Pursuant to Article 7, Paragraph 1, Item 2 of the Immigration Control and Refugee Recognition Act.
Earlier reports suggested that the "Business Manager" visa would become subject to heightened requirements, including an increase in the minimum capital from JPY 5 million to JPY 30 million and the mandatory employment of at least one full-time employee. The newly released draft, however, introduces even more rigorous criteria.
Although the proposal is currently under public review, the enforcement date is anticipated for mid-October 2025, leaving little time before implementation. This summary outlines the principal revisions contained in the proposal.
Revisions to the Screening Criteria Ordinance
The proposed amendments to the Ordinance for Establishing the Criteria Pursuant to Article 7, Paragraph 1, Item 2 of the Immigration Control and Refugee Recognition Act, which governs eligibility for the "Business Manager" visa, are as follows:
1. Business Scale Requirements
[Current] The business must satisfy one of the following conditions:
- (a) Employ at least two full-time employees residing in Japan, in addition to the individual engaged in management or administration.
- (b) Maintain paid-in capital or total investment of JPY 5 million or more.
- (c) Be recognized as operating at a scale equivalent to (a) or (b).
[Proposed] The business must satisfy both of the following conditions:
- (a) Employ at least one full-time employee.
- (b) Maintain paid-in capital or total investment of JPY 30 million or more.
This amendment both increases the capital requirement sixfold (from JPY 5 million to JPY 30 million) and imposes a mandatory employment condition.
2. Educational Background or Work Experience of Business Managers
- (a) The applicant must hold a Ph.D., Master’s, or other professional degree in business management or a discipline requiring technical expertise relevant to the proposed business.
- ((b) Where the applicant serves as a manager, they must possess at least three years of experience in business management or administration. Periods spent in Japan under the “Designated Activities” visa status (pursuant to Article 7, Paragraph 1, Item 2) for preparatory business activities, such as securing office premises, will be counted toward this requirement.
Currently, only individuals in administrative positions are required to demonstrate practical experience, while representative directors and other managers are exempt. Under the revision, managers will also be required to evidence either appropriate academic qualifications or equivalent practical experience.
3. Revisions to Required Documents
The documentation requirements for visa applications will also be amended as follows:
1. Professional Evaluation of Business Plan
Applicants for a Certificate of Eligibility or Change of Status of Residence will be required to submit a business plan reviewed by an individual with professional expertise in business management. While the definition of “professional expertise” has not yet been finalized, it is anticipated to include certified public accountants and licensed small and medium enterprise management consultants. At present, only Category 3 and Category 4 companies are subject to this requirement.
2. Evidence of Business Scale
[Current] Applicants must provide one of the following:
- (a) Documentation evidencing the number of full-time employees (excluding the foreign national). Where two or more employees are engaged, payroll records and copies of residence certificates, residence cards, or special permanent resident certificates must also be submitted.
- (b) Documentation evidencing the amount of paid-in capital or total investment.
- (c) Other documents demonstrating the scale of operations.
[Proposed] Applicants must provide both of the following:
- (a) Documentation evidencing the number of full-time employees (excluding the foreign national), together with payroll records and copies of residence certificates, residence cards, or special permanent resident certificates.
- (b) Documentation evidencing the amount of paid-in capital or total investment.
3. Evidence of Education or Professional Experience
All applicants—regardless of whether they serve in a management or administrative capacity must submit documentation verifying their degree or professional experience.
4. Extension of Period of Stay
The evidentiary requirements for applications to extend the period of stay will also be revised.
[Current] Applicants must provide one of the following:
- (a) Documentation evidencing the number of full-time employees (excluding the foreign national). Where two or more employees are engaged, payroll records and copies of residence certificates, residence cards, or special permanent resident certificates must also be submitted.
- (b) Documentation evidencing the amount of paid-in capital or total investment.
- (c) Other documents demonstrating the scale of operations.
[Proposed] Applicants must provide both of the following:
- (a) Documentation evidencing the number of full-time employees (excluding the foreign national), together with payroll records and copies of residence certificates, residence cards, or special permanent resident certificates.
- (b) Documentation evidencing the amount of paid-in capital or total investment.
4. Conclusion
The proposed amendments represent a significant tightening of the eligibility requirements for the "Business Manager" visa. At present, it remains unclear whether these new criteria will be applied retroactively to extension applications for individuals already granted the visa under the current standards.
Going forward, establishing a new enterprise in Japan with the aim of obtaining a "Business Manager" visa will require coordinated support from multiple professionals, including: a judicial scrivener for corporate registration, an administrative scrivener for immigration procedures, and a certified public accountant or SME consultant for business plan evaluation.
Our firm is well-positioned to provide all of these services on a one-stop basis. Please do not hesitate to contact us with any questions or specific requirements.
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