Effective date: October 16, 2025 (Thu).
Japan’s Immigration Services Agency (ISA) has amended the Ministerial Ordinance (landing requirements) and the Enforcement Regulations for the “Business Manager” status of residence. This article distills the official guideline into practical steps for founders and companies.
At a glance
Hire at least 1 full-time employee (must be: Japanese, Special Permanent Resident, or a foreign national with a Table II status: “Permanent Resident,” “Spouse/Child of Japanese National,” “Spouse/Child of Permanent Resident,” or “Long-Term Resident”). Those with Table I work/student statuses do not count as “full-time” for this requirement.
Capital/Scale: ¥30 million or more.
Corporations: paid-in capital (K.K.) or total contributions (G.K./Gomei/Goshi).
Sole proprietors: total actually invested for office securing, one year of payroll for employees, equipment, etc.
Japanese proficiency: B2 or higher (per “Japanese Language Education Reference Framework”) held by either the applicant or the full-time employee (e.g., JLPT N2, BJT ≥400, Japanese education credentials, or 20+ years residence).
Background: a master’s/professional/doctoral degree in a relevant field or 3+ years of management/administration experience (the startup-preparation “Designated Activities (No.51)” period counts).
Business plan: must be verified by an expert (SME Management Consultant, CPA, or Licensed Tax Accountant). Note: except for attorneys/administrative scriveners, others may not draft application documents for a fee (Administrative Scrivener Act risk).
Office: home-office is, in principle, not allowed. Secure an office appropriate to the new scale.
Transition (updates): until Oct 16, 2028, updates may be approved on a holistic basis even if you haven’t met all new standards yet; after that, you must meet the new standards.
Permanent Residency/HSFP impact: if you don’t meet the new Business Manager standards after the effective date, PR and HSFP 1(h)→2 based on Business Manager won’t be approved.
- 1 1) What exactly changed?
- 2 2) Japanese B2—How to prove it
- 3 3) Expert-verified business plan
- 4 4) Treatment of applications, renewals, and during stay
- 5 5) Transition rules & “last-minute” filings
- 6 6) Practical compliance checklist (save this)
- 7 7) Frequently asked questions (condensed)
- 8 8) Forms & templates (after Oct 16, 2025)
- 9 9) Bottom line
- 10 💼 Need Expert Support?
- 11 📩 Contact (General Inquiries & Communication)
1) What exactly changed?
| Area | Before | After (from Oct 16, 2025) |
|---|---|---|
| Full-time staff | Alternative/looser | Mandatory: 1 full-time employee (Japanese, SPR, or Table-II status foreign national only) |
| Capital / Scale | Often “¥5M” benchmark | ¥30,000,000+ total (see corporate vs. sole proprietor definitions above) |
| Japanese | No uniform bar | B2+ held by applicant or the full-time hire (e.g., JLPT N2, BJT ≥400, Japanese schooling, 20+ yrs residence) |
| Degree/Experience | Considered in practice | Master/Professional/Doctoral degree (or foreign equivalent) or 3+ years management experience (incl. “No.51” startup-prep period) |
| Business Plan | Often formal check | Expert verification required (SME Consultant, CPA, Tax Accountant) |
| Office | Sometimes permissive | Home-office = in principle not allowed; secure a suitable premises |
2) Japanese B2—How to prove it
Who needs B2?
Either the applicant or the full-time employee must have B2-level Japanese ability.
(Japanese nationals and Special Permanent Residents are exempt.)
✅ Acceptable proof examples:
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JLPT N2 or higher certificate
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BJT score of 400+
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20+ years as a mid- to long-term resident in Japan
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Graduation from a Japanese university
(or completion of compulsory education + high school in Japan)
In the application form, clearly state who satisfies the B2 requirement and how,
for example:
“Full-time Japanese employee employed; JLPT N2 certificate attached.”
💡 Important note:
When it comes to Japanese language ability,
the term “full-time employee” also includes foreigners with a Status of Residence under Table 1,
such as holders of Engineer/Specialist in Humanities/International Services (技術・人文知識・国際業務),
in addition to Japanese nationals or permanent residents.
In contrast, for the employment requirement itself,
the full-time employee must be a Japanese national, Special Permanent Resident,
or a foreigner under Table 2 (e.g., Permanent Resident, Spouse of Japanese National, Long-Term Resident).
“Japanese Language Requirement for the Business Manager Visa – Why JLPT N2 Matters.”
3) Expert-verified business plan
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Who counts as “expert”? At implementation: SME Management Consultant, Certified Public Accountant, or Licensed Tax Accountant. (Future changes may be announced by ISA.)
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Compliance tip: Except for attorneys and administrative scriveners, others must not prepare application documents for a fee (risk of violating the Administrative Scrivener Act). Keep roles clearly separated: expert verifies feasibility; scrivener/attorney handles application drafting/submission.
4) Treatment of applications, renewals, and during stay
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Economic substance: If your activities look like outsourced contracting without real executive control, you won’t be treated as engaging in “Business Manager” activities.
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Office: Home-office is, in principle, not accepted; the office must match the enlarged business scale.
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Long absence: Unjustified long stays abroad during your period of stay can cause renewal denials.
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Taxes/insurances at renewal: ISA will check labor insurance (EI/Workers’ Comp enrollment & premium payment), social insurance (health/pension enrollment & payment), and due national/local taxes (corporate or personal, as applicable).
-
Regulatory licenses: If licenses can only be obtained after you get the status, submit a reason letter now and show the license at the next renewal.
5) Transition rules & “last-minute” filings
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Filed before Oct 16, 2025: applications (CoE/renewal/status change) continue under old standards.
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But: after Oct 16, 2028, renewals must meet the new standards.
-
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Renewals filed up to Oct 16, 2028: even if you don’t fully meet the new standards, ISA may holistically assess your business status and prospects (they may ask for an expert-evaluated document).
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From Designated Activities (No.51) → Business Manager:-
If you applied for/hold No.51 before Oct 16, 2025 → at status change you can use old standards. -
If you apply for No.51 on/after Oct 16, 2025 → at status change to Business Manager you must meet the new standards.
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✅ Updated Text (as of Oct 16, 2025)
From Designated Activities → Business Manager (Updated Rules as of Oct 16, 2025)
1. From Designated Activities (No.44 – Startup Visa Program):
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If your Confirmation Certificate for Startup Activities was issued before the enforcement date of the amended notice,
the old criteria (pre-amendment standards) will apply when you apply to change your status to Business Manager. -
If your Confirmation Certificate was issued on or after the enforcement date,
the new criteria (post-amendment standards) will apply at the time of your Business Manager status change.
2. From Designated Activities (No.51 – Future Creation Human Resources / Startup Preparation):
-
If, as of the day before the enforcement date (Oct 15, 2025),
you have already applied for or currently hold the Designated Activities (No.51) status,
then the old criteria will apply when changing your status to Business Manager. -
If you apply for the No.51 status on or after Oct 16, 2025,
then the new criteria will apply at the time of your Business Manager status change.
6) Practical compliance checklist (save this)
Capital/Scale
Corporation: Paid-in capital / total contributions ≥ ¥30M (verify via Certificate of Registered Matters)
Sole proprietor: Evidence of actually invested total ≥ ¥30M (office, 1 year of payroll, equipment, etc.; collect contracts, receipts, wire records)
People
1 full-time employee hired (Japanese/SPR/Table-II foreign national), with employment contract and social insurance enrollment complete
Language
B2 Japanese held by the applicant or the full-time employee; attach the certificate/records and state it explicitly in the form
Background
Master/Professional/Doctoral (or equivalent) or 3+ years management experience (count No.51 prep period); attach objective evidence
Business Plan
Expert verification by SME Consultant/CPA/Tax Accountant—opinion attached (specific, reasonable, feasible)
Office
Lease a dedicated office appropriate to the new scale (home-office not acceptable in principle)
Public dues
Labor insurance, Social insurance, National & Local taxes—enrolled and paid; file copies ready for renewal
7) Frequently asked questions (condensed)
Q1. Who counts as the “full-time employee” for the mandatory hire?
Under the new standard, your mandatory full-time employee must be either:
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a Japanese national, or
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a Special Permanent Resident, or
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a foreign national with a Table-II status:
“Permanent Resident,” “Spouse or Child of Japanese National,” “Spouse or Child of Permanent Resident,” or “Long-Term Resident.”
⚠️ Foreigners with Table-I working visas (e.g. Engineer/Specialist in Humanities/International Services, Intra-company Transferee, Skilled Labor, etc.) do not count for the employment requirement itself.
Q2. I’m confused: sometimes it says Table-I foreigners “do not count”, and sometimes they “are included” as full-time staff. Which is correct?
The key is to separate two different requirements:
-
Mandatory full-time employee for “employment” requirement
→ Must be Japanese, Special Permanent Resident, or Table-II foreigner.
→ Table-I foreigners do not count for this part. -
B2 Japanese language requirement
→ Can be met by either the applicant or a full-time employee, and here a Table-I foreigner can also be the person who proves B2 (JLPT N2, BJT 400+, Japanese schooling, long residence, etc.).
So for example:
-
✅ OK: You hire one Long-Term Resident (Table-II, with proof of Japanese ability) as the mandatory full-time staff.
-
✅ OK: You hire one Long-Term Resident (no N2) and one Engineer/Specialist in Humanities (with N2).
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The Long-Term Resident satisfies the employment requirement.
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The Table-I Engineer satisfies the B2 Japanese requirement.
-
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❌ Not OK: Only a Table-I employee with N2, and no Japanese/SPR/Table-II staff.
-
❌ Not OK: Only a Table-II employee, but with no proof of B2 Japanese for anyone.
Q3. What exactly is a “full-time employee” under this reform?
ISA will judge “full-time” based on overall working conditions, especially:
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The employee is scheduled to work every business day (except holidays, etc.) under a regular work schedule.
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Appropriate salary and benefits are set for the position.
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Compared with part-timers, the employee typically:
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works 5+ days per week and 217+ days per year,
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works 30+ hours per week,
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is covered by Employment Insurance and meets the 30-hours rule,
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is given at least 10 days of paid annual leave after 6 months of continuous work with 80%+ attendance.
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Also, workers dispatched from another company or working under secondment/dispatch/outsourcing contracts are not treated as “full-time employees” of your company for this standard.
Q4. If I have several full-time employees, do I have to submit documents for all of them?
No. You do not need to submit every employee’s documents.
Immigration just needs to confirm that at least one full-time employee satisfies the new standard (status + working conditions + Japanese ability if necessary).
Q5. How is the ¥30M “business scale” checked for corporations?
For corporations, immigration mainly checks the paid-in capital / total investment using:
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the commercial registry (登記事項証明書), and
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financial statements and other company documents.
For a corporation, the relevant amount is:
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for a joint-stock company (Kabushiki Kaisha): the paid-in capital, or
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for a partnership / LLC (Gomei, Goshi, Goudou): the total amount of investment.
⚠️ Important:
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Items like capital reserve, capital surplus, retained earnings are not counted in the “business scale” amount.
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You cannot “add” yearly salaries or office running costs to capital in order to reach ¥30M for corporations. The capital/investment figure itself must be at least ¥30M.
Q6. How is the ¥30M scale checked for sole proprietors?
For sole proprietors, there is no “capital” in the registry. Immigration will check the actual amount invested into the business, such as:
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office securing (deposit, key money, initial rent),
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one year of salaries for employees,
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equipment and other business assets needed to operate.
You will typically need to show:
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your latest financial statements/tax return, and
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receipts, contracts, and bank transfer records proving these investments.
Q7. I don’t have a finished financial year yet. Do I still need a balance sheet?
Yes. Even if your first fiscal year has not yet ended, you are expected to prepare a balance sheet as of a certain date (e.g. at incorporation or a later snapshot date) and submit it.
You cannot simply say “no balance sheet because the first year is not finished.”
Q8. Who can satisfy the B2 Japanese requirement? How do we prove it?
B2-equivalent Japanese is required for someone in the management team or full-time staff (Japanese and Special Permanent Residents are exempt from the “proof” requirement).
For non-Japanese / non-SPR, you must generally show one of:
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JLPT N2 or higher, or
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BJT 400+, or
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20+ years of mid- to long-term residence in Japan, or
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graduation from a Japanese university or other higher education institution, or
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completion of Japanese compulsory education + high school in Japan.
Proof may include:
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exam certificates or transcripts,
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graduation certificates,
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residence records (住民票) showing long residence.
On the employer’s form, you should explicitly state who has the required Japanese ability and how it is proved (e.g. “CEO holds JLPT N2” or “We employ a Japanese national full-time”).
Q9. Who can review and sign the required business plan under the new rules?
At the time of enforcement, the “expert” who evaluates your business plan must hold a Japanese professional qualification with recognized ability in enterprise evaluation, specifically:
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SME Management Consultant (中小企業診断士),
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Certified Public Accountant (公認会計士), or
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Licensed Tax Accountant (税理士).
Foreign qualifications alone (e.g. US CPA) do not currently satisfy this requirement.
Q10. I used the Startup Visa / Designated Activities (No.44 or No.51). Will the new standards apply when I change to Business Manager?
It depends on timing:
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If your Startup Visa confirmation (No.44) or No.51 Designated Activities was issued before October 15, 2025, and you change to Business Manager based on that, your change-of-status application will be examined under the old standards.
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However, once you are on Business Manager, your future renewals will follow the same 3-year transition and new standards as everyone else:
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up to October 16, 2028 → some flexibility based on your progress,
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after that → you must meet the new standards in full.
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We have compiled and explained the latest official Q&A released by the Immigration Services Agency, including full-time employee rules, capital requirements, Japanese language standards, and renewal practice.
👉 Read the full Business Manager Visa Reform FAQ here
8) Forms & templates (after Oct 16, 2025)
Use the new checklists and forms (CoE, Change of Status, Renewal) and the Explanatory Notes available on the ISA “Business Manager” page (PDF/Excel/Word formats).
9) Bottom line
Japan has moved the Business Manager visa from “check-the-box” to “prove real business”: capital, hiring, language capability, verified planning, proper offices, and clean public-dues records.
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If you’re applying soon, build evidence now—don’t leave any gap.
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If you’re already on Business Manager, use the 3-year window wisely to align with the new standards—especially if you aim for Permanent Residency or HSFP upgrades.
💼 Need Expert Support?
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