Reading Japan's Business Manager Criteria in the Text: The Standard Effective 16 October 2025

"Set up a company, put up a certain amount of capital, and the residence status follows." We hear this premise constantly from clients planning a business and a move to Japan at the same time, and explanations based on the pre-amendment threshold are still in circulation. The current criteria, however, are aimed not at the company as a vessel but at the substance of the business. This article sets out, as general information on the system, what the text of the ordinance actually requires of the Business Manager (経営・管理) status.

Where the Rule Sits: Part of the "Conditions for Landing"

Article 7(1)(ii) of the Immigration Control and Refugee Recognition Act (the "Act") provides that, as a condition for landing, the intended activity must fall within one of the activities in the right-hand column of Appended Table I and — for activities under Tables I-2 and I-4 — must also "conform to the criteria prescribed by Ministry of Justice ordinance." Those criteria are set by the Ministerial Ordinance to Provide for Criteria Pursuant to Article 7(1)(ii) of the Act (the "Landing Criteria Ordinance").

Business Manager sits in Table I-2, and the activity is defined as "engaging in the operation of international trade or other business, or engaging in the management of such business, in Japan." That same entry carves out an exception: activities involving the operation or management of a business that may not lawfully be conducted without one of the qualifications listed under the Legal/Accounting Services entry of Table I-2 fall outside this status. The amended criteria took effect on 16 October 2025 under Article 1 of the Ordinance's Supplementary Provisions.

Six Elements Make Up the Standard

The Business Manager row of the Landing Criteria Ordinance opens with "the applicant shall satisfy all of the following" and then lists the elements below. As a rule each is tested against the applicant; the only requirement the text expressly allows another person to satisfy is the Japanese-language one.

(All from the Business Manager row of the table in the Landing Criteria Ordinance.)

Three Points Most Often Misread

It is not "¥30 million of stated capital." What the text requires is that the total value of assets applied to the business — a figure that includes stated capital and total contributions — reach ¥30 million. Capital is one component counted toward that total, not the object of the test.

The language requirement does not necessarily fall on the applicant. The text asks that any one of the persons operating the business, or engaged in it other than on a part-time basis, meet the level. It attaches a further condition: that person is to reside in Japan. Note that this "any one of" formulation is unique to the language requirement. The background requirement — the degree or the three years of experience — is tested against the applicant personally and cannot be satisfied by an employee or anyone else.

The pool of countable full-time employees is narrower than it appears. The text specifies "full-time employees residing in Japan, excluding persons residing under a status of residence listed in the left-hand column of Appended Table I." Article 2-2(2) of the Act provides that statuses of residence "shall be as listed in the left-hand column of Appended Table I ... or the left-hand column of Appended Table II" — the left-hand column being the column of status names. Table I includes Highly Skilled Professional, Business Manager, Engineer/Specialist in Humanities/International Services, Specified Skilled Worker, Student, and Dependent, among others. Persons holding those statuses therefore do not count toward this requirement. Table II lists Permanent Resident, Spouse or Child of Japanese National, Spouse or Child of Permanent Resident, and Long-Term Resident. Hiring plans have to be built on that distinction.

What the Document List Reveals About How This Is Checked

The Business Manager row of Appended Table III to the Regulations for Enforcement of the Act lists, among the required materials, "a copy of a business plan that has been evaluated by a person with specialist knowledge of business management." It further requires materials showing the total number of full-time employees other than the applicant, documents on wage payments to those employees together with copies of residence records, residence cards, or special permanent resident certificates, materials establishing the total value of assets applied to the business, an outline of the place of business, documents evidencing degrees or work history, and materials establishing Japanese-language ability and residence in Japan. Plan, employment, assets, language — each is expected to be evidenced in writing.

Transitional Rules and Renewal Run on Different Provisions

The Ordinance's Supplementary Provisions contain two transitional rules. Dispositions on landing applications and on applications for a certificate of eligibility filed before the effective date remain governed by the former rules (Art. 2). And where a certificate of eligibility issued before the effective date supports a landing application made on or after it, the former rules continue to apply until the day on which three months elapse from the effective date, or from the date of issuance (Art. 3).

Renewal for those already in Japan is a separate question. Under Article 21(3) of the Act, an extension may be granted only where "there are reasonable grounds to acknowledge the extension as appropriate" — a judgment resting on a different provision from the conditions for landing. How renewals are handled in practice needs to be confirmed against published administrative guidance, case by case.

The Company and the Status Are Designed at the Same Moment

In our experience, what becomes expensive to fix later is rarely the status itself; it is the corporate structure built to support it. Whose funds satisfy the total-assets figure — the individual's, an existing offshore company's, or the family's — quietly fixes the route that dividends, transfers, and succession will later have to take. Employing full-time staff likewise brings continuing obligations: withholding on salary payments (Income Tax Act, Art. 183(1)) and coverage under employees' pension insurance where a corporate place of business continuously employs staff (Employees' Pension Insurance Act, Art. 6(1)(ii)).

Three things to settle:

• Whose capital, and in what ownership split, will satisfy the total-assets requirement
• Whether the staff who actually count toward the requirement can, in fact, be hired
• Whether the language requirement is to be met by the applicant or by an employee

Mapping the status requirements alongside the company's capital structure and hiring plan, on a single structural diagram, is where designing a business and a residence in Japan properly begins.

This article provides general information on the relevant systems. It does not constitute individual tax consultation, nor the handling of immigration applications. Specific filings and tax computations are handled by licensed partner tax accountants whom we introduce; for status-of-residence procedures we introduce appropriately licensed professionals.