This page provides a practical explanation of key points regarding the amendments to the Immigration Control Act Enforcement Regulations and the Ministerial Ordinance on Landing Standards (“Business Manager”) published in the Official Gazette on October 10, 2025.

Table of Contents

Key Points of the “Business Manager” Revision

Key Points of the Revised “Japanese Language Proficiency” Requirement

Impact and Response Patterns in Management Visa Practice

Approach to Supporting Documentation (Relationship with Enforcement Regulations)

Frequently Asked Questions (FAQ)

Checklist (Before Application)

Summary

Our Support (Examples)

 Key Points of the “Business Manager” Revision

•  When applying for a Business Manager visa, either the applicant themselves or a full-time employee engaged in the business (excluding part-time employees) must now possess Japanese language proficiency at a level enabling highly independent understanding and use of Japanese.
•  This is an additional requirement parallel to the stricter criteria such as capital of 30 million yen, at least one full-time employee, experience/academic background, and a business plan verified by an expert.
•  In practice, it is crucial to plan early on which individual will provide proof (the applicant or a full-time officer/employee) and how proof will be demonstrated (e.g., test certificates, academic background, or documented Japanese language usage in the workplace).

 Key Points of the Revised “Japanese Language Proficiency” Requirement

 ① “ Among the persons who will manage the business pertaining to the application or engage in said business (excluding part-time employees)”

•  Two categories of eligible individuals:
  1.  Individuals managing the business (e.g., Representative Director, Executive Officer, etc.)
  2.  Individuals engaged in the business (e.g., full-time officers, employees, etc.)
•  Part-time employees are excluded. Requirements cannot be met solely through part-time, temporary, or contract work.

 ② “at least one must possess Japanese language ability at a level enabling highly independent understanding and use of the language”

•  Only one person meeting the Japanese language proficiency requirement is necessary (this can be the applicant themselves or a full-time officer/employee).
•  Key terms in the wording are “highly” “independent” and “understanding and use.” This implies the ability to read, write, speak, and listen independently in a business setting, not merely everyday conversation.
•  As a guideline, this is considered equivalent to CEFR B2 (equivalent to JLPT N2).

 ③ “the applicant …must be scheduled to reside in Japan”

•  The applicant themselves must be the primary resident. At the time of screening, it is necessary that the applicant resides in Japan and is engaged in the management and operation of the business (remote, nominal management is not acceptable).
•  Even if a full-time employee meets the Japanese language proficiency requirement, the applicant’s own residency requirement is imposed separately.

 Translation: Tanishima Legal Corporation

 Impact and Response Patterns in Management Visa Practice

1. When the Applicant Themselves Meets the Japanese Language Requirement

•  Simplest approach. Design proof using the applicant’s own test certificates (e.g., JLPT N2, etc.), Japanese academic background (graduation from a Japanese university or graduate school), or long-term work experience in Japanese.
•  Advantages: Low risk of continuity or replacement issues.
•  Note: Statutory provisions may exclude part-time (contract) positions. Substantive evidence of full-time employment and actual residence in Japan is required.

1. When a Full-Time Officer or Employee Meets the Requirements

•  A structure addressing this through hiring and placement is also conceivable. The fundamental approach is interpreted as establishing evidence of full-time status and organizational structure, such as a full-time employment contract and enrollment in social insurance.
•  Advantages: Allows for designing a structure where core Japanese-speaking personnel are placed within the company, even if the applicant is not a native Japanese speaker.
•  Points to Note: “Part-time workers are not permitted.” “External contractors are not permitted.” Substantive evidence of full-time status and residence in Japan is required.

1. Shared Responsibilities Among Co-Representatives or Multiple Management Members

•  A structure where one member of the management team fulfills the Japanese language requirement could be considered. A structure demonstrating effective management involvement through articles of incorporation, shareholder agreements, or board regulations could also be considered (interpreted as persuasive).

 Approach to Supporting Documentation (Relationship with Enforcement Regulations)

•  The Immigration Control Act Enforcement Regulations can be interpreted as establishing the concept of “documents proving Japanese language ability.” Specific documents deemed sufficient will likely be clarified through future operational notices and examination practices.
•  Exams/Certifications: For example, a passing certificate for JLPT (Japanese Language Proficiency Test) N2 or higher could be interpreted as qualifying as “evidence of Japanese language ability.”
•  Academic Background, etc.: A supplementary approach using documents demonstrating Japanese-language learning achievements, such as coursework or completion at Japanese educational institutions, is also conceivable.
• Supplementary Notes on Japanese Usage in Business Operations: While definitive conclusions cannot be drawn until operational guidelines are clarified, one possible approach is to prepare explanatory materials detailing the actual usage of Japanese in business operations (e.g., as the foundation for internal and external communication).
•  Note: The combination of documents deemed sufficient may depend on individual cases and the current operational practices. It is safest to confirm the latest operational guidelines and optimize them according to each case.

Translation: Tanishima Legal Corporation

 Frequently Asked Questions (FAQ)

 Q1. Can an applicant apply even if they cannot speak Japanese?
 A. The provision can be interpreted as “either person,” meaning the business can be established if a full-time officer or employee meets the Japanese language requirement. However, the applicant themselves must meet the residency requirement in Japan.

 Q2. How should “full-time” be understood?
 A. Generally, it can be interpreted as referring to direct employment. Contract or part-time positions are not covered under the provisions.

 Q3. Can the requirement be met by hiring an overseas-based consultant?
 A. Based on the wording, part-time (contract) employment appears excluded, so it is interpreted as not meeting the requirement. It is understood that full-time employment with residence in Japan is a prerequisite.

 Q4. Can proof be provided using materials other than JLPT certificates?
 A. The enforcement regulations establish a framework for “documents proving Japanese language ability.” JLPT certificates are considered valid under this framework. However, it is safest to await clarification in operational notices regarding the treatment of other documents and to optimize applications on a case-by-case basis.

 Q5. How do the new requirements affect existing residence status (renewals)?
 A. Since the regulations at the time of renewal apply, it is interpreted that they may be applied. It is prudent to review your status before renewal.

 Q6. What level of Japanese proficiency is the benchmark?
 A. At this preliminary stage, it can be interpreted that the design is intended to target a level equivalent to CEFR B2 (approximately JLPT N2). Please adjust to align with the final standards specified in the operational notice.

 Q7. Can startups with small teams meet the requirements?
 A. Since the text states “one person” is sufficient, it is possible to structure the team with one full-time Japanese core personnel.

 Checklist (Before Application)

•  The applicant’s actual residence in Japan or the certainty thereof is a prerequisite (residence plan, lease agreement, living foundation)
•  Determine who will be the Japanese language proficient individual (1 person) (Applicant or full-time officer/employee)
•  Evidence of full-time status (e.g., employment contract, social insurance, attendance records)
•  Evidence strategy (exams/academic background/practical work records)
•  Design to simultaneously meet other requirements (business plan, capital, personnel, etc.) with stricter coexistence rules
•  Establish internal and external communication systems in Japanese (meeting minutes, approval documents, contracts, sales materials)

 Summary

•  The intent of the new requirements is to ensure smooth communication with the local community and business partners, and to guarantee substantive management.
•  Key factors in the review process are “identification of individuals,” “substantive full-time employment and residency,” and “evidence of practical Japanese language use.” Prepare well in advance.

 Our Support (Examples)

•  Preliminary assessment of requirement fulfillment (30-minute online session)
•  Designing a Proof Strategy (Optimal Combination of Exams/Education/Practical Experience)
•  HR documentation (job description, employment contract, Japanese language usage policy)
•  Preparation of complete application documents and agency representation for immigration procedures