Reasons for Denial of the Business Manager Visa and Countermeasures | A Thorough Explanation of the Stricter Latest Ministerial Ordinance

The status of residence “Business Manager” (the so-called Business Manager Visa) is required for foreign nationals to establish a company in Japan and operate a business. The permission criteria for this Business Manager Visa have, due to the latest revision of the Landing Criteria Ministerial Ordinance, been made stricter to an incomparable degree compared with the past.

Inquiries such as “I prepared in the same way as before and applied, but was denied,” or “The time for renewal has come, but I am unable to meet the new requirements and am uneasy,” are also coming in to our Administrative Scrivener office in large numbers. Under the current permission criteria, unless you accurately understand the latest changes and take sufficient measures, not only new acquisition but even renewal of the visa has become difficult.

In this article, an Administrative Scrivener well-versed in immigration affairs, based on the latest revised ministerial ordinance, thoroughly explains the typical reasons for denial of the Business Manager Visa and practical countermeasures for reliably securing permission. Even for those who have currently obtained the Business Manager Visa under the old requirements, this will be a matter of life and death for future renewals, so please read to the end.

Introduction: With the current revised ministerial ordinance, the bar for “Business Manager” has risen dramatically

The requirements for the Business Manager Visa up to now were generally things such as “capital of 5 million yen or more” and “employment of two or more full-time employees (or substitution by capital).” However, under the current permission criteria, in order to review the continuity and stability of the business more strictly, a fundamental review of the permission criteria has been carried out.

The main changes from the latest ministerial ordinance revision are as follows.

These changes are intended to make the business scale of foreign managers in Japan more certain, and to prevent paper companies and businesses lacking substance. Proceeding with application preparation while still holding the knowledge of the old criteria is nothing other than maximizing the risk of denial.

Risk of renewal denial for those who already hold the “Business Manager” Visa

What requires the most attention in this ministerial ordinance revision is foreign managers who are already residing in Japan under the “Business Manager” status of residence. If you take comfort in thinking, “I already have the visa, so the next renewal will surely be no problem,” you will receive an unexpected denial notice.

The “first renewal” coming after 3 years have elapsed since the effective date is the biggest hurdle

For those already residing, as a transitional measure, a grace period of 3 years from the effective date of October 16, 2025 (until October 16, 2028) has been established. However, from the first application for permission to extend the period of residence that arrives after this grace period has elapsed, as a rule, conformity to the new permission criteria after the revision is required.

In other words, by the deadline of October 16, 2028, you must grow your business and completely satisfy “both requirements” of “increasing capital to 30 million yen or more” and “newly employing one or more full-time employees,” or the risk of being mercilessly given “renewal denial” awaits.

Cases where denial can occur even during the grace period

Then, are renewal applications made during the grace period until October 16, 2028 100% safe? The answer is no. Even for renewal applications within 3 years of the effective date, the review is conducted strictly.

Specifically, the likelihood of denial increases in cases such as the following.

The “public charges” payment status, which is strictly checked at renewal

Furthermore, what is greatly emphasized in the current renewal review is “the status of fulfillment of the obligation to pay public charges (taxes, social insurance premiums, etc.).”

If there are any unpaid amounts or arrears that fall under the following, your qualifications as a manager will be questioned, and this will become a powerful reason for renewal denial.

Causes of denial in “new applications” under the revised ministerial ordinance

For those who will newly obtain the Business Manager Visa from now on, you must clear all of the latest permission criteria from the very start. Here we explain four causes that are typical examples of denial in new applications.

1. The capital / total investment does not reach “30 million yen”

The biggest change is the business scale requirement. Previously, business scale was recognized with “capital of 5 million yen,” but under the current criteria, capital, etc. of “30 million yen or more” is required. Applications that do not satisfy this criterion will be denied at that point.

2. There is no actual employment of full-time employees (one or more)

Before the revision, there was no such requirement (as an alternative to the capital requirement, an employment requirement of two or more was set). However, under the latest requirements, even if capital is 30 million yen or more, “the employment of one or more full-time employees is always made mandatory.”

Where the pitfall of denial lies here is the restriction on the eligible persons—namely, “who can be employed.” The eligible persons for “full-time employees” are limited to Japanese nationals, Special Permanent Residents, and foreign nationals residing under the statuses of residence in Appended Table II of the Act (“Permanent Resident,” “Spouse or Child of Japanese National,” “Spouse or Child of Permanent Resident,” “Long-Term Resident”). Foreign nationals residing under statuses of residence in Appended Table I of the Act (general work visas such as “Engineer/Specialist in Humanities/International Services”) are not eligible. If you mistake this, you will be denied for failing to meet the requirement.

3. Insufficient proof of Japanese language ability (equivalent to CEFR B2, etc.)

Under the current law, a new requirement related to “Japanese language ability” has been added. Either the applicant or a full-time employee must have a considerable level of Japanese language ability.

A considerable level of Japanese language ability means Japanese language ability equivalent to B2 or above in the “Reference Framework for Japanese Language Education,” and unless you can prove with objective materials that you fall under one of the following, you will be denied.

Note that regarding “full-time employees” for the purpose of satisfying this requirement, unlike the employment obligation described above, foreign nationals residing under statuses of residence in Appended Table I of the Act (foreign nationals holding work visas, etc.) are also included.

4. Lack of confirmation and evaluation of the “Business Plan” by a specialist

In an application for the Business Manager Visa, the Business Plan is the lifeline. The latest revised ministerial ordinance has made confirmation by a person with specialized knowledge of business management mandatory for the Business Plan submitted at the time of the decision on the status of residence, as something that evaluates whether the plan has concreteness and rationality and is feasible.

This “person with specialized knowledge” specifically refers to the holders of the following national qualifications.

Unless you receive an evaluation from these specialists and attach their confirmation document, the application will be denied.

5. Cases where the stability and continuity of the business is not objectively recognized

What is fundamental in the review of the Business Manager Visa is “the stability and continuity of the business.” Even if you have formally prepared 30 million yen of capital and employed full-time employees, if the essential business model has collapsed or the effectiveness of the business is doubtful, you will be denied as “the stability and continuity of the business is not objectively recognized.”

The newly mandatory “confirmation of the Business Plan by a specialist” is precisely to strictly check this “objective stability and continuity” through professional eyes. You must not stop at formally clearing the requirements; you must prove, through a persuasive business plan and objective supporting materials, that it firmly stands as an actual business.

Practical pitfalls of “denial” that become blind spots

In addition to the clear numerical criteria and qualification requirements above, there are also practical pitfalls in the review where a case is regarded as “lacking substance” and denied.

Substance of the place of business: a home-cum-office is, as a rule, not recognized

Because it is necessary to secure a place of business for carrying out management activities according to the revised scale, etc., combining your home as a place of business is, as a rule, not recognized. It is necessary to firmly secure an independent office space or store.

Actual activity as a manager: dependence on outsourcing

If, due to outsourcing or the like, the actual activity as a manager is not sufficiently recognized, it will be treated as not being recognized as carrying out activities falling under the “Business Manager” status of residence. If you are judged to have dumped the main duties of the business on another company, you will be denied.

Hollowing-out of activity due to long-term departure from Japan

If, during your period of residence, you have departed from Japan for a long period without justifiable reason, you will be regarded as having no actual activity in Japan, and permission for the extension of the period of residence will not be granted. Managers are required to direct and supervise their business with Japan as their base.

Strategic countermeasures to avoid denial

As explained up to here, the current review for the Business Manager Visa has become extremely strict. After the effective date, if you do not conform to the revised permission criteria, applications for permanent residence permission, etc. premised on “Business Manager” activities will also no longer be granted. For reliable permission and stable business operation, we strongly recommend the following measures.

Drafting an “improvement plan” with renewal in mind (for existing residents)

Those who already hold the visa should draft a medium-to-long-term roadmap with the grace period of “October 16, 2028” in mind. You need to compile, as an objective and reasonable “business plan,” how you will increase capital to 30 million yen and when you will recruit a full-time employee.

A double-check system between an Administrative Scrivener and a “business plan specialist”

Both at the time of new application and at the time of renewal, cooperation with specialists is indispensable. Note that for anyone other than an attorney or an Administrative Scrivener to perform, as a business and for compensation, the drafting of documents such as application forms to be submitted to government agencies, is likely to constitute a violation of the Administrative Scrivener Act.

The shortest route to avoiding denial is to entrust the matter to an office that has built a system in which an “Administrative Scrivener” who lawfully drafts application documents, and a “Small and Medium Enterprise Management Consultant / Certified Public Accountant / Tax Accountant” who objectively evaluates the business plan, can closely cooperate.

In summary: Correctly understand the latest permission criteria for stable business management

The latest revised ministerial ordinance for the Business Manager Visa imposes extremely high hurdles, such as capital of 30 million yen, the employment of full-time employees, Japanese language ability, and confirmation of the business plan by a specialist. However, for business operators who properly prepare and meet the requirements, it can also be said that an environment has been put in place where they can gain high trust from Japanese society and carry out stable business management.

So that you do not regret it after receiving a denial notice, and so that you do not close off the future path to a permanent residence application, correctly understand the latest criteria and take measures as early as possible.

At our Administrative Scrivener office, specialists well-versed in the latest laws and regulations, in cooperation with external specialists such as Small and Medium Enterprise Management Consultants, strongly support your reliable acquisition and renewal of the Business Manager Visa. If you are anxious about whether you conform to the current requirements, or if you would like to consult about future business plans, please do not hesitate to contact our office.