Business Manager Visa: Transitional Measures and Renewal Preparation for Existing Holders

The October 16, 2025 amendment to the landing criteria for Japan's "Business Manager" residence status includes transitional measures for those already residing in Japan under this status. However, these measures do not exempt applicants from all requirements, and it is essential to understand exactly what they cover and the conditions that apply.

Period Covered by the Transitional Measures

Those already residing in Japan under the Business Manager status who file a renewal application before October 16, 2028 (three years after the enforcement date) will not be denied solely for failing to meet the revised criteria.

Renewal applications filed after October 16, 2028 must comply with the revised criteria.

Conditions for the Transitional Measures to Apply

Even within the transitional period, renewal will only be granted if the following conditions are met: the business is performing well; tax and other payment obligations are being properly fulfilled; and there is a reasonable prospect of meeting the revised criteria by the next renewal. These factors will be assessed together with other aspects of the applicant's residence status.

The transitional measures represent a grace period only. If there is no reasonable prospect of meeting the revised criteria, or if there are issues with business performance or tax compliance, renewal may be denied even within the transitional period.

Impact on Permanent Residence Applications

After the enforcement date, those who do not comply with the revised criteria will not be permitted to apply for permanent residence from the Business Manager status. A change of status from "Highly Skilled Professional (i) (c)" to "Highly Skilled Professional (ii)" will also not be permitted. Those considering a permanent residence application should address the new criteria as early as possible.

Applications Filed Before the Enforcement Date

Applications for a certificate of eligibility, change of status, or renewal that were received on or before October 15, 2025 (the day before enforcement) will be assessed under the previous criteria. However, even if permission is granted under the previous criteria, renewal applications filed more than three years after the enforcement date must meet the revised criteria.

Change of Status from Startup Visa

For those changing from Special Activities (No. 44 — Foreign Entrepreneur Startup Visa): if the confirmation certificate was issued before the enforcement date of the related ministerial notification amendment (October 15, 2025), the previous criteria apply to the change of status application. If the certificate was issued on or after the enforcement date, the revised criteria apply.

For those changing from Special Activities (No. 51 — Future Human Resource Creation Startup Preparation): if an application for a certificate of eligibility had already been filed, or the applicant was already residing under this status, as of the day before the enforcement date, the previous criteria apply. Applications filed on or after the enforcement date are subject to the revised criteria.

Highly Skilled Professional (i) (c)

Holders of "Highly Skilled Professional (i) (c)" status (premised on business management activities) must also satisfy the Business Manager criteria. The transitional measures apply to this status in the same way as to the Business Manager status.

Frequently Asked Questions

Q. During the transitional period, is it acceptable to not meet any of the new criteria?

No. The transitional measures only mean that failure to meet the new criteria alone will not result in automatic denial. Business performance, tax compliance, and the prospect of meeting the criteria by the next renewal will all be assessed. If no reasonable prospect is recognized, the application may be denied.

Q. If I file a renewal application after October 16, 2028, must I fully meet the new criteria?

Yes. However, if the business is performing well, payment obligations are being properly fulfilled, and there is a reasonable prospect of meeting the new criteria by the next renewal, overall residence circumstances will be taken into account.

Q. I want to apply for permanent residence during the transitional period but have not yet met the new criteria. Will my application be denied?

You may submit an application, but it will not be approved if you do not comply with the revised criteria after the enforcement date. Those planning to apply for permanent residence should work toward meeting the new criteria as early as possible.

Q. How can I demonstrate a "prospect of meeting the criteria by the next renewal" in my renewal application?

A written plan with concrete and achievable steps is required — for example, a specific capital increase plan, a recruitment plan for full-time employees, or a scheduled sitting of the Japanese language proficiency test. In some cases, a written evaluation from a business management professional may also be requested during the assessment.

Arch Immigration Law Office specializes in Business Manager visa applications and renewals. We support clients in responding to the transitional measures, preparing for the transition to the new criteria, and filing renewal applications. Please feel free to contact us for a consultation.