Business Manager Visa Transition Checklist: What to Do Before October 2028
Current visa holders have 3 years to comply with the new rules. Year-by-year action plan, red flags that trigger denial, and the full 6-requirement checklist.

Information current as of March 2026 based on the Immigration Services Agency's official revision notice and ACROSEED's detailed analysis. For a full breakdown of what changed, see our complete guide to the 2025 Business Manager visa reform.
If you already hold a Business Manager visa (経営・管理 / keiei kanri), you don't need to meet every new requirement today. But "transition period" does not mean "do nothing for three years." Immigration officers at renewal will assess whether you're making genuine, documented progress. This checklist tells you exactly what to do and when.
The 3-year transition timeline
| Period | What happens at renewal |
|---|---|
| Before Oct 16, 2025 | Applications reviewed under old criteria |
| Oct 2025 – Oct 2028 | "Holistic judgment" — approved if sound management + demonstrable progress toward new criteria |
| After Oct 2028 | Full compliance required — all six criteria must be met |
"Holistic judgment" (総合的判断 / sougouteki handan) means immigration considers your entire situation: business performance, tax compliance, social insurance enrollment, and whether you have a credible plan to meet each requirement before the deadline. A profitable company with ¥10 million in capital and a board resolution to increase it will be treated very differently from a dormant company with no plan.
Month-by-month action plan
Year 1 (now through October 2026): Assess and plan
- Audit your gaps. Go through the checklist table below and mark which of the six requirements you already meet. Be honest — "I think my capital is close" is not the same as having ¥30 million registered.
- Start capital increase planning. Increasing registered capital (増資 / zoushi) requires a shareholder resolution, amended articles of incorporation, a filing at the Legal Affairs Bureau (法務局 / houmukyoku), and has tax implications. This takes months, not weeks. Talk to your tax accountant now.
- Identify a certifying professional. Your business plan must be certified by a CPA (公認会計士), tax accountant (税理士), or SME consultant (中小企業診断士). Note: your immigration lawyer (行政書士) cannot certify it. Start interviewing candidates now — good ones get booked up.
- Check your Japanese language proof. Do you or any full-time employee (any nationality) have JLPT N2? Note: this is a separate requirement from the mandatory employee (Japanese/PR/LTR only). If neither you nor any employee has N2, register for the next JLPT or hire someone who has it.
Year 2 (October 2026 – October 2027): Execute
- Execute the capital increase. Complete the shareholder resolution and legal filings. Ensure the capital is genuinely invested in the business — immigration checks the source and flow of funds.
- Hire a qualifying employee if you don't have one. The employee must be Japanese, a Permanent Resident, or hold spouse/long-term resident status. They must be enrolled in social insurance (社会保険 / shakai hoken) and labor insurance (労働保険 / roudou hoken).
- Get your business plan certified. Work with your CPA or tax accountant to produce a certified plan covering revenue projections, hiring costs, cash-flow forecasts, and KPIs. This is not a one-page summary.
- Secure a proper office if needed. Home offices are no longer accepted. You need a commercial lease with documentation showing purpose of use, fire insurance, and floor plans.
Year 3 (October 2027 – October 2028): Verify and finalize
- Confirm all six requirements are met. Review the checklist table with your tax accountant and immigration lawyer.
- Prepare renewal documents early. Compile everything 3–4 months before your visa expires.
- File renewal before October 2028 if possible. A renewal filed before the deadline is still judged holistically. After October 2028, full compliance with the new criteria is expected — though some sources suggest limited holistic judgment may still apply for businesses demonstrating sound management and clear progress.
The full compliance checklist
| # | Requirement | Target | Action items |
|---|---|---|---|
| 1 | Capital (資本金) | ¥30 million registered | Shareholder resolution → amend articles → file at Legal Affairs Bureau → verify source of funds documentation |
| 2 | Full-time employee | 1+ (Japanese/PR/spouse of JN or PR/LTR) | Recruit → employment contract → enroll in social insurance + labor insurance |
| 3 | Japanese language | JLPT N2 or equivalent | Applicant or any full-time employee (any nationality) must hold N2/BJT 400+/20yr residence/Japanese degree. Separate from the mandatory employment requirement (#2) |
| 4 | Management experience | 3+ years or master's/doctoral/professional degree | Gather employment certificates, tax records, company registries as proof |
| 5 | Certified business plan | CPA/tax accountant/SME consultant sign-off | Draft plan with revenue model, cash-flow projections, KPIs → submit for certification |
| 6 | Office premises | Separate commercial space | Commercial lease → fire insurance → layout photos → floor plans |
Red flags that will get you denied — even during transition
Holistic judgment gives you flexibility, not immunity. Immigration will deny renewals during transition if they see:
- Zero progress since last renewal. Same capital, no employee, no plan. This signals you're not taking the transition seriously.
- Tax non-compliance. Unpaid corporate tax, resident tax, or consumption tax. Immigration cross-checks with the National Tax Agency.
- Social insurance violations. If you have employees but haven't enrolled them in shakai hoken, that's an immediate red flag.
- Shell company indicators. No revenue, no clients, no business activity. The reform specifically targets this.
- False documentation. Inflated capital through temporary deposits (見せ金 / misekin) withdrawn after filing. Immigration has seen this trick for decades.
Japanese phrases for your advisors
増資の手続きを始めたいです。株主総会の決議が必要ですか?
(Zoushi no tetsuzuki wo hajimetai desu. Kabunushi soukai no ketsugi ga hitsuyou desu ka?)
— I want to start the capital increase process. Is a shareholder resolution required?
経過措置中の在留資格更新で、どこまで対応できていれば安全ですか?
(Keika sochi-chuu no zairyuu shikaku koushin de, doko made taiou dekite ireba anzen desu ka?)
— For a visa renewal during the transition period, how much compliance is safe enough?
事業計画書の認定をお願いできますか?
(Jigyou keikakusho no nintei wo onegai dekimasu ka?)
— Can you certify my business plan?
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Don't Navigate This Alone
The checklist is clear, but executing it — finding a CPA who speaks English, understanding capital increase tax implications, hiring your first employee in Japan — is where things get complicated. On LO-PAL, you can post your question for free and get help from a local Japanese person who understands the system. They can help you find the right professionals, explain Legal Affairs Bureau procedures, or review your timeline. You only pay if you request a task and the helper completes it.
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Founder, LO-PAL
Former Medical Coordinator for Foreign Patients (Ministry of Health programme) and legal affairs professional. Built LO-PAL from firsthand experience navigating life abroad.
Written with partial AI assistance
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