Japan’s new Business Manager criteria took effect on 16 October 2025, substantially raising the bar through requirements relating to capital, full-time staff, Japanese ability, management experience/education and professional review of the business plan. Nearly a year later, one practical question remains surprisingly hard to answer: who has actually seen a new approval under the new criteria?
Many “approvals” turn out to be renewals
After the new criteria took effect, we continued to hear that Business Manager cases had been approved. But on closer inspection, many were renewals. Existing holders benefit from transitional arrangements, so a renewal is not the same as a fresh application fully tested under the new criteria.
Concrete new-approval examples remain difficult to verify
Stories such as “someone I know got it” or “a large firm got an approval” circulate. But when we ask whether it was a new application or renewal, when it was filed, and whether the new criteria actually applied, the details often become unclear. In that sense, the new-criteria approval became almost an urban legend: the system exists, but the real specimen is rarely seen.
We do have one new approval under the new criteria
Our firm has handled a new Business Manager approval to which the post-16 October 2025 criteria applied. It was not a renewal and not a transitional case. But one case is not enough to establish a general rule, and we will not claim that “this is the formula” or that we know immigration’s internal standards.
Still, one completed case gives a certain practical feel
The published requirements look like a checklist: capital, employee, Japanese ability, management/education background, business plan. Yet after taking a case through to approval, our impression is that the review may not end with formal boxes alone. That is an impression—not an official standard—and turning it into a confident formula would simply create a new urban legend.
Perhaps we are still in the “textbook phase” of the new system
Immediately after a legal change, nobody has a mature body of case experience. Practitioners read the rules and Q&A, file applications, respond to requests for evidence, and gradually build a practical sense only after many outcomes accumulate.
The new Business Manager criteria may still be in that stage. The law exists, but shared case experience remains limited. Time will tell whether early impressions were accurate or merely coincidence.