This is Part 4 of our six-part series on Thai companies expanding into Japan. Having selected the entry vehicle in Part 1, cleared FEFTA in Part 2, and incorporated the Japanese subsidiary in Part 3, the next question is which residence status will allow the Thai director or executive to live and work in Japan long-term. This article reflects publicly available information as of April 2026 and focuses on the Business Manager visa as overhauled on 16 October 2025 (Reiwa 7), including the six new requirements, the three-year transitional window, family accompaniment, the impact on the path to permanent residence, and the Highly Skilled Professional / J-Skip alternatives.
What Changed on 16 October 2025
Effective 16 October 2025, the Immigration Services Agency materially tightened the landing criteria for the Business Manager status by amending the Criteria Ordinance under Article 7(1)(ii) of the Immigration Act and the corresponding Enforcement Rules. The stated rationale is to address a growing number of paper-company-style applications.
The most consequential structural change is from an OR test to an AND test. The old standard was “JPY 5 million capital OR two full-time employees” — either limb sufficed. The new standard is “JPY 30 million capital AND at least one full-time employee” — both must be met.
| Item | Old (until 15 Oct 2025) | New (from 16 Oct 2025) |
|---|---|---|
| ① Employment | Two full-time employees (OR) | At least one full-time employee (AND, restricted pool) |
| ② Capital | JPY 5 million (OR) | JPY 30 million or more (AND) |
| ③ Japanese language | Not required | Applicant or employee at CEFR B2 (e.g. JLPT N2) |
| ④ Education / experience | Not required | Master’s/professional degree OR three years’ management experience |
| ⑤ Business plan | Discretionary | Verification by Certified SME Management Consultant, CPA, or licensed tax accountant |
| ⑥ Office | Lenient | Home-office configurations no longer accepted in principle |
| Transition | — | Three-year window to 16 Oct 2028 for existing visa holders |
The headline trade-off — capital up 6×, headcount halved — understates the reality: the move to AND plus three new pillars makes the bar materially higher.
The Five Status Categories Used by Thai Inbound Investors
| Status | Typical holder | Period of stay | Impact of the October 2025 reform |
|---|---|---|---|
| Business Manager | Company directors, executives | 5y / 3y / 1y / 4m | Direct (six new requirements) |
| Highly Skilled Professional 1(c) / J-Skip | High-scoring managers | 5 years | Tied to Business Manager criteria |
| Highly Skilled Professional 2 | Promoted from 1 | Indefinite | Same |
| Intra-company Transferee | Intra-group transferees | 5y / 3y / 1y / 3m | No direct impact |
| Engineer / Specialist in Humanities / International Services | Engineers, specialists | 5y / 3y / 1y / 3m | No direct impact |
| Specified Activities 44 / 51 | Startup preparation | 1–2 years | Affects conversion to Business Manager |
| Dependent | Spouse, children | Same as principal | No direct impact |
After the reform, Intra-company Transferee, HSP 1(c), J-Skip, and Specified Activities 44 / 51 deserve much more weight as alternatives where the Business Manager bar is not realistic.
The Six New Requirements
Requirement 1: At least one full-time employee (Criteria Ordinance Art. 2(i))
The pool of qualifying employees is restricted: Japanese nationals, special permanent residents, or holders of Appendix II statuses (permanent resident, spouse of Japanese national, spouse of permanent resident, long-term resident). Appendix I status holders (Business Manager, HSP, Engineer/Specialist, Intra-company Transferee, etc.) generally do not count. “Full-time” means around 30 hours a week, 217+ days a year, five days a week, with paid leave entitlement and enrolment in employment insurance. Part-timers, seconded staff, dispatch workers, and sub-contracted personnel do not count.
Requirement 2: Capital (or equivalent investment) of JPY 30 million or more (Criteria Ordinance Art. 2(ii))
For corporations, this is paid-in capital of a KK or aggregate equity contributions of a partnership-type entity. Capital reserves, capital surplus, and retained earnings are excluded — only paid-in capital counts. Aggregating across multiple companies is not permitted; one company must clear JPY 30 million on its own. For Thai-parent expansions, the AML / beneficial-owner workstream from Part 3 and the FEFTA / BOT ODI workstreams from Part 2 should be redesigned at this 6× scale.
Requirement 3: Japanese language at CEFR B2 (Criteria Ordinance Art. 3)
Either the applicant or one of the company’s full-time employees must reach B2 under Japan’s “Reference Framework for Japanese Language Education”. Common evidence:
| Method | Notes |
|---|---|
| JLPT N2 or higher | Issued by JEES / Japan Foundation |
| BJT Business Japanese Test, 400+ | Issued by Kanken |
| 20+ years as a mid- to long-term resident | — |
| Graduation from a Japanese higher-education institution | Including senmon-gakkō and high-tech colleges; foreign-language curricula and correspondence courses are excluded |
| Completion of compulsory education in Japan + Japanese high-school graduation | — |
Japanese nationals and special permanent residents satisfy this automatically. In practice, hiring a Japanese full-time employee is the natural way to satisfy both Requirement 1 and Requirement 3.
Requirement 4: Education or three years’ management experience (Criteria Ordinance Art. 4)
The applicant must have either (i) a master’s or professional degree (foreign degrees count) in a field relevant to management or to the underlying business, or (ii) at least three years’ experience in business management or operations (time spent under Specified Activities 51 startup-preparation can count). A young, sub-three-year manager dispatched directly is no longer realistic.
Requirement 5: Expert verification of the business plan (Enforcement Rules, Appendix III, Item 1(a))
The business plan filed at the visa stage must be verified by a person with management expertise. As of the effective date, the recognised credentials are:
- Certified SME Management Consultant (Chūshō Kigyō Shindanshi)
- Certified Public Accountant
- Licensed Tax Accountant
Foreign credentials such as US CPA do not qualify. Officers and employees of the applicant company are excluded for objectivity reasons (an external advisor is fine). Drafting application documents for compensation by anyone other than a lawyer or administrative scrivener risks a violation of the Administrative Scrivener Act.
Requirement 6: Home-office prohibition in principle
A combined home/office is no longer accepted as a rule. The required size has no fixed metric, but it must be commensurate with the scale of operations. Virtual offices were already difficult before the reform; after the reform, the bar is higher still.
The Transitional Window
The transitional regime is designed to protect existing holders and applicants while pushing migration to the new rules.
| Category | Treatment |
|---|---|
| Applications received by 15 Oct 2025 | Old criteria apply |
| Renewals by existing Business Manager holders during 16 Oct 2025 – 16 Oct 2028 | Even if the new criteria are not met, the application is decided on the basis of operating performance, prospects of meeting the new criteria, etc. (an external expert assessment may be requested) |
| Renewals from 17 Oct 2028 onward | Compliance with the new criteria is required, with a degree of flexibility where operations are healthy, taxes are properly paid, and compliance is genuinely on track for the next renewal |
| HSP 1(c) (which presupposes Business Manager criteria) | Same as above |
For conversions from Specified Activities 44 (Startup Visa) and 51 (Future Creation Talent), whether old or new criteria apply turns on whether the relevant certificate of confirmation (44) or CoE filing (51) dates from before or after the reform’s effective date.
What This Means for Thai Investors
The shift from JPY 5 million / OR to JPY 30 million / AND requires a strategic re-set:
- Capital: 6× the prior reference point — Part 2 (FEFTA) and Part 3 (incorporation) workstreams need to be rescaled accordingly;
- Full-time employee pool: pick from Japanese nationals, special permanent residents, or Appendix II status holders. Either find a Thai national who has obtained permanent or long-term resident status from existing communities, or hire a Japanese employee;
- Japanese language: practically, hiring a Japanese full-time employee is the most realistic way to clear the B2 hurdle;
- Three-year management experience: dispatch a director-, board- or department-head-level executive with 3+ years’ track record at the Thai parent;
- Business plan verification: must be done by a Japan-credentialed Certified SME Management Consultant, CPA, or licensed tax accountant — Thai-side accountants and consultants do not qualify;
- Independent office: lease a dedicated office in Japan;
- Lead time: with capital, expert verification, hiring, and language proof, the runway is materially longer than under the old regime.
Where these are not realistic, Intra-company Transferee, HSP 1(c), J-Skip, and Specified Activities 44 / 51 become essential alternatives.
From Application to the Residence Card
| Step | Action | Time |
|---|---|---|
| 1. Business plan verification | Certified SME Management Consultant / CPA / tax accountant | A few weeks |
| 2. Capital injection (JPY 30 m) and full-time hire | See Part 3 | A few weeks+ |
| 3. CoE filing | At the regional Immigration Services Bureau by counsel | 1–3 months |
| 4. Visa application | At the Japanese Embassy in Bangkok | 3–7 business days |
| 5. Entry to Japan | Residence card issued at landing inspection | Same day |
| 6. Residence registration / social insurance | Municipal office, pension office, labour standards office | Within 14 days |
Switching from short-term visitor to Business Manager inside Japan is generally not permitted. Where the new Business Manager bar is unrealistic, Specified Activities 44 (1-year startup preparation via METI-recognised host bodies) and 51 (Future Creation Talent / startup preparation, linked to J-Skip / J-Find) are conversion routes worth considering, and Intra-company Transferee (after one year at the Thai parent) is a clean alternative that is not affected by the October 2025 reform.
Period of Stay, Renewal, and Public-Charge Compliance
The Business Manager visa is granted in 5y / 3y / 1y / 4m tiers. Initial grants are almost always one year. Reaching five years requires sustained revenue, employment continuity, and a clean compliance record.
Renewal review focuses on:
- Public charges: corporate, local-resident, business and consumption taxes; withholding income tax; labour insurance (employment / industrial accident); social insurance (health / employees’ pension);
- Continuity of full-time employment;
- Continuity of the office (lease renewal);
- Operational substance (revenue trend, customer continuity, regulatory licences);
- Applicant’s residence record (extended absences, criminal record, etc.).
Existing holders that originally cleared the JPY 5 million limb still face a prospective compliance check during the transitional window.
Dependents — Spouse and Children
A Business Manager’s spouse (legally married) and children (unmarried and dependent) can accompany under the Dependent status. Common-law partners, parents, and siblings are not eligible. Dependent status does not in itself permit work; up to 28 hours a week is allowed with a permission to engage in activity outside the status. CoEs for the principal and dependents can be filed concurrently.
Highly Skilled Professional 1(c) and J-Skip — Strong Alternatives
Highly Skilled Professional 1(c) is effectively an upgrade to Business Manager. Education, experience, income, age, Japanese ability, and position are scored: 70 points unlocks HSP 1, 80 points triggers the favourable PR treatment.
| Item | Points (approx.) |
|---|---|
| Doctorate | 30 |
| Master’s | 20 |
| Bachelor’s | 10 |
| 10+ years’ professional experience | 20 |
| Annual income of JPY 10 m+ | 40 |
| Annual income JPY 5–7 m | 10–20 |
| Age under 30 | 15 |
| JLPT N1 | 15 |
| Position of representative director, etc. | 10 |
Approximate values as of April 2026; verify against the latest ISA points table.
J-Skip (Special Highly Skilled Professional, introduced in April 2023) bypasses point calculation entirely if a credential / experience plus income floor is met:
- HSP 1(a)/(b): master’s degree AND annual income of JPY 20 m+, or 10+ years’ experience AND JPY 20 m+
- HSP 1(c) (management activities): 5+ years of business management or operations AND JPY 40 m+ annual income
J-Skip carries even stronger benefits than ordinary HSP: eligibility for HSP 2 after one year, eligibility for permanent residence after one year, expanded spouse work rights, eased rules for domestic helpers, and (conditional) parental accompaniment. For executives dispatched from Thai majors such as CP, SCB, PTT, or SCG, J-Skip is often the clean way around the new Business Manager bar, though the underlying activity remains “management of the Japanese entity”, which still requires real operational substance (an office, real activity).
Permanent Residence and Naturalisation
Permanent residence under Article 22 of the Immigration Act in principle requires 10 years’ continuous residence including 5 years in a work status, plus good conduct and an independent livelihood.
| Route | Residence requirement | Other key requirements |
|---|---|---|
| Standard (Business Manager 10y) | 10 continuous, 5 in work status | Good conduct, independent livelihood |
| HSP 1, 70 points | 3 years | Same |
| HSP 1, 80 points | 1 year | Same |
| J-Skip | 1 year | Same |
| Spouse of permanent resident | 3y married + 1y resident | — |
| Long-term resident | 5 years | — |
Following the October 2025 reform, where the new Business Manager criteria are not met after the effective date, permanent residence cannot be granted from Business Manager, HSP 1(c), or HSP 2 (premised on management activities); nor can HSP 1(c) be upgraded to HSP 2. Whether time spent during the transitional window counts toward the residence-time requirement is decided case by case.
Naturalisation under Article 5 of the Nationality Act requires 5+ years of continuous residence, age 20+, good conduct, an independent livelihood, and renunciation of current nationality. Thailand does not generally permit dual nationality, so naturalisation in Japan effectively means giving up Thai citizenship.
Re-entry — Deemed and Standard
For Thai executives travelling between Bangkok and Japan, deemed re-entry (return within one year, on showing the residence card at departure) is the standard tool. For absences expected to exceed one year and up to five, a standard re-entry permit must be obtained before departure. Not securing one for an absence longer than a year causes the residence status to lapse. Cumulatively absent for more than half of the period of stay also weighs against renewal.
Common Pitfalls (Post-Reform)
- Filing on the basis of a JPY 5 million capital subsidiary — refused (JPY 30 million required)
- JPY 30 million headline, but JPY 10 million is in capital reserves — only paid-in capital counts (effectively JPY 20 million), refused
- Aggregating JPY 30 million across multiple companies — must be a single company, refused
- Only Thai staff employed full-time (Appendix I statuses) — outside the qualifying pool, refused
- Japanese employee at 20 hours a week — not full-time, refused
- No Japanese-language proof (applicant and Appendix II employee both lack proof) — refused
- Two years’ director track record at the Thai parent — short of the three-year bar, refused
- Internal accounting staff “verifies” the business plan — fails the objectivity test
- US CPA verification — foreign credentials don’t qualify; only Japan-licensed credentials do
- Apartment used as office — not accepted as a rule
- Coasting through the transitional window without preparing for the new criteria — refusal risk at renewals from 17 October 2028 onward
- Specified Activities 44 with a confirmation certificate dated on or after 15 October 2025 — falls under the new criteria for the conversion (often missed)
- Trying to convert a short-term visitor visa to Business Manager inside Japan — generally not permitted
- Dependent child working full-time after graduation — breach of activity restrictions
- Travelling to Thailand for over a year without a re-entry permit — status lapses
Comparison with Thailand’s LTR Visa (Reference)
Thailand’s Long-Term Resident (LTR) visa offers a 10-year stay and a 17% personal income tax preference, among other features. Japan has no equivalent long-stay, low-tax visa. Japan’s HSP 2 resembles LTR in activity scope and stay length, but tax treatment is structured separately. A Thai executive holding an LTR visa still needs a separate Business Manager or HSP-track visa to take up residence and management activity in Japan.
Up Next
Part 5 will cover personal income tax and resident tax for the Thai executive, corporate tax for the Japanese subsidiary, and withholding tax on dividends, interest, and royalties paid back to the Thai parent — together with the relief available under the Japan–Thailand tax treaty. Part 6 closes the series with hiring Japanese employees, work rules, social insurance, and labour management.
Contact
Following the October 2025 reform, the Business Manager visa is reachable only with a coordinated package — JPY 30 million capital, a qualifying full-time hire, a B2 Japanese-speaker, three years’ management experience, expert business-plan verification, and an independent office. JTJB Bangkok (Thai-side documentation and Embassy-side visa application support) and Tono, Tanami & Kosada Law Office in Tokyo (CoE filings, renewals, status changes, transitional-window strategy, and the HSP 1(c) / J-Skip / Specified Activities 44–51 alternatives) work together as a single team. Engaging counsel from the capital and hiring-design stage materially improves the success rate.
Related Articles
- Thai Companies Expanding into Japan, Part 1: Choosing the Entry Vehicle
- Thai Companies Expanding into Japan, Part 2: Inbound Direct Investment Rules and FEFTA
- Thai Companies Expanding into Japan, Part 3: Setting Up the Company
This article is for general informational purposes about Japan’s immigration framework as at April 2026 and does not constitute legal advice. The Immigration Act, the Criteria Ordinance, the Enforcement Rules, operational guidelines, the Highly Skilled Professional points calculation table, and the permanent-residence guidelines are revised from time to time. For specific matters, please consult the latest legislation, notifications, and operational guidance, and obtain professional advice. Our team responds in cooperation with the Thai-qualified attorneys of JTJB International Lawyers and the Japanese-qualified lawyers of Tono, Tanami & Kosada Law Office.