Is Japan Tightening Permanent Residency Rules? An Immigration Consultant's Take on the 2026 Draft Guidelines

1. Introduction

On August 4, 2026, Japan's Immigration Services Agency (ISA) published a draft revision of its Guidelines on Permanent Residency Permission and opened a public comment period. The window is short — comments are accepted only until September 4, 2026, at 00:00 (JST) (case number 315000140).

The draft introduces a large number of new, concrete standards covering income, pension, and Japanese-language ability, and many readers will come away with the impression that "permanent residency is about to get much harder." This article compares the draft to the current guidelines, walks through every change in detail, and looks at which real-world cases are likely to be affected.

💬 Expert Commentary It's true that this draft leans heavily toward stricter requirements overall. But reading it as a practitioner, "stricter" isn't the whole story. Some provisions are actually more lenient than before, and — perhaps more importantly — the draft makes a clear effort to put into writing internal standards that examiners have long applied in practice without ever spelling them out. That said, this move toward codification has a side effect worth flagging: the more specific the standards become, the more checkpoints an application is likely to be screened against going forward.

2. Key Changes

Below is a full summary table, followed by a detailed breakdown of each item.

Summary Table

No.	Category	Change	Impact
1	Independent means	Explicit income standard (household income above the Japanese national average)	High
2	Independent means	New pension requirement	Medium
3	National interest	Narrower definition of "work-based status" (intra-company transferee, ikusei shurō excluded)	Medium
4	National interest	New penalty for extended absences (6 months / cumulative 2 years 6 months)	Medium
5	National interest	Explicit reporting obligations and residence-card carrying obligation	Medium
6	National interest	Payment of taxes and social insurance (household-unit review codified)	Medium
7	National interest	Criminal record (juvenile protective dispositions added)	Low–Medium
8	National interest	Non-applicability of landing refusal grounds / landing permission criteria codified	Low
9	National interest	"Not becoming a public burden" — framework clarified	Low–Medium
10	National interest	New Japanese-language requirement (B1 level or above)	High
11	National interest	New check on understanding of Japan's rules and systems	Medium
12	National interest	New school attendance requirement for school-age children	Medium–High
13	National interest	Contribution to the government's "Comprehensive Measures" policy added as a factor	Low
14	Special track	Stricter spousal requirements (marriage 3→5 yrs, residence 1→3 yrs)	High
15	Special track	"Contribution to Japan" track consolidated and detailed	Low
16	Designated Activities	Activities excluded from the "10-year" count, now codified	Medium
17	Designated Activities	Clarification of which activities count as work-based status	Low–Medium
18	Effective date	Effective April 1, 2027, with partial retroactive application	Relevant to all applicants

Detailed Breakdown

1. Explicit Income Standard

The current guideline uses only a vague phrase — "assets or skills sufficient to avoid becoming a public burden." The draft replaces this with a concrete benchmark: household income must "continuously exceed the level of average income for a Japanese household of the same size." Household income is calculated by combining the income of all members of the same household unit, while excluding the income of adult dependents no longer supported by their parents and of non-work-status dependents (e.g., "Dependent" visa holders). Dependents abroad are added to the household size count, and households of five or more face a further upward adjustment to the required income level.

💬 Expert Commentary The informal benchmark practitioners have long used — roughly ¥3 million plus ¥800,000 per dependent — is, in my assessment, lower than what this newly codified standard will require in many cases. Applicants with larger households in particular should expect the income bar to rise.

2. New Pension Requirement

A projected future pension benefit ("projected benefit") will now be assessed against a reference benchmark ("benchmark benefit") — the pension one would receive after 30 years of Employees' Pension (kōsei nenkin) contributions at the above-average income level. Applicants who fall short can still satisfy this requirement if they hold sufficient financial assets ("supplementary assets"), calibrated by age. If the applicant has a spouse, the spouse's projected benefit (including any period as a dependent Category 3 insured person) is added to the total.

💬 Expert Commentary The number "30 years" sounds intimidating, but it isn't a requirement that you must already have 30 years of contributions on record. The projected benefit factors in future contributions too, assuming you continue at a comparable income level going forward. In other words, falling short of 30 years of contributions as of the application date does not automatically disqualify you. That said, this projection assumes Employees' Pension enrollment — self-employed applicants who are only enrolled in the National Pension are likely to fall short even after projecting forward, and may need to rely on supplementary assets to make up the difference.

3. Narrower Definition of Work-Based Status (Intra-Company Transferee and "Ikusei Shurō" Excluded)

Applicants must hold a work-based or residence-based status for at least 5 of the required 10 years of residence. In addition to the current exclusions — Technical Intern Training and Specified Skilled Worker (i) — the draft newly excludes "Ikusei Shurō" (the new worker-development status) and, notably, Intra-Company Transferee.

💬 Expert Commentary Intra-company transferee status was sometimes counted toward this requirement depending on the specifics of the case. The draft closes that door explicitly. Anyone who has spent a long period in Japan on an intra-company transfer status with an eye toward permanent residency should review how this affects their timeline.

4. New Penalty for Extended Absences

The draft newly specifies that, without reasonable cause, a single absence of six months or more, or a cumulative absence of two years and six months or more, within the past ten years will generally result in a negative evaluation.

💬 Expert Commentary Interestingly, this is more lenient than the informal benchmarks examiners have applied in practice — historically, a single trip over 90 days, or 100–120 total days abroad per year, was treated as a red flag. Applicants who have been overly cautious about travel days may actually find this reassuring.

5. Explicit Reporting Obligations and Residence-Card Carrying Requirement

Obligations such as reporting a change of address, procedures for reissuance of a residence card, the duty to carry and present a residence card at all times, and the prohibition on activities outside one's permitted status are now listed as an independent evaluation factor.

💬 Expert Commentary Reporting violations are already scrutinized closely in practice. What stands out here is the explicit mention of the "duty to carry your residence card at all times." Police checks on foreign nationals' residence cards are not currently enforced very rigorously, but I expect that enforcement to tighten — and a documented failure to carry the card could count against an application down the line. In my experience, whenever ISA writes something into the guidelines explicitly, scrutiny of that specific item tends to increase afterward.

6. Payment of Taxes and Social Insurance

Proper payment of taxes (income tax, resident tax, corporate tax, property tax, etc.) and social insurance contributions (health insurance, pension, etc.) will be reviewed on a household-unit basis, as now explicitly stated. A past history of delinquency proceedings, even if resolved by the time of application, will generally still count against the applicant.

💬 Expert Commentary Household-unit review isn't new in practice, but it's now written down explicitly. Currently, examiners typically check resident tax, five national tax categories, pension, and health insurance — going forward, income tax and property tax may increasingly come under scrutiny as well. Business owners in particular should note that examiners have recently started checking whether a company has properly withheld and remitted resident tax on behalf of its employees, not just the owner's personal payments.

7. Criminal Record

In addition to prior imprisonment or fines, the draft adds certain juvenile protective dispositions (under specific provisions of the Juvenile Act) as a new factor generally resulting in a negative evaluation.

8. Non-Applicability of Landing Refusal Grounds / Compliance with Landing Permission Criteria

A requirement of similar substance already existed under the current guidelines, but the draft now explicitly states non-applicability of landing refusal grounds (under Article 5, Paragraph 1 of the Immigration Act) as an independent factor, and reorganizes the treatment of compliance with landing permission criteria for the currently held status.

9. Not Becoming a Public Burden

This factor is now more clearly tied to the independent-means requirement. Notably, even applicants exempt from the independent-means requirement (e.g., under the spousal exception) may still receive a negative evaluation if their household is, or is realistically at risk of becoming, a public burden — though the draft states that this judgment should give weight to family unit stability and humanitarian considerations.

10. New Japanese-Language Requirement

Applicants will generally need Japanese proficiency at or above B1 level under the Japanese Language Education Reference Framework. Exemptions apply to Highly Skilled Foreign Professionals and their families, those who completed six or more years of elementary/secondary education in Japan, and children of permanent residents (under certain conditions).

💬 Expert Commentary Highly skilled professionals and their families are exempt by design, so the real issue is for applicants outside that category who are less confident in Japanese — particularly those who don't reach 70 points under the points-based system for highly skilled professionals. This requirement could become a genuine obstacle for that group.

11. New Check on Understanding of Japan's Rules and Systems

Applicants will be assessed, via a method designated by the Commissioner of the ISA, on their understanding of Japan's systems and rules, centered on the content of the official "Life and Work Guidebook."

💬 Expert Commentary ISA is currently considering implementing this check through an ICT-based system. How it's actually administered will significantly affect the practical burden on applicants, so it's worth watching for further details as they're announced.

12. New School Attendance Requirement for School-Age Children

Where an applicant is the parent of a school-age child (or is themselves school-age), whether that child (or the applicant) is actually attending elementary or junior high school becomes a new evaluation factor.

💬 Expert Commentary This is a point even highly skilled applicants often overlook. The "elementary school" and "junior high school" referenced here may specifically mean schools under the School Education Act — in which case attendance at an international school could fail to satisfy this requirement. Families whose children attend international schools should watch how this provision is finalized very closely.

13. Contribution to the "Comprehensive Measures" Policy

Contribution to the initiatives outlined in the "Comprehensive Measures for Accepting Foreign Nationals and Achieving an Orderly Coexistence Society," decided on January 23, 2026 (e.g., promoting the specified residence card, and expanding Japanese-language and civic-education programs), is now explicitly added as a consideration under the national interest requirement.

14. Stricter Spousal Requirements

For spouses of Japanese nationals, permanent residents, and special permanent residents, the required period of substantive marriage extends from 3+ years to 5+ years, and the required period of continuous residence in Japan extends from 1+ year to 3+ years. The residence requirement for children born of such marriages also extends from 1+ year to 3+ years.

15. "Contribution to Japan" Special Track Consolidated

Under current rules, this track was only referenced via a link to a separate guideline. The draft folds it directly into the main text (Section 4) and lists specific qualifying achievements in detail — national honors and decorations, five or more years as an executive of a company listed on the Prime Market of the Tokyo Stock Exchange, internationally prestigious awards such as the Nobel Prize, and top finishers or coaches at events such as the Olympics. The separate legacy guideline will be abolished.

16. Activities Excluded from the "10-Year" Count, Now Codified

Periods spent on ongoing job-hunting activity, as a job offer recipient awaiting status change, as a graduate engaged in startup preparation activity, undergoing refugee/complementary protection status determination procedures, or residing in Japan due to instability in the home country, are now explicitly excluded from the 10-year residence count.

17. Clarification of Work-Based Status Under "Designated Activities"

Among activities under the Designated Activities status, the draft newly specifies that Notification No. 6 (amateur athletes), No. 8 (international arbitration representatives), No. 36 (specified research activities), No. 37 (specified information processing activities), No. 46 (graduates of Japanese universities), and EPA nurses/care workers count as work-based status, while No. 5 and 5-2 (Working Holiday), No. 9 (internships), and those who found employment after graduating from a Japanese high school do not.

18. Effective Date and Partial Retroactive Application

If adopted as drafted, the revised guidelines take effect for applications filed on or after April 1, 2027. However, the new income standard and the "not becoming a public burden" requirement will also apply retroactively to applications filed within the six months before the effective date that remain pending as of that date.

3. Cases Likely to Be Affected

Based on the changes above, here is a breakdown of specific situations most likely to feel the impact.

① Intra-company transferees pursuing permanent residency

The draft explicitly excludes intra-company transferee status from counting as work-based status (Change 3). Some cases previously counted this status toward the 5-year requirement — that door is now closed.

💬 Expert Commentary Intra-company transferee status was sometimes counted toward this requirement depending on the specifics of the case. The draft closes that door explicitly. Anyone on a long-term intra-company transfer with permanent residency in mind should start reviewing options, including a possible change of status, sooner rather than later.

② Expats who don't speak Japanese

The draft generally requires B1-level Japanese (Change 10). Highly skilled professionals and their families are exempt, but expat employees who don't reach 70 points under the points system are not, and will be directly affected.

💬 Expert Commentary The people this really hits are those who don't qualify as highly skilled professionals and aren't confident in Japanese. Expats who have gotten by on English alone for both work and daily life in Japan will need to start planning for Japanese study in a more structured way.

③ Spouses of Japanese nationals, permanent residents, and special permanent residents

The spousal special track now requires 5 years of marriage (up from 3) and 3 years of residence (up from 1) (Change 14).

💬 Expert Commentary For couples in international marriages, this effectively pushes back eligibility by roughly two years. Anyone whose marriage or residence period is close to the borderline should confirm early whether they'll qualify for transitional treatment.

④ Large households or households near the income borderline

Household income must exceed the Japanese national average for a household of that size (Change 1). Households with more dependents face a correspondingly higher threshold after adjustment.

💬 Expert Commentary In many cases, this new standard will set a higher bar than the informal ¥3 million + ¥800,000-per-dependent benchmark previously used. Families with multiple children, or those supporting parents abroad as dependents, should run the numbers well in advance.

⑤ Self-employed and freelance applicants not enrolled in Employees' Pension

Because the pension requirement (Change 2) assumes Employees' Pension enrollment, applicants relying solely on the National Pension will structurally tend toward a lower projected benefit.

💬 Expert Commentary You don't necessarily need 30 years of contributions on record to satisfy this requirement — but that leniency applies to Employees' Pension enrollees. Self-employed applicants should factor in building up supplementary financial assets to cover any projected shortfall.

⑥ Applicants exempted from Japanese pension enrollment under a Social Security Agreement

Under Japan's bilateral Social Security Agreements, some individuals assigned to Japan from partner countries are exempt from Employees' Pension enrollment for a defined period, remaining enrolled only in their home country's pension system instead. This shortens their actual period of Employees' Pension contributions in Japan, which can work against them under the new pension requirement (Change 2).

💬 Expert Commentary If you were exempted from Japan's pension system under a Social Security Agreement, that exemption period shortens your Employees' Pension enrollment record in Japan and tends to lower your projected benefit calculation. You did nothing wrong — you were simply making lawful use of the agreement — but it can still work against you under the new permanent residency pension requirement. If a shortfall looks likely, it's worth considering building supplementary assets, or reviewing (where possible) the exemption arrangement itself.

⑦ Company owners and executives

Household-unit review of tax and social insurance payments is now codified (Change 6), and there is a growing trend of examiners also checking whether the company properly withholds and remits resident tax on behalf of its employees.

💬 Expert Commentary Company owners should be mindful not just of their personal tax compliance, but of the company's compliance as an employer — particularly proper withholding and remittance of employees' resident tax. This is easy to overlook, but we're increasingly seeing it come up in actual reviews.

⑧ Families with children attending international schools

The new school attendance requirement (Change 12) may specifically refer to schools under the School Education Act, in which case international schools could fall outside its scope.

💬 Expert Commentary This is a point even highly skilled applicants often overlook. Families with children at international schools should watch closely for how the final guideline defines "school" once it's confirmed.

⑨ Applicants who previously held a "job-hunting" Designated Activities status

Time spent on ongoing job-hunting activity, or as a job offer recipient, will now be explicitly excluded from the 10-year residence count (Change 16).

💬 Expert Commentary If you spent time on a job-hunting Designated Activities status after graduation before finding employment, that period may not count toward your 10 years. This could push your eligibility timeline out further than expected.

⑩ Applicants with frequent business travel or extended trips home

The threshold for a negative evaluation due to absences is now explicitly set at "six months or more in a single trip" or "two years and six months cumulative" (Change 4).

💬 Expert Commentary Somewhat surprisingly, this is actually more lenient than the informal benchmark long used in practice — a single trip over 90 days, or 100–120 total days abroad per year. Applicants who have been overly cautious about their travel days may find this reassuring.

⑪ Applicants already preparing an application or planning to apply soon

The revision applies to applications filed on or after April 1, 2027, but the income and public-burden standards apply retroactively to applications filed within the prior six months that are still pending at that date (Change 18).

💬 Expert Commentary Whether you'll fall under transitional treatment makes a significant difference to your strategy if you're currently preparing to apply under the current standards. Consulting a professional early is the best way to determine whether it makes sense to file now.

(Reference) Highly Skilled Professionals and Specially Highly Skilled Professionals

Provisions around the Japanese-language exemption and the expanded "contribution" track continue to favor this group, or in some cases enhance the advantages they already had. Overall, this group is relatively insulated from — or even benefits from — the changes.

Conclusion: Submit a Public Comment, and Consult a Professional Early

This draft revision reflects a clear shift toward more objective, quantifiable criteria for permanent residency review. At the same time, several changes — particularly the extended spousal requirements and the new Japanese-language standard — raise the bar for many applicants.

This is a voluntary public comment process, open to anyone.

• Comment period: August 4, 2026, 12:00 – September 4, 2026, 00:00 (JST)

• How to submit: Via the e-Gov Public Comment website

• Case page: Guideline revision draft — public comment page

• Contact: Immigration Services Agency, Residence Management Division, Residence Planning Office (Tel: 045-370-9755, ext. 2779)

Whether your specific case would fall under the new standards, and how the transitional rules would apply to a pending or planned application, depends heavily on individual circumstances. If you are considering a permanent residency application, we recommend consulting with a qualified professional now, rather than waiting for the guidelines to be finalized.

Our office regularly advises clients on permanent residency applications, including how to time an application in light of these upcoming changes. Feel free to reach out with any questions.

About the Author

Daichi Ito, Immigration Consultant (Gyoseishoshi) Founder and Principal, Kamakura International Legal Office Consultant, International Division, Kanagawa Gyoseishoshi Association / Registered Notification Agent, Tokyo Regional Immigration Services Bureau

Since founding Kamakura International Legal Office in 2019, Daichi Ito has worked exclusively as a specialist in permanent residency and naturalization matters. Since relocating the office to Minami-ku, Yokohama in 2023, he has handled a large volume of permanent residency and naturalization applications for foreign residents in the Yokohama area.

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This article is based on information available as of August 2026 and is intended as general commentary, not individualized legal advice. Applicants should consult a qualified professional and refer to the finalized official guidelines in light of their specific circumstances before proceeding with an application.