---
title: "Visa, Immigration, and Business-Manager Status Risks — Overview"
url: https://memocore.ai/memos/6a5f637963d783ad68709448
project: "Doing Business in Japan"
tags: "japan-business, visa-business-manager, visa-other"
updated_at: "2026-07-21T12:18:01.981Z"
---

# Visa, Immigration, and Business-Manager Status Risks — Overview

This section merges several related areas: the risk that a mismatch between a business's real activity and its declared visa status creates — a nominal company opened "for the box," self-subcontracting by a director, someone on the wrong visa type performing director functions, changing directors after a BM-visa refusal, and holding a business through offshore structures under CFC rules; the legal nature of the Business Manager visa and the October 2025 reform, including the public-comment process via e-Gov, the consultation results, the arguments submitted against tightening the rules, holder statistics by nationality, the non-retroactivity rule with its transition period, and the reluctance to approve BM status for three or more foreign directors; actual immigration-officer practice around requesting information, the lack of a single communication protocol, the formal nature of business-plan interviews, the ability to appeal a decision in court, and public activity as a possible audit trigger; and additional migration topics — Employer-of-Record schemes for work visas, remote seishain work from abroad, nominal directors, working through a foreign company's branch representative office, visas for Ukrainian refugees, foreign-company ownership overlap, and business-survival statistics. See: Nominal Business Risk and the Legal Nature of the BM Visa; BM-Visa Reform Arguments, Statistics, and Officer Practice; EoR Schemes, Nominal Directors, Refugee Visas, and Detention.
