Under the Business Manager criteria effective from 16 October 2025, a Japanese-language requirement was introduced. A common source of confusion is that the person who satisfies the full-time employee requirement does not always have to be the same person who satisfies the Japanese-language requirement.
Separate the employee requirement from the Japanese-language requirement
The new criteria require at least one qualifying full-time employee. For the employee requirement, persons generally counted are Japanese nationals, Special Permanent Residents, or foreign nationals holding a status listed in Appended Table II, such as Permanent Resident, Spouse or Child of Japanese National, Spouse or Child of Permanent Resident, or Long-Term Resident.
By contrast, the Japanese-language requirement asks whether the applicant or a full-time employee has Japanese ability at approximately B2 or higher. For this purpose, a full-time foreign employee holding an Appended Table I work status may potentially satisfy the language side even if that person does not count toward the employee requirement.
The person who satisfies the employee requirement and the person who satisfies the Japanese-language requirement do not necessarily have to be the same person.
How is Japanese ability proven?
For persons other than Japanese nationals and Special Permanent Residents, the published routes include, in principle, JLPT N2 or higher, BJT 400 points or higher, 20+ years of residence in Japan as a mid- to long-term resident, graduation from a Japanese higher-education institution, or completion of compulsory education and high school in Japan, among the prescribed methods.
Seven typical patterns
| Pattern | Manager Japanese | Japanese / SPR employee | Table II employee | Foreign employee proving Japanese | Result |
|---|---|---|---|---|---|
| 1 | No | None | Yes | No | Not sufficient |
| 2 | Yes | None | None | — | Not sufficient |
| 3 | No | Yes | — | — | Sufficient |
| 4 | No | None | Yes | Yes | Sufficient |
| 5 | Yes | Yes | — | — | Sufficient |
| 6 | Yes | None | Yes | No | Sufficient |
| 7 | Yes | None | Yes | Yes | Sufficient |
How to read the patterns
Pattern 1: A Long-Term Resident employee may satisfy the employee requirement, but if neither the manager nor any employee can prove the required Japanese ability, the language requirement remains unsatisfied.
Pattern 2: Even if the manager has N1/N2, that does not remove the separate obligation to have a qualifying full-time employee.
Pattern 3: One Japanese full-time employee can satisfy both the employee requirement and the Japanese-language requirement.
Pattern 4: A Table II employee can satisfy the employee requirement, while a different work-status employee (for example, Engineer/Humanities with N2) can satisfy the Japanese requirement.
Patterns 5–7: Where the manager can prove Japanese ability, the language side can be satisfied by the manager while the employee requirement is satisfied separately.
Look at “who satisfies which requirement”
- Long-Term Resident employee → employee requirement: yes; Japanese: verify separately.
- Engineer/Humanities employee with N2 → employee requirement: no; Japanese requirement: yes.
- Japanese full-time employee → both: yes.
- Manager with N2 → Japanese requirement: yes; qualifying employee still required separately.
“We have an Engineer/Humanities employee with N1, so everything is fine” is only half correct. That employee may cover the language requirement but not the separate employee requirement.
Speaking Japanese and proving the requirement are different
In practice, do not stop at “Can you speak Japanese?” The question is: By which prescribed evidence can the new-criteria Japanese-language requirement be proven? Fluency in conversation and documentary proof under the published framework are separate issues.
These seven patterns are representative examples, not an exhaustive list. The most important method is to judge the employee requirement and the language requirement separately.