The Immigration Services Agency opened a public comment process in early August on two documents that together reshape permanent residence in Japan.
What is being consulted on
The first is a revision of the permanent residence approval guidelines — how the agency decides applications. It sets out the positioning of the permanent resident status and the baseline considerations applied to each case.
The second is new: guidelines on revocation. The 2024 amendment to the Immigration Control Act added grounds on which permanent residence can be withdrawn, but left the standards for exercising them undefined. This document defines them.
Why revocation guidelines matter
Permanent residence has been, in practice, the most secure status available short of citizenship. The 2024 amendment changed that in principle by creating withdrawal grounds tied to non-payment of taxes and social insurance and to certain offences.
Guidelines determine what that means in practice. The gap between a ground existing in statute and being applied to a real case is exactly the gap these documents close, which is why the consultation matters more than the usual administrative exercise.
The income criteria question
Separately, reporting in early August indicated that the new income criteria discussed since July would be applied to applications already pending — filed under the earlier published criteria, decided under the new ones.
This is the sharpest point of the whole process. Japanese administrative practice generally assesses an application against the rules at the time of filing, which is why the fee revision, for example, expressly exempts applications lodged before 1 October. Permanent residence appears to be being handled differently.
How public comment works
Comments go through the e-Gov platform. Anyone may submit, including foreign residents, and submissions in Japanese carry more weight in practice because they are read in Japanese.
The agency publishes responses to the substantive points raised, and consultations do change drafts. This one drew a large volume of submissions.
In the meantime
Nothing final until the guidelines are issued. The criteria in force are those on our permanent residence page, and the means test is covered on the financial and income requirements page.
The practical advice has not changed: keep tax, pension and health insurance payments current and on time, keep your residence card notifications up to date, and pull your own records before filing.
Sources: Immigration Services Agency, The Japan Times