Changing from a Standard Work Visa to Designated Activities (Notice No. 46) and Permanent Residence Requirements#

For foreign nationals building a career in Japan, changing one’s Status of Residence (commonly referred to as a visa) is a significant decision. In recent years, a specific status known as “Designated Activities (Public Notice No. 46)” has gained attention. This status is designed for foreign nationals who have graduated from a Japanese university and possess a high level of Japanese language proficiency.

A common concern arises among those currently holding a standard work visa, such as “Engineer/Specialist in Humanities/International Services,” who are considering switching to “Designated Activities (Notice No. 46).” The primary question is: “How will this change affect my eligibility for Permanent Residence (PR) in the future?”

This article provides an objective and detailed explanation of the system, focusing on the relationship between this specific visa status and the requirements for Permanent Residence.

Understanding Designated Activities (Public Notice No. 46)#

To understand the impact on Permanent Residence, one must first grasp the nature of “Designated Activities (Public Notice No. 46).” Established in 2019, this status is granted to foreign nationals who meet specific criteria:

Graduation from a Japanese university (including graduate schools) with a degree.
High Japanese language proficiency, typically demonstrated by passing the JLPT N1 (or majoring in Japanese at a university).

Under standard work visas like “Engineer/Specialist in Humanities/International Services,” there is a strict requirement for a link between the applicant’s university major and their job duties. Furthermore, work considered “simple labor” is generally prohibited.

In contrast, Designated Activities (Notice No. 46) allows for a much broader range of activities. Provided the work requires “smooth communication in Japanese,” applicants can engage in roles that were previously difficult to sponsor, such as service staff in restaurants, retail sales, manufacturing line management, or taxi driving. This flexibility makes it an attractive option for those wishing to change careers or gain on-site experience in Japanese industries.

Residency and Work History Requirements for Permanent Residence#

To apply for Permanent Residence in Japan, applicants must generally meet the following residency requirements:

Continuous residence: Living in Japan for 10 consecutive years or more.
Work requirement: Within those 10 years, the applicant must have worked under a valid work visa (or residential status) for 5 years or more.

The crucial question here is whether time spent under “Designated Activities (Notice No. 46)” counts towards the “5 years or more of work experience.”

Does Notice No. 46 Count as a Work Visa?#

The answer is yes. Designated Activities (Notice No. 46) is recognized as a valid working status for the purpose of Permanent Residence applications.

This status authorizes full-time employment and is fundamentally different from the “Permission to Engage in Activity Other Than That Permitted under the Status of Residence Previously Granted” (part-time work permission) held by students. It is a legitimate status granted by the Immigration Services Agency for professional activities.

Therefore, if an individual works for 3 years under an “Engineer/Humanities” visa and then switches to “Designated Activities (Notice No. 46)” for another 2 years, this constitutes a total of 5 years of work history. The continuity of the work period is maintained, and the counter is not reset simply because the type of visa has changed.

Financial Stability: A Critical Consideration#

While the visa category itself satisfies the legal requirement, applicants must be cautious about the practical criteria for approval, specifically the “Independent Livelihood Requirement.”

The Immigration Services Agency scrutinizes the financial stability of PR applicants. Generally, an annual income of around 3 million JPY is often cited as a benchmark for a single applicant, with higher amounts expected for those supporting dependents. The stability of this income over the years (usually the last 1 to 5 years, depending on the application route) is key.

Potential Risks Regarding Income#

Switching from “Engineer/Humanities” to “Designated Activities (Notice No. 46)” often involves a change in job type or industry. For instance, moving from an office-based role to a position in the service or retail sector might result in a lower salary.

Although Notice No. 46 requires the applicant to receive remuneration “equal to or greater than that of a Japanese national,” if the industry average itself is low, the resulting salary might dip below the levels typically expected for Permanent Residence approval. If a career change leads to a significant drop in income, it could negatively impact the assessment of financial stability, even if the visa status itself is valid.

Impact on the “Highly Skilled Professional” (HSP) Route#

Another factor to consider is the impact on the “Highly Skilled Professional” (HSP) point system. Many applicants aim for PR through the “fast-track” route by accumulating 70 or 80 points, which reduces the residency requirement to 3 years or 1 year, respectively.

Standard work visas often align well with the HSP point categories (such as professional career history). However, the nature of work under Designated Activities (Notice No. 46) can be complex when calculating points. Since Notice No. 46 allows for duties that include elements of physical or on-site work, it might be difficult to claim those years as “advanced specialized/technical career history” in future point calculations, depending on the specific job description.

If an applicant is planning to use the HSP point system for early Permanent Residence, it is advisable to carefully simulate whether the switch to Notice No. 46 will affect their total points or eligibility for the HSP status itself.

Conclusion#

Switching from a standard work visa to “Designated Activities (Public Notice No. 46)” does not inherently disqualify an individual from Permanent Residence. The time spent under this status is validly counted towards the required work duration.

However, the core of the Permanent Residence examination lies in the applicant’s stability and integration into Japanese society. When considering this visa change, it is essential to look beyond the visa eligibility itself and evaluate whether the new employment will maintain the necessary income levels and financial stability required for a successful Permanent Residence application in the future. Comprehensive career planning is key to navigating the immigration system successfully.