We Submitted Public Comments on Japan’s Proposed Immigration Fee Revision | PR Fee, Family Burden and Reductions
We Submitted Public Comments on Japan’s Proposed Immigration Fee Revision
Our comments address the proposed JPY 200,000 permanent residence fee, cumulative costs for families, predictability of fees based on the period of stay granted, eligibility for reductions and payment options.
On August 2, 2026, Tommy’s Legal Service submitted two comments through Japan’s e-Gov public comment system concerning the Immigration Services Agency’s proposed revision of residence-permission fees and its draft guidelines on persons eligible for reduced fees.
This article does not reproduce the full proposed fee table. Instead, it focuses on the comments submitted by our office and the practical issues affecting foreign residents, their families, employers and those preparing immigration applications.
The Two Public Comments We Submitted
Proposed fees and payment methods
This proposal concerns fees for procedures such as change of status, extension of period of stay and permanent residence, including fee levels based on the period of stay granted and electronic payment methods.
Draft guidelines for reduced fees
These draft guidelines describe who may qualify for a reduced residence-permission fee where financial hardship or humanitarian considerations are present.
We recognize the policy objectives of securing resources for immigration administration and promoting online applications. At the same time, we requested a fairer balance of burdens, greater predictability and clearer procedures.
Five Issues Highlighted in Our Comments
The proposed JPY 200,000 PR fee and cumulative family costs
Under the proposal to charge JPY 200,000 per person for permission for permanent residence, the burden would multiply when several members of the same household receive permission at the same time. A couple with two children could face JPY 800,000 in government fees alone.
We requested reconsideration of the amount itself, together with reduced fees for minors, a household cap for family applications, phased implementation, and substantial reductions or exemptions where applicants face financial hardship.
Predictability when fees depend on the period of stay granted
If the fee for a change or extension depends on the period of stay determined only when permission is granted, the applicant cannot know the final amount when filing the application.
We requested narrower differences between fee bands, advance notice of the expected band and maximum amount, notification of the confirmed amount before permission, and clear publication of the main factors considered when determining the period of stay.
Cashless and installment payment options
Requiring a substantial fee to be paid in one lump sum can burden both applicants and Immigration counters. We requested cashless payment options for permanent residence as well as other procedures, together with installment payments, payment deferrals or a reasonable payment period for high fees.
Reductions based on actual financial hardship
We requested that applicants not be excluded solely because of their category of residence status. Relevant circumstances should include exemption from resident tax, sudden unemployment or business closure, illness or high medical expenses, disasters, domestic-violence evacuation, single-parent households, and households supporting several minors. Income, assets, dependants and temporary hardship should be considered together.
Objective criteria, evidence and published outcomes
A reduction system is difficult to use if applicants cannot identify the income and asset benchmarks, how household size will be considered, which documents are required, what alternatives are accepted, when a request must be made, how long review may take, or how the decision will be communicated.
We therefore requested a way to seek a reduction without unnecessarily informing an employer, a pre-application consultation channel, flexible evidence, separate guidance or FAQs for permanent residence, publication of acceptance and refusal reasons and processing times, and a review of the system after implementation.
Do Not Choose an Application Date Based on the Fee Alone
Applicants should not rush to file merely to avoid a possible fee increase if the supporting documents or explanation are incomplete. The timing of an extension, change of status or permanent residence application should be reviewed from four perspectives.
Check the expiry date, current status of residence, income, tax and social insurance record, family circumstances and residence history.
Check job duties, employment terms, the employer’s circumstances, social insurance and relevant facts concerning family members or the accepting organization.
Check certificates, contracts, company materials, written explanations and consistency across all supporting documents.
Identify matters requiring an individual explanation, including job changes, divorce, dependency, late or unpaid obligations, and previous application history.
We Will Continue to Monitor the Official Outcome
Japan’s public comment process is not decided simply by counting the number of comments. After the submitted views have been considered, the government will publish the consultation result and the final legal and operational materials.
We will review the official result, final Cabinet Order and ministerial rules, fee-reduction guidelines and actual implementation, and update our information when necessary. We will not state that our comments were adopted or that the system was changed unless and until this is confirmed in an official publication.
Questions About a Renewal, Change of Status or Permanent Residence Application?
Rather than rushing an application solely because of the proposed fee revision, it is important to review the expiry date, current status, employment and family circumstances, tax and social insurance record, and supporting documents. If you are unsure about timing or required evidence, please contact us with the relevant facts.
Official Sources
This article provides general information based on materials published and comments submitted by our office as of August 2, 2026. Please check the latest official information and the circumstances of the individual case before making an application decision.
