Reporting scope expanded from April 2026

Japan revised regulations under the Foreign Exchange and Foreign Trade Act effective April 1, 2026, expanding post-transaction reporting for certain acquisitions of Japanese real estate by non-residents. The Ministry of Finance explains that when a reportable non-resident acquires real property in Japan or certain rights such as a leasehold or mortgage interest, a report on the acquisition must generally be filed within 20 days through the Bank of Japan to the Minister of Finance.

A Japan-based agent may submit Form 22

The Ministry of Finance states that the report can be submitted by the acquiring non-resident or by a resident agent in Japan, including a real estate intermediary. Paper and online filing methods are available, and the Bank of Japan provides the current Form 22 and filing guidance. Exemptions still exist for certain transactions, so foreign nationality alone does not determine whether a filing is required. The relevant test is the person's resident or non-resident status under FEFTA and the nature of the acquisition.

Post-closing compliance should be part of the purchase process

International buyers already need to coordinate registration, remittance, identity verification and tax matters when purchasing Japanese property. The 2026 change makes FEFTA reporting another item that should be considered before closing. The practical risk is greatest when an overseas buyer completes the transaction without knowing that a separate post-acquisition report may be required. Buyers and their advisers should decide before settlement who will check whether the filing applies and who will be responsible for submitting it on time.