Business Manager visa and working as both CEO and employee

Hi everyone,

I’d like to ask for advice from people who have experience with the Business Manager (経営・管理) visa in Japan, because I’ve run into a situation with a potential Japanese client that raised some questions.

My situation:

  • I run my own Kabushiki Kaisha (KK) in Japan.
  • I am the 代表取締役 (CEO) on paper, but at the same time I also work as a UI/UX Designer for clients (mainly foreign, had some small gigs for japanese companies but not relevant here).
  • I pay myself a monthly salary from the company and I am enrolled in shakai hoken (social insurance, pension).
  • My visa has already been renewed once under these conditions without any issue.
  • This setup has also been confirmed as acceptable by my gyoseishoshi and a notary I consulted.

The problem I’ve run into:

  • A Japanese company I’m talking to about a contract asked a lawyer for advice.
  • The lawyer told them that since I’m on a Business Manager visa, I can only do “management” work, not technical work myself (like design or development).
  • They said: if my company signs a B2B contract with them, but I personally execute the design/development work, that would be outside the permitted scope of the visa.
  • According to that interpretation, the only way it would be allowed is if my company hired another employee (not me) to do the actual technical work.
  • To prove that, they asked me to provide an employment contract (雇用契約書) for the employee.

My question:

  • Is this really the correct interpretation of the Business Manager visa?
  • From what I understand (and from what my gyoseishoshi told me), as long as my company formally employs me as a worker, pays me a salary, and I pay all social insurance/taxes, then I can legally do design/development as an employee of my own company, while also being CEO.
  • This seems to be how many foreigners on Business Manager visas actually operate, since small companies usually don’t have the budget to hire extra staff right away.

TL;DR:

  • On Business Manager visa, CEO of my own KK, also employed as a UI/UX Designer by the same KK.
  • Salary + social insurance paid properly, visa already renewed like this.
  • Japanese client’s lawyer says I can’t do technical work myself.
  • Looking for confirmation from people in similar situations: is it really illegal, or is my current structure (CEO + employee) valid to outsource to Japanese companies?

Thanks a lot in advance for any insight.

by Julien-Temaki