Japan FEFTA Reporting for Foreign Property Buyers: Form 22 and What Happens If You Miss It

Most English-language guides to buying property in Japan cover the purchase process through to settlement and registration. Very few mention what you must do within 20 days of that settlement if you are a non-resident buyer. Under Japan's Foreign Exchange and Foreign Trade Act (FEFTA), the purchase of domestic real estate by a non-resident is formally classified as a "capital transaction." The legal consequence is a mandatory post-acquisition reporting obligation to the Bank of Japan that carries federal penalties for non-compliance. The form is completed entirely in Japanese. The deadline is 20 days from the date of acquisition.

This is not an obscure technicality. It is a statutory requirement that tens of thousands of foreign buyers complete each year through their agent or judicial scrivener — and that a meaningful fraction of overseas purchasers miss entirely because their agent did not proactively raise it.

What FEFTA Requires and Why

FEFTA (外国為替及び外国貿易法 — Gaikoku Kawase oyobi Gaikoku Boeki Ho) is Japan's primary foreign investment control legislation. It governs the cross-border movement of capital, not the legal right to own assets. Since foreign nationals can freely purchase Japanese property without restrictions, the law's role in real estate is not to prevent ownership — it is to track foreign capital inflows.

Under FEFTA, when a non-resident acquires real estate in Japan, the transaction is classified as a capital transaction, triggering a post-transaction reporting requirement. The buyer (or their authorized Japanese proxy) must submit Form 22 — formally titled "Report on Acquisition of Real Estate in Japan" (国内不動産の取得に関する報告書) — to the Minister of Finance through the Bank of Japan.

The critical details:

• Deadline: 20 days from the official date of property acquisition (typically the settlement/registration date)
• Language: The form must be completed entirely in Japanese
• Method: Submitted to the Bank of Japan (not to the Ministry of Finance directly, despite the statutory framing)
• Proxy: Non-residents without a Japanese address can authorize a Japanese-resident proxy — typically the agent or judicial scrivener — to file on their behalf
• Content: Property type, total area, exact location (including address and land registry identification), date of acquisition, purchase price

Who Is a "Non-Resident" Under FEFTA?

The FEFTA definition of "non-resident" differs from immigration status and is worth understanding precisely. Under the Act, a non-resident is generally a foreign national who has not established their primary residence in Japan — meaning someone who is based abroad at the time of purchase. This includes:

• Overseas investors purchasing Japanese property from their home country
• Foreign nationals on short-term or tourist visas at the time of purchase
• Expats who recently departed Japan but purchased property while resident

Note the overlap case: an expat who is a Japanese resident (holding a valid residence card) at the time of purchase and remains a Japanese resident post-purchase is generally not subject to the non-resident FEFTA reporting requirement. The obligation applies specifically to non-residents under the FEFTA definition. If your residency status is uncertain or you are in a transition period (recently arrived, preparing to depart, renewing visa), confirm your status with your agent or judicial scrivener before assuming the filing does or does not apply.

The 2026 Mandatory Address Registration Reform

Japan's compliance landscape for property owners has changed materially in recent years, and two reforms in particular create ongoing obligations beyond the initial FEFTA filing.

Mandatory Inheritance Registration (Enforced April 2024): Heirs are now required to register property ownership within three years of learning they have inherited it. This law applies retroactively to past inheritances — heirs of property inherited before April 2024 who have not updated the title must register by March 31, 2027, or face civil fines up to ¥100,000.

Mandatory Address and Name Change Registration (Enforced April 2026): Registered property owners must now report any change in their residential address or legal name to the property registry within two years of the change occurring. The penalty for non-compliance is up to ¥50,000. For foreign property owners who move internationally — which describes essentially every non-resident buyer over a long holding period — this creates an ongoing compliance obligation to update the Japanese property registry any time you relocate. An overseas investor who purchases Tokyo property, changes address several times over a 15-year holding period, and never updates the Japanese registry may face compounded penalties at the time of eventual sale when the registry discrepancy surfaces.

Practical Compliance Steps

At Acquisition

1. Confirm with your agent or judicial scrivener whether FEFTA Form 22 applies to your specific situation (resident vs. non-resident status under the Act's definition)
2. If it applies, authorize a Japanese-resident proxy to file on your behalf, or arrange to file from abroad within the 20-day window
3. The form requires the legal address of the property (as registered), the land area, the building specifications, the purchase price, and the acquisition date. Your judicial scrivener will have all of this information from the settlement documentation.
4. Retain a copy of the filed form and confirmation of submission for your records

Ongoing

1. Any time you change your residential address, assess whether the Japanese property registry needs to be updated under the 2026 mandatory address registration reform
2. The deadline for address updates is two years from the date of change — maintain a record of when you notified the Japanese registry to document compliance
3. If you are collecting rental income as a non-resident, confirm whether your rental structure triggers the 20.42% withholding requirement on your tenant, and ensure you have a domestic tax agent in Japan

What Happens If You Miss the Form 22 Deadline

The legal framing is that failure to comply with FEFTA reporting constitutes a violation of federal financial statutes. In practice, the enforcement pattern for first-time violations by individual foreign buyers has generally been remediation through belated filing rather than immediate prosecution. However:

• Belated filing does not eliminate the compliance violation — it mitigates it
• Subsequent transactions or legal proceedings involving the property may surface the missed filing, creating complications at that point
• Japanese regulators have progressively tightened enforcement of foreign property ownership reporting as overseas investment has increased substantially since 2022

The safe approach is to treat the 20-day deadline as real, delegate the filing to your agent or judicial scrivener as part of the settlement package, and confirm completion before the deadline passes.

Who This Is For

FEFTA compliance applies most directly to:

• Non-resident overseas investors purchasing Japanese property from abroad, who are not residents of Japan at the time of purchase
• Expats who have recently left Japan but retain property acquired while resident, if FEFTA applies to their specific residency transition situation
• Remote buyers executing transactions through a Power of Attorney who need their agent or judicial scrivener to handle the FEFTA filing as part of the settlement package
• Any foreign buyer whose agent has not proactively raised the Form 22 requirement and who is in the pre-purchase or early post-purchase phase

Who This Is NOT For

• Foreign nationals who are Japanese residents (holding a valid residence card) at the time of purchase and remain resident post-purchase — they are generally not non-residents under the FEFTA definition and the Form 22 requirement may not apply. Confirm this with a professional if uncertain.
• Buyers who have already confirmed that their judicial scrivener has handled the Form 22 filing as part of the settlement package

Tradeoffs

Delegating FEFTA compliance to your agent or judicial scrivener is standard practice and works reliably for the vast majority of transactions. These professionals handle the form as a routine part of the settlement documentation for foreign buyers. The risk is that delegation relies on them proactively raising the requirement — which some do not, particularly if they work primarily in the resident expat market where the FEFTA obligation is less frequently triggered.

The 2026 address registration reform creates a different kind of ongoing burden — it is not a one-time compliance task but a recurring obligation for the life of your property ownership. For a long-term foreign owner who moves internationally multiple times over a 20-year holding period, maintaining the Japanese property registry with current address information requires deliberate systems, not just attention at acquisition.

The most practical mitigation is to establish a long-term relationship with a Japanese judicial scrivener or property management professional who can handle registry updates and ongoing compliance reporting on your behalf. This is standard practice for non-resident investors managing Japanese property remotely.

Frequently Asked Questions

What is Form 22 and where do I get it?

Form 22 is the "Report on Acquisition of Real Estate in Japan" required under FEFTA from non-resident buyers. The form is available from the Bank of Japan. In practice, most overseas buyers have their Japanese agent or judicial scrivener prepare and submit the form on their behalf using the information from the settlement documentation. You should not need to independently source and complete the form if your transaction team is handling it.

Does a resident expat need to file Form 22 when buying property in Japan?

Generally no. FEFTA's non-resident reporting requirement applies to buyers who are non-residents under the Act's definition — primarily overseas buyers not based in Japan. Expats who hold a valid Japanese residence card and are residing in Japan at the time of purchase are typically not subject to the Form 22 requirement. If you are in a transitional residency status or are uncertain whether you qualify as a resident under FEFTA, confirm with your judicial scrivener or a Japanese lawyer.

What is the mandatory address registration reform for property owners in Japan?

Effective April 1, 2026, registered property owners in Japan are legally required to report any change in their residential address or legal name to the property registry within two years of the change occurring. Failure to comply carries a civil fine of up to ¥50,000. For foreign property owners who relocate internationally over the life of their ownership, this creates a recurring compliance obligation to update the Japanese Land Affairs Bureau registry with current address information whenever a residential move occurs.

What is the 20.42% withholding tax on non-resident rental income in Japan?

Non-resident property owners who rent their Japanese property are subject to a 20.42% withholding tax on rental income. In transactions where the tenant is a corporation or an individual renting for purposes other than their own primary residence, the tenant is legally obligated to withhold this amount and remit it directly to the tax authority on behalf of the non-resident owner. This creates a significant cash flow consideration for overseas investors who must account for net rental yield after withholding. Non-resident owners are required to appoint a domestic tax agent (zeimu dairi) in Japan to handle tax filing obligations.

Where can I find the complete post-purchase compliance guide for foreign Japan property owners?

The Buying Property in Japan — Expat Guide includes the complete 2026 Reform Compliance Guide — covering the FEFTA Form 22 requirement, the April 2026 mandatory address registration reform, the April 2024 mandatory inheritance registration law, the July 2024 akiya brokerage fee amendment, and the ongoing tax compliance obligations for non-resident owners including the 20.42% withholding regime and domestic tax agent requirements.

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