What Happens If You Miss Japan's FEFTA Form 22 Filing as a Foreign Buyer (2026)

From April 1, 2026, Japan's Foreign Exchange and Foreign Trade Act (FEFTA) requires every non-resident buyer who acquires Japanese real estate to file Bank of Japan Form 22 within 20 days of acquisition. The previous exemption for residential property is gone. The rule now applies to every purchase, regardless of whether the property is for personal use, rental income, or investment. The window is short, the form is technical, and there is widespread confusion among foreign buyers who closed deals in March 2026 under the old rules and are now being told the new ones apply.

This article explains what actually happens if you miss the 20-day FEFTA Form 22 filing window, with the specific statutory basis, agency procedure, and remediation paths.

What is FEFTA Form 22?

Form 22 is the post-acquisition real estate report required by Article 55-3 of the Foreign Exchange and Foreign Trade Act. It records the buyer's identification, the property's type and location, the area, the acquisition date, and the price paid. The form is filed with the Bank of Japan through the Ministry of Finance system, and it can be submitted on the buyer's behalf by a licensed real estate agent or a judicial scrivener.

When does the 20-day clock start?

The clock starts on the acquisition date, which under the Real Property Registration Act is the day ownership transfer registration is recorded at the Legal Affairs Bureau. This is typically the same day funds are released at settlement and the judicial scrivener (shihōshoshi) submits the registration application. The 20 calendar days include weekends and Japanese public holidays.

What happens on day 21?

Nothing visible at first. The Bank of Japan does not issue an automatic non-compliance notice. The administrative consequence accrues silently. Your file becomes a late filing rather than a missed filing the moment you file, but until you file, the violation remains open.

What is the penalty for a late or missed filing?

Article 70 of FEFTA provides for administrative fines for failures to report, with maximums of up to ¥1 million (approximately USD 6,500 to 7,000 at 2026 rates) per violation. Lower-end fines are common for first-time, good-faith late filings that are voluntarily disclosed. Higher-end fines apply to repeat offenders, deliberate evasion, or filings only made after the Bank of Japan or the tax authority opens an inquiry.

Can the violation be discovered separately?

Yes, through three independent channels. The Ministry of Justice's nationality disclosure rule (effective April 1, 2026) requires every property buyer to declare nationality at the Legal Affairs Bureau, which lets the government cross-check against Bank of Japan FEFTA filings. The tax office cross-checks acquisition tax filings against the FEFTA list. And ongoing rental income filings by non-resident landlords include property addresses that can be matched against the FEFTA register.

What happens if I file late voluntarily?

A voluntary late filing is the standard remediation. You complete Form 22 with the actual acquisition date, note the late filing on the cover, and submit through your judicial scrivener or directly to the Bank of Japan. Fines for first-time, good-faith voluntary late filings are typically modest, and the file is treated as cured for future reference purposes.

What happens if the Bank of Japan inquires first?

The administrative posture stiffens. An inquiry-initiated late filing carries higher fines, requires more documentary support including evidence that the failure was inadvertent, and may trigger a wider review of your other Japanese tax filings. Inquiries are typically opened when the tax office flags a non-resident property acquisition that lacks a matching FEFTA record.

Does the title transfer get unwound?

No. FEFTA non-compliance is an administrative reporting violation, not a real estate title defect. Your name remains on the Real Property Register, your ownership is unaffected, and your right to occupy, rent, or sell the property is not impaired. The penalty is monetary and reputational, not proprietary.

Can I be denied future Japanese property purchases?

Not automatically, but a recorded FEFTA violation can affect bank cooperation, judicial scrivener engagement, and any future cross-border tax matter where the Japanese authorities run a compliance review. Repeat violators face stricter scrutiny on each subsequent transaction.

What if my judicial scrivener was supposed to file?

The legal obligation sits with the buyer, regardless of any agency arrangement with a judicial scrivener or licensed real estate agent. If the scrivener failed to file on your behalf, you remain administratively liable and must remediate. A claim against the scrivener for breach of mandate is possible but does not relieve the public-law penalty.

What if I bought through a Japanese kabushiki kaisha?

Form 22 is still required if the corporate purchaser is non-resident for FEFTA purposes. A Japanese kabushiki kaisha incorporated in Japan and managed from Japan is a resident entity, and Form 22 does not apply. A kabushiki kaisha incorporated in Japan but actually controlled and managed from abroad may be treated as non-resident for FEFTA purposes, in which case Form 22 applies.