2,850 Comments, Zero Changes: What the Public Said About the Permanent Residency Revocation Guideline

Based on the e-Gov public comment results for "永住者の在留資格の取消しに関するガイドライン案に係る意見募集の結果について" ("Results of the Public Comment Solicitation on the Draft Guideline on Revocation of 'Permanent Resident' Status"), results published October 1, 2026 (source)

I covered the substance of the permanent residency revocation guideline on October 7th. What I hadn't looked at yet is how it got there, and the public comment record is worth a post of its own. The Immigration Services Agency put the draft out for comment from August 4 to September 4, 2026, received 2,850 submissions, and published its results October 1. The line in the results table for "were changes made to the draft based on the comments received" reads: 無 — no.

Two very different sets of objections

What stands out reading through the agency's summary of the comments is that the pushback came from both directions at once. One camp argued the guideline is too harsh and too vague; the other argued it's too lenient and gives too much discretion to let people stay.

Too harsh, too vague. Comment 1 argued permanent residents already clear a tough bar to get the status in the first place — some were born and raised in Japan — and that a guideline this strict runs against the stated goal of a coexistence-oriented society. Comment 2 went further, listing out the guideline's own vocabulary — "intentional," "serious," "malicious," "clear," "by common social standards," "cannot be overlooked," "reasonable grounds," "comprehensive consideration" — and argued that with this many vague, evaluative terms, whether someone loses their status effectively comes down to the mood of the caseworker. Several comments pushed for numeric thresholds: a specific amount or duration of unpaid taxes and social insurance premiums that would trigger review, rather than case-by-case judgment calls.

Too lenient. On the other side, comment 18 argued that defaulting to a discretionary change of status rather than outright revocation "undermines the system's effectiveness," and that clearly malicious cases — long-term tax delinquency, forged residence cards, supporting illegal entry, repeat imprisonment — should mean automatic revocation absent extraordinary humanitarian circumstances. Comment 20 wanted serious or repeat intentional crimes to trigger revocation regardless of how settled someone is in Japan, arguing that factoring in ties to Japan or humanitarian considerations just blurs the line and invites abuse. Comment 22 took aim at the idea that a first offense gets the softer treatment: if the crime itself is serious enough, the agency shouldn't care whether it's someone's first conviction.

How the agency answered both sides

The agency's responses are fairly consistent in shape, whichever direction the criticism came from: it defended the guideline's substance while promising more consistent application, not different substance.

To the "too vague" critics, the agency's answer was essentially that it had already made every effort it could. The response to comment 2 says the guideline "makes every effort to be as concrete as possible" to secure predictability and fairness, and commits to ensuring every regional immigration bureau applies the same interpretation consistently — but doesn't add any numeric thresholds. The same answer repeats nearly verbatim across several other comments asking for hard numbers on tax delinquency (comment 7) or a bright line on minor documentation lapses (comment 5): no numbers, just a promise of consistent interpretation.

To the "too lenient" critics, the agency pointed to language already in the guideline: cases serious enough that continued residence is "not appropriate" do get revoked rather than downgraded, and the agency says it will apply that standard properly. On expanding revocation grounds further, or making revocation automatic, the agency's answer (comments 14, 20, 28) was the same noncommittal line each time — it would take the comment as a reference for future system design.

The retroactivity question, answered directly

One of the more substantive exchanges concerns timing. Comment 11 and comment 27 both pushed back hard on the guideline considering tax non-payment or criminal history from before the law's amendment takes effect, calling it a retroactivity problem that undermines legal stability — arguing the government's own failure to specify transitional rules shouldn't be the applicant's problem.

The agency's answer is worth reading in full because it's a real, substantive position, not a dodge: permanent residency is granted on the premise that the holder will continue to meet its requirements going forward, so if someone stops meeting them after being granted the status, that's relevant regardless of when the law changed. But the agency does draw a line — since the new revocation grounds apply only to people who already hold permanent residency, the look-back isn't infinite; it's bounded by when the person was granted the status, not open-ended into the past. And a single bad data point from before the law took effect won't by itself trigger revocation — the agency says it will weigh the person's conduct afterward too, including whether they've since cleaned up the situation.

Welfare recipients: an exemption that drew fire from an unexpected place

The guideline states that people receiving public assistance (生活保護) generally can't be found to have "intentionally" failed to pay taxes or social insurance premiums, because recipients are typically exempted from those obligations in the first place. Two separate comments objected to this — not because it's too lenient on welfare recipients generally, but comment 19 specifically invoked a Supreme Court ruling that foreign nationals have no legal entitlement to welfare benefits, arguing the exemption contradicts that precedent and should be deleted. The agency's answer sidesteps the constitutional argument entirely: welfare recipients don't owe the payments in the first place, so the revocation ground (failure to pay) simply doesn't apply on the facts, and the agency says it isn't in a position to comment on how the welfare system itself operates.

What's clearly still on the table

A handful of responses are notable mainly for what they don't rule out. On whether revocation grounds should be expanded, the agency's answer (comment 28) explicitly says this comment period wasn't about amending the law itself, but that revocation grounds should be set at a "necessary and appropriate" scope and that it will "continue to consider" the question going forward. The same open-ended language shows up on whether reporting by local governments should be mandatory (comment 33) and on future revisions generally — the agency's closing comment (37) says the guideline will be revised "as necessary" based on how it plays out in practice. None of this is a commitment, but none of it is a no, either.

Why this matters

2,850 comments is a substantial response for an immigration guideline, and they weren't rubber-stamping agreement — they pulled in opposite directions, with roughly as much pressure to go further as to pull back. The agency's answer to essentially all of it was the same: the substance stays, it will apply it consistently, and it's listening for next time. That's a useful data point for anyone trying to predict where this guideline goes from here — the version that shipped October 1 is, true to the public comment record, exactly the draft that went out for comment in August, and the places where the agency left itself room to "consider further" are probably the places most likely to move first.

Source: e-Gov Public Comment, case no. 315000141, "永住者の在留資格の取消しに関するガイドライン案に係る意見募集の結果について" (e-gov.go.jp); comment summary and agency responses (PDF).