⚠️ Key Takeaway: Failing to file the FEFTA report after a non-resident property purchase in Japan can trigger administrative fines and, in serious cases, criminal penalties under the Foreign Exchange and Foreign Trade Act — including imprisonment of up to 6 months or fines up to ¥1 million for willful violations. In practice, most genuine oversights are resolved by filing a late report, but you should act quickly and document that the omission was unintentional.
Many foreign buyers complete their Japanese purchase, register the title, and move on — never realizing a separate government report was due within 20 days of settlement. If that's you, this guide explains the actual consequences, how enforcement works in practice, and exactly how to remediate a missed filing.
This is the enforcement companion to our two reporting guides: the FEFTA 2026 reporting overview and the step-by-step Form 22 filing guide.
Quick Refresher: What You Were Supposed to File
When a non-resident acquires real estate in Japan, the Foreign Exchange and Foreign Trade Act (FEFTA) requires a post-acquisition report — Form 22 — submitted to the Bank of Japan (acting for the Minister of Finance), generally within 20 days of the transaction.
Since April 1, 2026, this obligation covers all non-resident acquisitions, including personal residences — the previous residential exemption was removed. It applies regardless of property type, price, or location.
Importantly: FEFTA reporting is not an ownership restriction. Japan places no restrictions on foreign property ownership. This is a transparency/reporting obligation — which is precisely why it's so easy to overlook.
The Penalties for Non-Compliance
FEFTA is a statute with real teeth, even though enforcement against individual residential buyers has historically been light.
| Violation type | Potential consequence |
|---|---|
| Late or missing report (oversight) | Obligation to file the overdue report; administrative follow-up |
| Willful failure / false statement | Criminal penalties: imprisonment up to 6 months or fine up to ¥500,000 (and up to ¥1,000,000 under certain provisions) |
| Serious / repeated violations | Higher exposure, potential referral for prosecution |
Key points:
- The penalties are defined by statute; the severity scales with intent. A genuine, promptly-corrected oversight is treated very differently from deliberate concealment or a false filing.
- Filing late is far better than not filing at all. Voluntarily submitting an overdue report demonstrates good faith.
- Providing false information on the form is treated more seriously than simply being late.
Enforcement Reality: What Usually Happens
For ordinary foreign buyers who simply didn't know about the obligation, the typical real-world outcome is administrative, not criminal:
- The authorities are primarily interested in getting the report filed and maintaining accurate records of cross-border capital transactions.
- Late filings are accepted. The standard remedy for a missed deadline is to file the report now, noting that it is overdue.
- Criminal prosecution is realistically reserved for willful, large-scale, or fraudulent cases — not honest residential oversights.
This is not a reason to ignore the obligation. Enforcement attention has increased alongside the 2026 changes and broader scrutiny of foreign capital flows, and an unfiled report is a loose end that can surface later — for example, when you sell, refinance, or are reviewed for other compliance matters.
Does a Missed FEFTA Filing Affect My Ownership or Title?
No. Your ownership and registered title (登記) are valid regardless of the FEFTA report. FEFTA reporting and property registration are entirely separate systems:
- Title registration (handled by a judicial scrivener / 司法書士) establishes legal ownership.
- FEFTA Form 22 informs the government about the capital transaction.
A missed Form 22 does not void your purchase — but it remains an outstanding legal obligation you should clear.
How to Fix a Missed or Late FEFTA Filing
If you've discovered you never filed, here's the remediation path:
- Gather your transaction records. Sales contract (売買契約書), settlement date, purchase price, property details, and your residency status at the time of purchase.
- Confirm you were a "non-resident" under FEFTA at the time of acquisition (this is the trigger). If you were a resident at purchase, the obligation may not have applied — verify your status.
- Prepare Form 22 following the step-by-step Form 22 guide, marking it as an overdue/late submission with the actual transaction date.
- Submit to the Bank of Japan through the prescribed channel, retaining proof of submission.
- Engage a professional if the situation is complex — a judicial scrivener, administrative scrivener (行政書士), or attorney experienced in FEFTA can file on your behalf and handle any follow-up, especially for higher-value or older transactions.
- Keep records of the late filing and any correspondence, in case the matter is ever reviewed.
Acting proactively and promptly is the strongest evidence that the omission was unintentional — which is exactly what keeps a late filing in administrative, rather than criminal, territory.
How to Avoid This Next Time
- Calendar the 20-day deadline at the point of settlement.
- Build it into your closing checklist alongside title registration.
- Ask your judicial scrivener or agent whether FEFTA applies to you — many handle or coordinate the filing.
- If you own multiple properties or buy regularly, standardize a compliance process.
For the full picture of obligations that attach to foreign ownership, see our FEFTA 2026 reporting overview and, if your property is near defense or border-island areas, the separate REIRA Act guide.
Frequently Asked Questions
What happens if I don't report my property purchase in Japan?
If you were a non-resident, you had a FEFTA obligation to file Form 22 within 20 days of settlement. Failure can trigger administrative follow-up and, for willful violations or false statements, criminal penalties — imprisonment up to 6 months or fines up to ¥500,000 (up to ¥1,000,000 under certain provisions). In practice, honest oversights are usually resolved by filing a late report.
Can I still file FEFTA Form 22 after the 20-day deadline?
Yes. Late filing is accepted and is far better than never filing. Submit Form 22 to the Bank of Japan as soon as possible, noting the actual transaction date and that it is overdue. Prompt voluntary correction demonstrates good faith and helps keep the matter administrative rather than criminal.
Does failing to file FEFTA invalidate my property ownership?
No. Your ownership and registered title remain valid. FEFTA reporting and property title registration are separate systems — a missed Form 22 does not void your purchase, but it leaves an outstanding legal obligation you should clear by filing late.
Will I really be prosecuted for a late FEFTA filing?
Realistically, criminal prosecution is reserved for willful, large-scale, or fraudulent cases, not honest residential oversights. The typical outcome for ordinary buyers is administrative — file the overdue report and retain proof. That said, the obligation is real and enforcement scrutiny has increased, so don't ignore it.
Should I hire a professional to fix a missed FEFTA report?
For straightforward residential cases you can often file the late report yourself using the Form 22 guide. For higher-value, older, or complex transactions — or if you're unsure of your residency status at purchase — engage a judicial scrivener, administrative scrivener (行政書士), or FEFTA-experienced attorney to file and manage any follow-up.
Related Articles
- Japan FEFTA Reporting Law 2026: What Foreign Buyers Must File →
- FEFTA Form 22: Step-by-Step Filing Guide →
- Can Foreigners Buy Property in Japan? Rules & Restrictions →
- REIRA Act: Property Restrictions Near Military Bases →
- Japan Property Tax Guide for Foreign Investors →
Disclaimer
This article is for informational purposes only and does not constitute legal, financial, or tax advice. Penalty provisions, enforcement practice, and reporting requirements under the Foreign Exchange and Foreign Trade Act are complex and subject to change. Outcomes depend on individual facts, including residency status and intent. If you have a missed or late filing, consult a qualified Japanese legal or compliance professional (司法書士, 行政書士, or attorney) for advice specific to your situation.