The break-even between staying non-resident with ACP and incorporating a Japan entity sits at roughly one to two employees: below that, ACP plus an Exporter/Employer of Record arrangement is cheaper and faster; above it, entity economics pull ahead quickly. The right answer also depends on whether you need a visa pathway, a local bank account, or a regulated licence, not on cost alone.
Last Updated: August 2026 · Reading Time: ~10 min
Option A: ACP (Non-Resident Import Without a Japan Entity)#
ACP (Attorney for Customs Procedures, 税関事務管理人) lets a non-resident company remain the legal importer on record while Aplash acts as the Japan-resident procedural agent under Customs Act (関税法) Article 95. This is a distinct structure from an Importer of Record (IOR) engagement, where Aplash itself takes title to the goods and becomes the named importer; see our IOR versus ACP comparison if you have not yet settled which of the two you need. What follows describes the ACP path specifically: staying non-resident and layering the supporting appointments around it.
How It Works
Cost Structure
| Cost Item | Estimated Range (Annual) |
|---|---|
| ACP service fee | ¥600K–2.4M (¥50K–200K/month) |
| Per-declaration fee | ¥5K–15K × number of shipments |
| JCT Tax Representative | ¥300K–600K |
| QIS registration & maintenance | ¥100K–200K |
| Domestic Representative (if PSE/PSC) | ¥300K–600K |
| EOR (per employee) | ¥3M–4.5M per employee/year |
| Total (no employees) | ~¥1.5M–4M |
| Total (with 3 EOR employees) | ~¥11M–18M |
Advantages
| ✅ Advantage | Detail |
|---|---|
| Speed | Operational in 3–4 weeks |
| Low upfront cost | No incorporation fees, no capital deposit |
| Flexibility | Easy to scale up or exit |
| JCT optimization | Input JCT recoverable via the ACP JCT Recovery Path (tax agent appointment plus Qualified Invoice Issuer registration) |
| No visa required | Manage remotely from overseas |
| No ongoing corporate compliance | No annual meetings, filings, audits |
Limitations
| ❌ Limitation | Detail |
|---|---|
| No JP entity for banking or licensing | Some partners/banks require local entity |
| Limited brand presence | No JP address on corporate materials |
| EOR cost scales linearly | Cost per employee doesn't decrease with scale |
| Can't hold certain licenses | Pharma, telecom, some financial licenses need entity |
| No visa pathway | Business Manager / HSP visa requires entity |
Option B: Japanese Entity (KK or GK)#
Incorporating a KK or GK makes the entity itself the resident importer and employer, removing the per-shipment ACP appointment and per-employee EOR fees in exchange for fixed annual compliance costs that do not scale down with low activity.
How It Works
Cost Structure
| Cost Item | KK (株式会社) | GK (合同会社) |
|---|---|---|
| Incorporation costs | ||
| Registration tax | ¥150,000 | ¥60,000 |
| Notary fee (Articles) | ¥50,000 | ¥0 |
| Stamp duty (paper filing) | ¥40,000 (waived if e-filed) | ¥40,000 (waived if e-filed) |
| Judicial scrivener fee | ¥80K–150K | ¥60K–100K |
| Total incorporation | ~¥280K–400K | ~¥100K–200K |
| Annual ongoing costs | ||
| Minimum inhabitant tax | ¥70,000 (even if unprofitable) | ¥70,000 |
| Tax accountant (税理士) | ¥600K–1.5M | ¥400K–1M |
| Social insurance admin | Varies by headcount | Same |
| Office rent | Market-dependent | Same |
| Capital requirement (for Business Manager visa) | ¥30M (since Oct 2025) | ¥30M |
| Director compensation | ¥3M–6M+ (for visa purposes) | Flexible |
Advantages
| ✅ Advantage | Detail |
|---|---|
| Full control | Hire, fire, set policies, hold licenses |
| Brand credibility | JP address, JP entity name on contracts |
| Banking | JP bank account (essential for many operations) |
| Visa pathway | Business Manager or HSP visa |
| Cost efficiency at scale | Per-employee cost drops vs. EOR |
| License eligibility | Can hold pharma, telecom, financial licenses |
Limitations
| ❌ Limitation | Detail |
|---|---|
| Slow setup | 2–6 months to become operational |
| High upfront capital | ¥30M+ for Business Manager visa |
| Complex compliance | Annual meetings, tax filings, audit requirements |
| Exit is expensive | Dissolution takes 2–6 months and has legal costs |
| Ongoing costs even if no revenue | Minimum tax + accountant + office |
When Does a Japan Entity Become Cheaper Than Staying Non-Resident With ACP?#
Entity costs overtake ACP plus Exporter/Employer of Record (EOR) costs once headcount reaches roughly one to two employees, because EOR pricing scales per head while an entity's fixed compliance costs spread across a growing team. Below that headcount, ACP stays cheaper because it avoids the minimum inhabitant tax, tax accountant retainer, and office overhead an entity carries regardless of size.
The key variable is number of employees.
| Employees | ACP + EOR Annual Cost | Entity Annual Cost | Winner |
|---|---|---|---|
| 0 | ~¥2M (ACP + Tax Rep) | ~¥3M+ (min tax + accountant + rent) | ACP |
| 1 | ~¥6M | ~¥5M | ≈ Even |
| 3 | ~¥14M | ~¥9M | Entity |
| 5 | ~¥22M | ~¥13M | Entity |
| 10 | ~¥42M | ~¥22M | Entity ✅✅ |
Cost (¥M/year)
45 │ ╱ ACP + EOR
│ ╱
35 │ ╱
│ ╱
25 │ ╱
│ ╱ ╱ Entity
20 │ ╱ ╱
│ ╱ ╱
15 │ ╱ ╱
│ ╱ ╱
10 │ ╱ ╱
│ ╱ ╱
5 │ ╱ ╱
│╱╱
0 ┼───┼───┼───┼───┼───┼───┼───┼───┼───┼──→ Employees
0 1 2 3 4 5 6 7 8 9 10
Break-even: ~1–2 employees
Entity clearly wins at 3+ employees
💡 The break-even is typically at 1–2 employees. Below that, ACP + EOR is cheaper and faster. Above that, entity economics improve rapidly.
Which Option Should You Choose?#
Choose ACP when you are testing the market, importing without a growing local team, or need to start within weeks; choose incorporation when you are hiring three or more permanent staff, need a visa pathway, or require a regulated licence an entity alone can hold. See our full IOR versus ACP structural comparison and ACP cost and fee guide for the pricing detail behind each column below.
Use ACP (No Entity) When:
| Scenario | Why |
|---|---|
| 🧪 Market testing (0–12 months) | Minimize risk before committing |
| 📦 Import-only operations | ACP handles all customs needs |
| 🛒 E-commerce only (Amazon FBA/Rakuten) | No entity needed for platform sales |
| 👤 0–1 employees needed | EOR cost is manageable |
| ⏱️ Need to start immediately | 3–4 weeks vs. months |
| 💰 Capital limited | No ¥30M requirement |
Incorporate When:
| Scenario | Why |
|---|---|
| 👥 3+ permanent employees planned | Cost efficiency |
| 🛂 Need Business Manager or HSP visa | Entity required |
| 🏦 Need JP bank account | Most banks require entity |
| 📜 Need regulated licenses | Pharma, telecom, financial services |
| 🏢 Want full brand presence | JP entity name on everything |
| 📈 Committed to 3+ year presence | Long-term ROI |
The Hybrid Path (Recommended for Most)
| Phase | Duration | Structure | Monthly Overhead |
|---|---|---|---|
| Test | Months 1–12 | ACP + EOR (if needed) | ¥150K–500K |
| Validate | Months 6–12 | Begin incorporation while ACP runs | +¥200K–400K (one-time) |
| Transition | Months 12–18 | Entity live; migrate from EOR to direct hire | ¥300K–800K |
| Scale | Year 2+ | Full entity operations | Variable |
What Hidden Costs Do People Miss in Each Option?#
The costs most first-time market entrants overlook are exit costs on the entity side and post-clearance audit exposure on the ACP side, both of which are absent from the headline monthly-overhead comparison above.
| Often Overlooked | ACP Route | Entity Route |
|---|---|---|
| Post-clearance audit defense | ¥500K–2M if issues arise | Same |
| Entity dissolution (if exiting) | ¥0 (just terminate ACP) | ¥500K–1.5M + 2–6 months |
| Employee termination costs | EOR handles (but follows JP law) | Severance negotiation ¥3M–12M+ per person |
| Annual corporate tax (even if ¥0 profit) | ¥0 | ¥70,000 minimum |
| Director compensation (for visa) | ¥0 | ¥3M–6M+ annually |
| Annual financial audit (Large Company) | N/A | ¥2M–10M+ |
Real-World Scenarios#
Scenario 1: US D2C Brand Testing Japan
"We sell consumer electronics on Amazon US. We want to test Amazon Japan with 50 SKUs."
| Recommendation | ACP route |
|---|---|
| ACP appointment (client stays non-resident importer) | ✅ |
| JCT Tax Representative | ✅ |
| QIS registration | ✅ (for B2B credibility) |
| PSE compliance (if electronic) | ✅ + Domestic Representative |
| Entity | ❌ Not yet |
| Timeline | 4–6 weeks to first shipment |
Scenario 2: EU Manufacturer with JP Distributor Deals
"We have 3 distribution partners in Japan and ship ¥200M/year."
| Recommendation | Entity (GK) |
|---|---|
| Entity type | GK (simple, low-cost) |
| IOR | Entity is resident IOR (no ACP needed) |
| Employees | 2–3 sales/operations staff |
| Visa | Business Manager for resident director |
| Timeline | 3–4 months to incorporate + hire |
Scenario 3: SaaS Company Hiring 1 Engineer in Tokyo
"We need one remote engineer in Japan. No physical goods."
| Recommendation | EOR only |
|---|---|
| EOR | ✅ Hire through EOR |
| ACP | ❌ No imports |
| Entity | ❌ Overkill for 1 person |
| Re-evaluate | When headcount reaches 3+ |
| Timeline | 2–4 weeks to hire |
✅ Decision Checklist#
- How many employees do I need in Japan? → >2 = lean toward entity
- Do I need a Business Manager or HSP visa? → Yes = entity required
- Do I import physical goods? → Yes = need ACP (or entity as IOR)
- How long is my Japan commitment? → >2 years = entity ROI positive
- Do I need JP bank account or licenses? → Yes = entity required
- What's my budget for market entry? → <¥5M = ACP route
- How fast do I need to start? → <1 month = ACP + EOR
Frequently Asked Questions#
If I only need 1 employee in Japan, is ACP or an entity actually cheaper?
At exactly one employee the two options land close to even, roughly ¥5 to 6 million a year either way, so the tie-breaker becomes non-cost factors: whether you need a visa pathway for that hire, a Japan bank account, or a regulated licence. If none of those apply, staying on ACP with an EOR arrangement avoids the entity's fixed compliance costs.
Can I switch from ACP to a full entity later without starting over?
Yes. The hybrid path most first-year entrants use runs ACP and EOR while incorporation proceeds in parallel, then migrates import and employment functions to the new entity once it is live. The ACP appointment and any EOR employment agreements are simply terminated at that point; nothing about starting on ACP locks you out of incorporating later.
Does choosing ACP mean I can never get a visa for anyone in Japan?
Not for owning or directing the company, but a visa pathway such as the Business Manager or HSP visa does require a qualifying Japan entity, not an ACP appointment. If a visa is on your roadmap even if not needed on day one, factor the incorporation timeline into your planning rather than treating ACP as a permanent substitute.
Official References#
| Source | Link |
|---|---|
| Japan Customs - ACP System | customs.go.jp |
| Companies Act (EN) | japaneselawtranslation.go.jp |
| NTA - Consumption Tax | nta.go.jp |
| JETRO - Setting Up Business in Japan | jetro.go.jp |
| ISA - Business Manager Visa | moj.go.jp |
This article is informational only and does not constitute legal, tax, or regulatory advice. Consult a qualified advisor before acting on the content. Last updated: August 2026.