Abstract
This article examines how the Japanese government administratively manages dual nationality to maintain the ideological fiction of ethnic homogeneity. While the Japanese passport grants high visa-free access, this privilege is conditional upon adhering to a singular, mono-ethnic definition of nationality. Drawing on a longitudinal qualitative analysis of newsletters (1980–2025) from the Japan Association of Intercultural Families, the study documents structural friction between transnational identities and the state’s registration system. The analysis identifies three mechanisms of administrative exclusion: “orthographic violence” in name standardization, the outsourcing of border control to private gatekeepers creating “identity gaps,” and the use of discretionary power by street-level bureaucrats to coerce disclosure of foreign status. The study concludes that these barriers are design features intended to filter out identity complexity. By prioritizing a family-based model, the state restricts the mobility of global citizens and necessitates a re-evaluation of modern citizenship.
Introduction: Nationality, mobility, and the administrative enforcement of identity
The paradox of Japan’s powerful passport
Japan’s passport is consistently ranked among the most powerful in the world, granting visa-free access to 187 countries as of 2026 (Henley and Partners, 2026). In the age of migration, it represents a golden ticket to global mobility. Yet for dual- or multiple-nationality holders, those holding Japanese citizenship alongside another nationality, this privilege is fragile. Routine administrative procedures such as passport renewal or international travel can trigger scrutiny over family registration, demands for disclosure of foreign nationality, and inconsistencies across naming systems.
This article argues that Japan’s passport does not simply enable mobility but also functions as an administrative mechanism that differentiates between “standard” citizens and those whose identities do not conform to institutional expectations. In doing so, it reveals how global mobility is conditioned by domestic systems of identification rooted in assumptions of singular and standardized nationality.
Theoretical framework: jus koseki, passports, and street-level bureaucracy
This study is aiming at researching Japan’s administrative infrastructure of constructing ethno-national state through management of passports and dual nationals. Therefore, previous studies for this article are three-folded: Japan studies, international passport studies, and sociology of administration. More specifically, understanding the friction between dual nationals and the Japanese state requires looking beyond the Nationality Act and Passport Act to the administrative infrastructure that enforces them. This article draws on three theoretical frameworks: the sociology of the passport, the concept of jus koseki, and street-level bureaucracy.
Torpey (2000) argues that the passport is how modern states “monopolize the legitimate means of movement,” controlling individual bodies to extract resources and exclude unwanted members. However, in Japan this control mechanism operates through a unique structural feature: the koseki (family registration) system. Krogness (2014) argues that while Japan nominally follows jus sanguinis (nationality by blood), it functionally operates on “jus koseki” (nationality by registered household membership). Family registration (koseki) acts as the definitive ledger of Japanese nationals, meaning legal existence is defined not as an individual but as a member of a household unit (ie). This creates a fundamental mismatch for dual nationals: international passports require identification of individuals compatible with global standards, but the Japanese state can only authenticate identity through the family or household, namely koseki.
This friction is compounded by what Lipsky (1980) terms street-level bureaucracy. Because laws governing dual nationality are often ambiguous or diplomatically unenforceable (as seen in the “duty of choice” under Article 14), actual policing of the jus koseki boundary falls to individual window clerks’ discretion at passport centers and consulates. Previous studies on Japan’s family registration system have examined its history (Endo, 2010), ideological familialism (Hamano, 2019), and social problems it causes (Ido, 2016). This article extends this scholarship by analyzing how koseki operates as the basis of international passport regimes through street-level bureaucracy, focusing on how the mono-ethnic myth is constructed through technological and administrative implementation.
Studying privilege investigating infrastructure
Scholars have long demonstrated that Japan’s image as a mono-ethnic nation is historically constructed and socially maintained (Oguma, 1995; Weiner, 2009). Existing research shows how this narrative obscures internal diversity and shapes policies of inclusion and exclusion. However, less attention has been paid to how such ideological constructs are reproduced through everyday administrative practices, particularly in the domain of international mobility.
Research on dual nationals and mixed-heritage populations in Japan has primarily focused on individuals with ties to Asia and the Global South, highlighting how administrative barriers intersect with racialization, colonial legacies, and socioeconomic marginalization (e.g. Chapman, 2008; Liu-Farrer, 2020; Tsuda, 2003). On the other hand, international passport studies similarly concentrate on Global South populations, analyzing the “mobility divide” where wealthy nation citizens enjoy visa-free travel while others face systematic barriers (Mau et al., 2015). Scholars trace how passports evolved as tools of colonial control (Mongia, 2018; Torpey, 2000) and how passport “power” rankings reinforce hierarchies of race and wealth (Harpaz, 2021).
This article takes a different approach by examining dual nationals with ties to the Global North, primarily European and North American connections documented in 40 years of newsletters from the Japan Association for International Families (JAIF, 1985–2025). The demographic composition of the dataset reflects JAIF’s membership, which predominantly comprises middle-class families with Global North nationality combinations, representing a relatively privileged layers of dual nationals: those with the cultural and social capital to organize collectively, the literacy to navigate complex Japanese legal systems and their implementations, the linguistic abilities to document experiences in both Japanese and other languages, and the financial resources to engage in international travel regularly. Families facing the most severe exclusion, such as those rendered effectively stateless, undocumented migrants with unclear nationality status, or economically marginalized populations lacking resources to pursue passport applications, are likely underrepresented or entirely absent from this archive.
However, rather than undermining the study, this privilege highlights the severity of structural exclusion embedded in Japan’s administrative systems. The author aware of the critical differences between Global South and Global North dual nationals in Japan. If educated, middle-class citizens holding the “powerful” Japanese passport face effective statelessness or administrative erasure at borders, it suggests that the “mono-ethnic” logic of the state is not merely a barrier for the marginalized, but a fundamental design feature of the Japanese legal system that entraps even the most resourceful subjects. The barriers documented here likely represent a baseline of exclusion that compounds exponentially for those without middle-class resources, racial privilege, or organizational support.
Research question and contribution
This article investigates how the Japanese state administratively manages dual nationality and how this process shapes access to international mobility. The central research question is: How do administrative practices surrounding passports and family registration produce structural barriers for dual nationals, and what does this reveal about the reproduction of national identity? Drawing on longitudinal data from JAIF newsletters, the analysis identifies three interrelated mechanisms: constraints in name representation, the outsourcing of border enforcement to private actors, and discretionary decision-making by frontline officials. Together, these mechanisms demonstrate that barriers faced by dual nationals are not merely legal but are embedded in everyday administrative processes that privilege standardized and singular forms of identity.
This study makes three contributions. Empirically, it provides a long-term analysis of dual nationals’ experiences with passport administration. Theoretically, it shows how abstract notions of national homogeneity are reproduced through mundane bureaucratic infrastructures. Methodologically, by focusing on relatively privileged populations, it reveals how exclusion operates at the infrastructural level even in the absence of overt discrimination.
The paper proceeds as follows. Section “Data and methods” outlines data and methods. Section “Background: The legal architecture of the ‘mono-ethnic’ family” presents empirical findings on documentary constraints, border enforcement, and administrative discretion. Section “Discussion: The administrative enforcement of the mono-ethnic myth” interprets these findings through previous literature, and Section “Conclusion” concludes by discussing broader implications for the relationship between bureaucracy and national identity.
Data and methods
This study draws on a longitudinal analysis of newsletters published by the Japan Association for International Families (JAIF, Kokusai Kekkon wo Kangaeru Kai) between 1980 and 2025. Founded in 1980, JAIF is a grassroots organization supporting families formed through international marriage. Its newsletters provide a sustained record of how individuals interact with Japanese administrative systems in everyday contexts.
From 382 issues published over this 45-year period, materials relevant to nationality and mobility were identified through systematic review of tables of contents and keyword searches (e.g. passport, dual nationality, border crossing, and name). This process yielded 26 documents central to the analysis, including two special issues on passport-related problems and 17 articles or letters describing specific encounters with passport offices, consulates, and airline personnel. These texts were selected for their detailed accounts of administrative interactions rather than general commentary.
Ethical considerations
Newsletters from the 1980s through 1990s contain information that would be considered highly sensitive by contemporary privacy standards, including full names, residential addresses, and detailed family backgrounds. To address this, all personal identifying information was systematically anonymized during the digitization process. Specifically, all names of newsletter contributors and individuals mentioned in the texts were replaced with pseudonyms that maintain similar phonetic or cultural characteristics to the original names while ensuring individuals cannot be identified. Geographic details more specific than prefecture level were removed or generalized.
The digitization project was conceived as collaborative archive-building to preserve citizen movement records at risk of deterioration and loss. Ownership of all digitized materials resides permanently with JAIF. The complete digitized archive has been returned to the organization and is now stored on JAIF’s website, where all current JAIF members can access it. This ensures the organization itself can reflect on past activities and utilize the archive for future advocacy and support work. Physical materials (original paper newsletters) used during the digitization process are stored in the author’s office in a locked cabinet with passcode access, maintained solely for research verification purposes and will be returned to JAIF upon project completion. The author does not claim private ownership of any digitized data. Importantly, although not formally stipulated in written agreements, the author operates under a practice of seeking explicit permission from JAIF’s board of directors for each specific use of the data, including conference presentations, journal submissions, and this article.
Data analysis
The analysis employs qualitative document analysis informed by Science and Technology Studies (STS) frameworks. Each newsletter testimony is treated as an ethnographic vignette documenting encounters between dual nationals and Japan’s passport infrastructure. The selected texts were coded according to three analytical dimensions that structure the subsequent Analysis section:
– Sites of friction: Where does the conflict occur? (e.g. the local passport center, the consulate abroad, the airline check-in counter).
– Mechanisms of exclusion: How is the exclusion enacted? (e.g. orthographic constraints on names, demand for “Confirmation Forms,” refusal of service).
– Non-state actors: How do private entities (airlines, postal services) enforce state definitions of nationality?
Following Star’s (1999) infrastructure ethnography approach, the analysis pays particular attention to moments when passport systems become visible through breakdown or malfunction for dual nationals while operating smoothly for mono-ethnic citizens. These breakdown moments reveal the usually invisible ideological work that passport infrastructure performs. Following Riles (2006), passport application forms are analyzed as governance techniques, examining how form fields, checkboxes, and required documentation structure what counts as legitimate identity.
Throughout this paper, I use the term “dual nationals” (ju-kokuseki-sha) to refer to any Japanese citizen possessing one or more foreign nationalities. While Japanese law distinguishes between those who acquire foreign nationality by birth versus by voluntary naturalization, and the exact number of nationalities individuals hold may vary, the administrative experience remains structurally consistent: friction between the singular Japanese koseki identity and plural international identities that cannot be reconciled within current bureaucratic systems.
Background: The legal architecture of the “mono-ethnic” family
To understand the administrative barriers faced by dual nationals, one must first locate the Japanese passport within its specific legal genealogy. As scholars have pointed out, Japan’s Nationality Act has historically functioned not merely to regulate membership in the state but to enforce normative understandings of family, kinship, and “Japanese-ness”. The root of the norm lies in Japan’s family system, namely, koseki.
The koseki and the principle of jus sanguinis
Japanese nationality is formally based on jus sanguinis, linking citizenship to descent. In practice, however, nationality is determined through registration in the koseki, a system that defines legal identity through membership in a household rather than as an autonomous individual (Krogness, 2014). As a result, nationality is not simply a matter of biological lineage but of administrative recognition within a family register. Individuals who are not properly recorded in a koseki may be excluded from nationality despite biological ties, while legal incorporation into a household can establish membership independent of such ties. At the same time, foreigners are not registered in koseki, but only Japanese nationals are.
This structure reflects the historical legacy of the ie system codified in the Meiji Civil Code (1899), which organized legal and social life around patriarchal household units. Although postwar reforms formally abolished the ie system, the koseki retained its function as the primary mechanism for recording nationality and civil status. Contemporary family registration is limited to nuclear units (married couples and their unmarried children), but it continues to treat the household as the fundamental unit of legal identity.
It is critical to distinguish between two separate systems of demographic governance in Japan that are often conflated but operate under different ministries with different logics: family register and residential register. The former, koseki, registers individuals as members of family units (currently limited to married couples and their unmarried children, a reduction from the prewar three-generation ie). The system operates under the Ministry of Justice and governs legal family relationships, nationality, and civil status. Notably, married couples cannot separate their koseki; they must be registered in a single-family unit. When individuals marry, they create a new koseki, but spouses cannot maintain independent koseki. On the other hand, the residential registration system operates under the Ministry of Internal Affairs and Communications (formerly Ministry of Home Affairs) and governs residential location for administrative purposes like taxation and social services. Households under this system can be freely separated; married couples living at the same address can register as heads of independent households.
These two systems generate distinct but coexisting visions of family-oriented nationhood. The koseki system maintains a structural commitment to family unity as the basis of nationality and legal status, while the residential registration system allows for more flexible, individualized administrative treatment. For dual nationals, the koseki system presents the primary barrier, as passports derive from koseki records rather than residential registration. As later discussed in Section “Discussion: The administrative enforcement of the mono-ethnic myth,” the orthographic rules of koseki and the unit of family as a basis of individual identification hinders international mobility of dual-nationals, whose koseki is somewhat “incomplete”; in the sense of the either parent who is lacking of koseki registry, “irregular” orthography in the names, and the eventual possibility of renouncing Japanese nationality thus deletion of koseki.
Imperial governance and the colonial legacies
The structure of family registration should also be understood in relation to Japan’s imperial past. During the colonial period (1895–1945), the Japanese state utilized koseki to strictly demarcate between mainland Japan/inner territory and outer territories populations. While Koreans and Taiwanese were technically Japanese nationals after their territories’ annexation, they were registered in separate outer territories koseki that marked them as Koreans or Taiwanese, not ethnic Japanese. The critical mechanism of exclusion was not denial of nationality per se, but administrative segregation through differentiated registration systems.
The 1918 Common Law (Kyotsuho) technically permitted procedures for transferring household registration between mainland and outlying territories. However, this formal possibility was severely constrained in practice. Administrative ordinances and internal directives created bureaucratic barriers making transfer extremely difficult, particularly for Koreans seeking to transfer to mainland koseki. As Endo (2010) documents, even Koreans who married Japanese nationals and should have been eligible for koseki transfer often faced refusal or were placed in marginal administrative categories. The system thus operated through surface-level inclusion with practical segregation: formal legal provisions for unity coexisting with administrative mechanisms ensuring separation. This contradiction between rhetoric and practice became especially pronounced during the 1930s. The state promoted assimilation ideology through slogans such as “Japan and Korea as One Body” and “Harmony of Five Races”, symbolized by arranged marriages between Japanese imperial family members and Korean royalty. The “Interior Marriage Promotion Policy” encouraged intermarriage between Japanese and Koreans as demonstration of imperial unity.
When the empire was defeated, the Allied occupation tried to abolish the ie system as a means of “spiritual disarmament” (Kato, 2022) aiming at preventing Japan from ever again becoming a military threat to the United States, the main military power of occupying Japan. However, even though the new Japanese Constitution (1947), and the partial reform of the Civil Code abolished the formal patriarchal ie system in 1950, the family registration system remains the primary mechanism for demographic registration and identification of Japanese citizens. When family law reform began in 1946, Japanese political leaders harbored deep attachment to the ie system as embodiment of family-state ideology centered on the Emperor. The compromise preserved the fundamental structure of family-based registration rather than individual one. This preservation keeps “the “family system” per se remains basically intact” (Ninomiya et al., 2011). The notion that families, not individuals, constitute the basic unit of the nation was not abolished but reconfigured.
The 1985 revision: Gender equality and the “duty of choice”
The uniqueness of the family registration system lies in the fact that there is no “individual” in the system; everyone who has Japanese nationality is a member of a household, regardless of their actual family status. Even a person who has no living family members is registered as a single-member household rather than as an autonomous individual. Consequently, the Japanese passport is not an independent document of the individual but a derivative reflection of the family registry that works as the basis of Japanese nationality.
The current legal predicament for dual nationals originates in the 1985 revision of the Nationality Act. Prompted by Japan’s ratification of the Convention on the Elimination of All Forms of Discrimination Against Women in 1984, Japan transitioned from patrilineal to bi-lineal descent in the following year, allowing Japanese mothers to pass nationality to their children. However, this expansion of rights was accompanied by a new restriction: the introduction of the nationality selection system (Article 14).
This system mandates that individuals holding multiple nationalities by birth must choose a single nationality within 2 years of reaching the age of maturity. This system required Japanese citizens with multiple nationalities to renounce their foreign nationality if they opted to retain their Japanese nationality, and individuals with multiple nationality have to declare their choice. Those who fail to choose may theoretically receive a notice from the Minister of Justice, which the no-response can result in the automatic loss of Japanese nationality. This revision institutionalizes the mono-ethnic ideal, legally framing dual nationality as a temporary anomaly that must be corrected upon reaching adulthood.
While the 1985 revision was progressive in dismantling patriarchal lineage rules by allowing Japanese women to pass citizenship to their children, it simultaneously introduced a nationality selection mandate that proved structurally unenforceable. Due to the technical impossibility to grasp multiple nationality holders, and the diplomatic impossibility of forcing foreign nations to revoke citizenship other than Japan c, the Ministry of Justice has never issued the formal warnings required to strip an individual of Japanese nationality since 1985. Consequently, for decades, the system operated on a default assumption that silence equated to the retention of Japanese status, creating a vast pool of “latent” dual nationals whose existence was legally prohibited but administratively ignored.
The “Renho scandal” and the shift to surveillance
This “don’t ask, don’t tell” balance was disrupted by the 2016 “Renho scandal,” where a prominent politician (Renho, in Democratic Party of Japan) was publicly attacked for retaining Taiwanese nationality. While renouncing Taiwanese nationality is technically impossible in Japan, because Japan does not formally recognize Republic of China, and the People’s Republic of China does not accept its citizens to have more than one nationality, this scandal became widespread, exposing the government’s inability to enforce its own single-nationality principle.
Understanding this scandal requires recognizing the rise of anti-China and anti-Korea internet nationalism that intensified during this period (Higuchi, 2014), and long-lasting sexism in Japanese politics (Ando, 2022). Renho’s Taiwanese heritage, together with her possibility of becoming the female leader of the opposite party, made her a target for racist/sexist sentiment that questioned whether individuals with Chinese/Taiwanese connections could be “truly Japanese,” regardless of their legal citizenship status. This racialized dimension of the scandal reveals how administrative enforcement of mono-nationality intersects with ethnic nationalism in ways that disproportionately affect those with Asian heritage.
This shifted the administrative logic from benign neglect to active detection. Following the scandal, passport applications began to include stricter inquiries into foreign nationality status. Members of the JAIF reported being questioned about their nationality status during passport renewals, even after submitting notifications of nationality selection. This marked a transition from passive tolerance to active surveillance, where the passport application became a site for “confessing” one’s deviation from the Japanese norm.
Combined by the increased public attention dual nationals and the shift of administrative policy prompted a wave of individuals to renounce their Japanese citizenship. Over the past 8 years, the number of individuals renouncing Japanese nationality has steadily risen, with Ministry of Justice data showing that 22,196 individuals had relinquished their Japanese citizenship by the end of 2023.
Situating renunciation within Japan’s demographic crisis clarifies the ideological stakes of the current regime. Faced with population decline, the state invests heavily in pronatalist policies and selective labor migration while simultaneously maintaining a legal architecture that encourages or effectively forces some citizens to abandon Japanese nationality rather than recognize plural belonging. This paradox makes sense only when read through the lens of mono‑ethnic nation‑state ideology: preserving the fiction of a singular, undivided national identity is treated as more important than retaining the actual people who hold Japanese citizenship.
Analysis
The newsletters of the JAIF reveal that for dual nationals, the passport is not merely a travel document but a site of constant negotiation with the state. This section categorizes these negotiations into three dimensions: the orthographic violence of naming conventions; the misalignment of identity verification systems; and the arbitrary enforcement of nationality laws by street-level bureaucrats.
Orthographic constraints
The first structural barrier is the incompatibility between the Japanese family registry and international naming conventions. The Japanese family registration mandates a single Japanese name written in Japanese script, rejecting “foreign” punctuation such as spaces or hyphens. When transcribed into the Roman alphabet for a passport, this creates a discrepancy between the subject’s Japanese identity and their identity in their other country of citizenship.
The erasure of spaces and hyphens
The rigidity of the system is illustrated by a 1994 case involving a dual British-Japanese child, Fiona Keiko. When applying for a passport renewal, the mother included a space between the first and middle names, consistent with the child’s British documentation. The passport office initially rejected this, insisting on “FIONAKEIKO” as a single string of characters, citing the principle of Japan’s family registration that a name is a single entity. Although the office eventually conceded to a space as a special measure after the mother protested, the official stance remained that the previous passport’s spacing was an error to be corrected.
Another case was reported in 2012, involving a Japanese woman married to a German citizen. In Germany, she legally registered her surname as “Yamashita-Huschka”. However, because Japanese law prohibits hyphens, her Japanese passport combined the names into “Yashitahuschka”, which is almost unreadable for both Japanese and German border guards. To prove her identity abroad, she was forced to carry a copy of her German family register with an explanatory note. Unaware that she could have applied for a space (a discretionary allowance often unadvertised), she eventually resorted to the Japanese Family Court to legally change her name, noting the high cost of ignorance regarding administrative loopholes. The woman was unaware that she could apply for a space between her names, later reflecting: “It is terrifying not to know; I felt such regret afterward” (JAIF Newsletter, Issue 340(1), March 2012, p. 10).
The struggle for non-Hepburn Romanization
Further complications arise from the mandatory use of Hepburn Romanization, which often distorts the phonetic reality of foreign names. In 1994, a mother fought to have her French-Japanese daughter’s name, “Cecilia” written as such rather than the Hepburn-mandated “Seshiria.” By presenting past JAIF newsletters as a precedent case to the Osaka City Passport Center, she successfully negotiated for the inclusion of the French spelling in parentheses: “SESHIRIA (CECILIA).”
Similarly, a 1995 case in Thailand highlights how administrative “manuals” dictate identity. When a mother requested that her child’s Thai name be included as an alias, the consular official instructed her to obtain the Thai passport first. The official implied that holding a foreign passport was a prerequisite for the “privilege” of an alias notation. In response, the woman shared her impressions: “Given the recent increase in Japanese-Thai couples, the response felt as if there were an internal manual. I also sensed a change in the times from an interaction that seemed to even encourage the inclusion of an alias” (JAIF Newsletter, Issue 171, September 1995, p. 12). This interaction suggests that internally, the bureaucracy had begun systematizing the management of dual nationals, treating the alias not as a right, but as a concession granted only upon proof of foreign status.
Recent legal and administrative reforms underscore that Romanization remains an active site where Japanese‑ness is encoded. The 2025 revision of the Family Register Law and the concurrent shift in official practice from Kunrei- to Hepburn Romanization standardized a particular way of rendering Japanese sounds into the Latin alphabet. While his appears as a technical adjustment aimed at global readability, in combination with continued refusal to accommodate hyphens, middle names, or non‑Japanese naming orders, it consolidates a template of “proper” Japanese names that privileges certain phonetic and orthographic forms while marginalizing others.
Such rules of naming and orthography first affected Zainichi Koreans, who had lived in Japan since the pre-war period. When they applied for Japanese nationality, local authorities refused to allow them to retain their Korean ethnic names, forcing them to adopt “Japanese-style” names and informing them that their applications would otherwise be denied. In 1982, 10 Zainichi Koreans who had obtained Japanese nationality filed petitions in local family courts, seeking to register their ethnic names as their formal names in the koseki. They formed the “Minzoku mei wo torimodosu kai” (Association to Reclaim Ethnic Names) in 1985. In the same year, the revised Nationality Act was enacted, and in 1987, the recording of the aforementioned Zainichi Koreans’ ethnic names in the family register was officially permitted (Minzoku mei wo torimodoshita kai ed, 1990). As a result, koseki administration started to accept “irregular” names and orthographies in koseki registration.
This history demonstrates how individual legal challenges to bureaucratic naming conventions that is initially led by Zainichi Koreans paved the technical and legal way for various orthographies now sought by dual nationals. It also highlights a shift in the state’s role from an entity that enforces cultural assimilation through mandatory ‘Japanese-style’ names to one that manages diversity through selective administrative concessions.
The outsourcing of borders: Private gatekeepers and identity aps
The second dimension of the challenge arises when state border control is outsourced to private entities, specifically, airlines.
The airline as border guard
Because dual nationals often hold passports with different names (due to the orthographic constraints discussed above), they are frequently flagged as security risks by airline systems that demand a strict “one person, one name” match. At the same time, the method of navigating the two systems creates a crisis of administrative legibility. When a dual national holds two passports with inconsistent naming conventions, their identity as a single individual is no longer guaranteed by the state’s documents. A report in JAIF Newsletter in October 2008 (Issue 309, pp. 3–4) by a Japanese mother of a Japanese-German dual national child highlights this precariousness. The child’s German passport listed only the German family name, while the Japanese passport included the mother’s Japanese family name in parentheses—a standard but often confusing Japanese administrative practice for dual nationality holders. The mother expressed deep anxiety that this discrepancy would prevent her child from traveling from Japan to Germany. She feared that German airline staff would refuse to issue a boarding pass for her child because the name on the ticket did not perfectly match the primary name field in either passport. Ultimately, the mother managed the situation by having the airline include both the German and Japanese surnames on the ticket. Although this hybrid name did not strictly match either passport’s official data field, it provided enough administrative “common ground” for identity verification.
Reflecting on this experience, the mother wrote: “While a mismatch between a ticket and a passport is certainly a problem, in the case of dual nationality, there is a clear and justifiable reason for it. At the boarding gate, the primary issue is not why one holds two passports, but rather the verification of the individual against the ticket.” This case illustrates the reality of “borderwork” performed by dual nationals: they must personally bridge the gap between two incompatible state systems by negotiating with private actors (airlines) to ensure their mobility is recognized, even when their official identity remains “fragmented” on paper.
Another illustrative case from March 2012 involves a 24-year-old Japanese-German dual national living in Germany (JAIF Newsletter, March 2012, p. 10). The woman, who had been staying in Japan on her Japanese passport, decided to extend her stay after finding work. She temporarily returned to Germany to settle her affairs and purchased a one-way ticket back to Japan through a Japanese travel agency in Germany. The agency processed her booking as a returning Japanese citizen, using the name on her Japanese passport, which included her Japanese maternal family name alongside her German paternal family name.
The trouble started at the check-in counter in Germany. When she presented her German passport, the staff noticed critical discrepancies: first, she was a German citizen traveling to Japan on a one-way ticket without a visa, a scenario for which the airline refused to take responsibility. Second, the name on her ticket (which included her Japanese family name) did not match the name in her German passport (which did not include her Japanese family name). The woman hesitated to present her Japanese passport, being feared that revealing her dual nationality might lead to the immediate confiscation of her passport or the loss of her Japanese or German nationality, especially since she had not yet completed the formal nationality selection. Ultimately, she was forced to make a last-minute return booking through the travel agency and ran to the boarding gate just before takeoff.
This episode highlights two critical dimensions of administrative violence. First, it demonstrates how the airline check-in counter functions as a rigorous site of identity verification where the slightest orthographic mismatch between the ticket and the passport can trigger a denial of mobility. Second, it reveals the profound psychological burden placed on dual nationals. The state of anxiety regarding nationality loss, fueled by vague legal threats and communal misinformation, forces individuals to navigate the border with double identities, even when the possession of a second passport would legally resolve the conflict.
The difficulties JAIF members and their families face at airport check-in counters illustrate a broader shift in the governance of mobility. In an effort to interdict “undesirable” travelers before they reach territorial soil, modern states have deputized commercial carriers as the first line of border defense. Under the threat of heavy fines for transporting undocumented passengers, airlines operate with a risk-averse logic that is often stricter than that of the state itself. However, in the Japanese context, this global phenomenon produces a unique orthographic trap. Unlike standard immigration officers who may have access to discretionary judgment or secondary databases, airline personnel interact with the passenger solely through the rigid interface of the Global Distribution System and the passport. When a dual national’s ticket booked under a Japanese name fails to match their foreign passport used for visa-free entry into a third country, the passenger appears to the airline not as a citizen, but as a data error or a security risk. This privatization of border control creates a perilous gap for dual nationals: they possess the state’s guarantee of protection (the passport), but they are immobilized by the market’s demand for data consistency. The anxiety expressed by JAIF members reveals how the Japanese state has effectively outsourced the policing of its mono-ethnic naming conventions to the private sector.
Such outsourcing is supported by the legal system. Japan’s Immigration Control and Refugee Recognition Act, Articles 71 to 74, defines the obligations of airline companies; if airline companies carry passengers without valid passports or visas, they are not only subject to expensive fines but also required to bear the costs of deportation. Therefore, what the airlines fear most is a discrepancy between the names provided at check-in, the names in the passport, and the names registered in Japan’s immigration system. Japanese passports and the immigration system are strictly based on koseki, which assumes only two elements of a surname and a given name without hyphens or middle names. Here, state does not directly exclude individuals who deviate from the “Japanese-style” name registration prescribed by the koseki. Instead, by delegating risk management to private companies, those who fall outside the logic of the koseki (i.e. a single name) are automatically identified. To avoid risk, airline companies may treat elements that deviate from koseki-derived names such as foreign-style middle names or spaces not only as system errors but also as grounds for suspecting forged passports.
While passports and biometrics are originally intended to identify a specific individual, Japanese practice prioritizes perfect data matching with the koseki text upon which the passport is based. Even if dual nationals can physically prove their identity, their movement is restricted simply because their name format differs from “standard Japanese notation.” This implies that the Japanese state recognizes its citizens not as living individuals, but only as members linked to a monoethnic lineage, namely, koseki. While middle names and spaces held by dual nationals are common under international standards, they are considered “non-standard” in Japanese koseki notation. The system that automatically detects this “non-standard” status as an “error” or “deficiency” can be seen as the embodiment of an ideology that regards only those with a single name and a single background as correct Japanese.
The honseki-chi versus place of birth
The idiosyncratic nature of the Japanese passport extends beyond naming conventions to the very categories used to define a subject’s origin. In 2015, two cases were reported in Düsseldorf, Germany, where Japanese passports were rejected as valid identification at local post offices because they lacked a “place of birth” field (JAIF Newsletter, Issue 362, p. 11). Specifically, Japanese residents in Germany attempting to open online bank accounts utilized the PostIdent service (a system where postal employees verify an individual’s identity on behalf of the bank). However, because Japanese passports record the place of (family) origin (honseki-chi in Japanese) rather than the place of (individual) birth, the document was deemed insufficient for the German identification protocol. One contributor expressed their frustration saying that “[i]n Germany, identifying an individual requires their name, date of birth, and place of birth (. . .). It is a constant source of trouble that the Japanese passport only lists the honseki-chi”.
Actually, the omission of the place of birth is not unique to Japan: other states, such as Saudi Arabia, South Korea, Switzerland (which records only “place of origin”), and, until recently, Vietnam, also issue passports without birthplace information. Moreover, under recent ICAO guidelines, birthplace is classified as an optional, not mandatory, field, partly in response to growing privacy and anti‑discrimination concerns.
The issue, therefore, is not that Japan deviates from an imagined global standard of including birthplace, but how it chooses to guarantee identity in the absence of such information. This administrative friction highlights a fundamental clash between two different systems of “state legibility” (Scott, 1998). While other countries (in this case, Germany), bureaucratic systems rely on the static, biological fact of one’s birth location to anchor an individual’s identity, the Japanese state remains tethered to the logic of the honseki-chi in the family registration, a purely administrative and often symbolic location that may have no geographical connection to the individual’s actual life. Rather than relying on biometrics or birthplace data as primary anchors of identity, Japan continues to treat the family register (koseki) as the definitive proof of who a citizen is. From this perspective, the passport functions less as an autonomous individual document and more as a mobile extract of a domestic family‑based registry.
Legal ambiguity and street-level bureaucracy
The third and perhaps most precarious issue is the arbitrary application of the law. While Japanese law theoretically requires the renunciation of foreign nationality, there is no penalty for inaction for those born with dual nationality. However, the lack of clear standard operating procedures allows individual officials (street-level bureaucrats) to enforce their own interpretations of the law.
In 1995, a Japanese consulate in Shanghai refused to issue a passport to a dual-national child, citing Chinese law, which forbids dual nationality. The consular official, prioritizing local law over Japanese nationality rights, instructed the parent to obtain a Chinese passport and a Japanese visa instead. The parent argued that a Japanese citizen should not require a visa to enter Japan, yet the official denied their request based on the “lack of precedent.” This creates a legal contradiction: as the Immigration Bureau clarified in 2006, if a Japanese citizen enters Japan using a foreign passport (as a “foreigner”), they are statistically recorded as such. If they fail to cancel their resident status upon realizing their error, they may technically become “illegal overstayers” in their own country of citizenship.
Administrative pressure has intensified in recent years. In 2012, reports surfaced of passport offices demanding that dual nationals sign a confirmation form, acknowledging they were aware that holding dual nationality could be a crime. In the newsletter, the contributor reports as the following:
This applicant is a dual national by birth and explained to the counter staff that the contents of this confirmation form did not apply to her. However, the staff member did not seem to understand the distinction, claiming that “all dual nationality holders are required to submit it” and that “dual nationality is likely to be more restricted in the future.” As she got frustrated, the applicant called the Ministry of Foreign Affairs directly, but was simply told that since authority is delegated to local jurisdictions, they should follow the instructions of the specific office. Ultimately, the applicant went to the Haneda Passport Office and successfully renewed their passport without being asked to submit those documents. (JAIF Newsletter, Issue 338, January 2012, p. 12)
This form, originally intended for those who voluntarily acquired foreign nationality (and thus lost Japanese nationality), was wrongly forced upon birth dual nationals by confused staff in passport centers.
By 2022, this surveillance became formalized. The passport application form now includes mandatory fields for foreign nationality, requiring applicants to detail when and how they acquired it. JAIF members warn that answering “No” to this question constitutes a violation of Article 23 of the Passport Law (punishable by prison or fine). Consequently, dual nationals are forced to self-report their “gray” status. The detailed categorization, distinguishing between “acquisition by birth” (legally safe) and “voluntary acquisition” (potentially disqualifying), places the burden of legal proof entirely on the applicant. The introduction of the confirmation form in 2012 and the subsequent revision of passport application forms in 2022 to include mandatory declarations of foreign nationality represent a significant shift in administrative power.
These episodes share a common reality: the judgment and level of understanding of frontline officials often take precedence over, or are conflated with, statutory provisions. In the 1995 case, the consulate refused to issue a Japanese passport to an individual who should have held Japanese nationality, citing China’s nationality law (which does not recognize dual citizenship). In the 2012 case, an official coerced a dual national by birth (who is not subject to penalties) into signing a “Confirmation Form” (acknowledging potential penalties) intended for those who voluntarily acquire foreign nationality. The official also offered personal, unsubstantiated views, such as “there is a trend toward restricting dual nationality.” Furthermore, inconsistencies can be seen across different offices; for example, documents required at a passport office in Haneda were not required at another office for the same application. When inquiries were made to the Ministry of Foreign Affairs regarding these discrepancies, the response was that matters are “left to each jurisdiction,” or it appeared that decisions were made at the sole discretion of the consul. This suggests a tendency for the central authority to either endorse or neglect the individual judgments made at the frontlines.
Such cases specifically illustrate the risk that dual nationals, despite the fact that they hold Japanese nationality, may be treated as “foreigners” depending on whether they possess a Japanese passport. In the 1995 case, if one cannot present a document proving Japanese nationality (such as a passport), they must enter as a “foreigner” using their other country’s passport, resulting in the individual being required to obtain a visa that should have been unnecessary. Additionally, according to a 2006 response from the Immigration Bureau, if a Japanese national enters on a foreign passport and fails to perform the proper procedures to cancel their residency status, they could, statistically and in appearance, fall into a state of “illegal overstayer.”
Furthermore, there is a serious conflation between the nationality selection system and the issuance of passports. Inherently, the failure to submit a declaration of nationality choice is not a valid legal reason to refuse a passport application. However, cases occur at the frontline level where applications are rejected precisely because the declaration has not been submitted. In this situation, dual nationals are caught between three Japanese laws (the Nationality Act, the Immigration Control Act, and the Passport Act) as well as the systems of their other country, facing difficulties that restrict their freedom of movement. Additionally, when dual nationals use different passports, the lack of an exit record in one country may be viewed as a problem during their next entry, showing that individuals carry the risks created by these institutional gaps.
These cases reveal that the discretion of the window often exceeds official Ministry of Foreign Affairs views or legal grounds. Even when an individual asserts legal validity, they are often turned away with excuses like “there is no precedent” or “it is up to the jurisdiction.” Despite being “purely Japanese,” dual nationals are placed in an unstable position where procedural deficiencies (such as not carrying a passport) can easily result in them being treated as “foreigners”, who are subject to visa requirements or classified as illegal residents.
Of course, discretion does not always function oppressively. While the cases analyzed in this article focus on discretion as a form of oppression, it can also act as a means of salvage or relief that ultimately can lead to change the administrative procedure or even the legal system. However, when the deficiencies of a system or institution are filled in street-level bureaucracy, whether it leads to exclusion or inclusion, the outcome depends entirely on the knowledge, perceptions, and conscience of individual officials and the interaction at the service counters. Such precarity itself signifies that the right to mobility for dual citizens is being downgraded from a right to a “mercy”.
Post-pandemic trends
Furthermore, in 2022, as mobility restrictions associated with COVID-19 began to ease, new problems faced by multiple passport holders were reported. In one instance, a former Japanese national who acquired U.S. citizenship (thereby losing Japanese nationality) applied for permanent residency in Japan to take care for the family member, but the application was rejected. As a result, they had to go through the process of re-acquiring Japanese nationality to achieve their goal. In another case, when applying for a Japanese passport for a child who previously traveled between Japan and abroad using a foreign passport, the parent was told to present their own foreign residence permit. In a third case, a Japanese couple (one holding U.S. permanent residency, the other holding U.S. citizenship) attempted to renew a Japanese passport; the spouse with permanent residency was told to present the U.S. citizen spouse’s residency permit and was informed the application would not be accepted if they refused (JAIF Newsletter, No. 7, April 2022).
These cases confirm that the following practices are being implemented: first, during passport renewals for Japanese nationals or applications for children, officials are demanding the foreign residence permits of parents or spouses. If the applicant refuses to present these specific documents, the application itself is not accepted at the frontline. Additionally, in recent years, the passport application form has included mandatory fields to declare the possession of foreign nationality, the date of acquisition, and the method of acquisition. Failing to declare foreign nationality (marking “No”) despite possessing it falls under Article 23, Paragraph 1 of the Passport Act (False Statements), and is subject to penalties (up to 5 years of imprisonment or a fine of up to 3 million yen).
Discussion: The administrative enforcement of the mono-ethnic myth
The episodes and descriptions drawn from 40 years of JAIF newsletters reveal that the difficulties faced by dual nationals are not merely bureaucratic inefficiencies or technical glitches. Rather, they represent a structural conflict between the reality of transnational lives and a state apparatus designed to enforce a mono-ethnic national identity. This section analyzes how the Japanese state manages and marginalizes multiple identities through three specific mechanisms: (1) the incompatibility of the family registry system with global mobility; (2) the outsourcing of surveillance to private gatekeepers; and (3) the discretionary power of street-level bureaucrats.
The family registration versus the body: Orthographic violence and the household logic
The fundamental source of friction for dual nationals lies in the disjuncture between the logic of the family registry and the logic of the international passport. As Torpey (2000) argues, the passport is a tool for the state to embrace the individual body to monopolize the movement. However, in Japan, the primary unit of governance is not the individual, but the ie (household) as defined by the family registration.
The family registration system is predicated on a static, domestic, and mono-ethnic model. It requires a single Japanese surname, prohibits “foreign” punctuation (spaces, hyphens), and anchors identity to a honseki-chi (ancestral domicile and the place of family origin) rather than a physical place of birth of individual. When this domestic logic is projected onto an international travel document, it produces what can be termed as orthographic violence. The erasure of a space (e.g. forcing “FIONA KEIKO” into “FIONAKEIKO”) or the removal of a hyphen (transforming “Yamashita-Huschka” into “Yamashitahuschka”) is not a trivial formatting issue, but an administrative act that renders the dual national’s legal name in their other country of citizenship invalid in the eyes of the Japanese state.
This forces the dual national into an impossible bind; to be legible to the Japanese state, they must accept a distortion of their identity that renders them illegible to global systems (such as foreign banks or visa authorities). Conversely, to maintain their global identity, they are treated as “exceptions” within Japan, requiring special annotations or family court interventions. The mono-ethnic myth is thus maintained not just ideologically, but technically, by stripping the “foreignness” (middle names, hyphens) from the official record to force the diverse body into a standardized Japanese mold.
Outsourcing border control: The glitch in the machine and system
In the age of digitized borders, the management of identity is increasingly outsourced to non-state actors, particularly airlines. As noted in the analysis, airlines act as strict gatekeepers, enforcing a “one name, one person” logic to avoid liability for transporting undocumented passengers.
For the mono-ethnic Japanese citizen, the passport and the airline ticket align seamlessly. However, for the dual-/multiple nationality holders, whose identity is often split across two or several passports with different names due to the family registration restrictions discussed above, this alignment fractures. The dual national appears as a system error or a security risk. The case studies reveal that the discrepancy generates a specific form of disciplinary power that can result in the fear of statelessness or confiscation. The anxiety expressed by members that showing both passports might lead to confiscation or loss of nationality demonstrates how the state’s ambiguity is internalized as self-censorship.
The airline counter thus becomes a site where the mono-ethnic myth is policed by private sector. The necessity for dual nationals to engage in survival strategies, such as asking travel agents to manually merge names on tickets highlights their precarity. They are citizens who hold the “world’s strongest passport,” yet their mobility is contingent on constant negotiation and the benevolence of ground staff, revealing that the privilege of the Japanese passport is reserved only for those who fit the “standard” mono-ethnic definitions.
Street-level bureaucracy and the production of precarity
Finally, the newsletters highlight how street-level bureaucracy plays a major role in defining the rights of dual nationals. Because the Japanese Nationality Act tolerates dual nationality in practice while prohibiting it in principle, there are no standardized administrative procedures. This legal gray zone gives individual officials at passport centers and consulates excessive discretionary power. Cases like the 1995 refusal of a passport in China based on local law or the arbitrary demand for a confirmation form in 2012 show that the ability to travel often depends on the personal interpretation or mood of the clerk at the window.
This arbitrariness serves a disciplinary function. By keeping the rules ambiguous and dependent on individual discretion, the dual nationals in Japan are kept in a state of insecurity. The recent introduction of mandatory questions regarding foreign nationality on passport applications signifies a shift from benign neglect to active surveillance. By forcing applicants to declare their foreign status under threat of punishment (Passport Act of Japan, Article 23), the administration forces the dual national to constantly confess their deviation from the mono-ethnic norm, thereby reinforcing their status as “other” even while they hold Japanese nationality.
The experiences of JAIF members challenge dominant sociological theories regarding mobility in the neoliberal age. Ong (1999) famously described the strategy of “flexible citizenship,” where elite subjects accumulate passports and residency rights to maximize their economic power and evade state regulation. In this framework, multiple nationalities are an asset, namely, a form of cultural capital that facilitates fluid movement across borders. The subjects of this study are typically middle-class professionals with the passports of Japan, who should benefit from the mobility of flexible citizenship. However, the cases analyzed here show the limits of this logic. Despite having the economic resources to travel internationally, these dual nationals often find their mobility restricted by the rigid requirements by the Japanese legal and administrative system. The state’s refusal to accept hyphens in names, or airlines’ refusal to board passengers with “inconsistent” identities, demonstrates that Japan prioritizes maintaining a mono-ethnic national image over facilitating the free flow of human capital. For dual nationals, the Japanese passport provides global access only if they erase the complexity of their multi-national identities. This proves that even in a globalized economy, the state’s emphasis on family and lineage remains a powerful force that restricts the movement of its citizens.
Conclusion
This article analyzed 40 years of newsletters from the Japan Association of Intercultural Families (JAIF) to identify the structural mechanisms that marginalize dual nationals in Japan. By examining the friction between the koseki (family registry) and the international passport, this paper offers three main conclusions.
First, the myth of the mono-ethnic nation is materialized through daily administrative procedures. The barriers facing dual nationals stem from the conflict between the domestic logic of the koseki, which prioritizes the household unit and single Japanese names, and the international logic of the passport, which requires individual differentiation. When the state forces dual nationals to remove spaces or hyphens to match the family registry, it is an administrative effort to make a “deviant” identity fit the standard Japanese model.
Second, this study clarifies that the “privileged mobility” of the Japanese passport is actually conditional. Although the passport offers high visa-free access to almost all countries and regions, this privilege is reserved for those who fit the state’s singular definition of a Japanese citizen. For dual nationals, the passport can become a source of vulnerability. Because the state outsources border checks to private actors like airlines, dual nationals are frequently flagged for data errors. The fear of passport confiscation or being denied boarding shows that, for these subjects, citizenship does not guarantee mobility; instead, it triggers increased surveillance.
Third, the administrative barriers identified, such as the “confirmation form” and the rejection of foreign naming conventions, suggest that digital modernization is not making border control more inclusive. As systems become more digitized and integrated with the family registration, the exclusion of individuals with multiple nationalities becomes more efficient. These administrative difficulties are not system failures; they are the result of a system designed to eliminate identity complexity.
Ultimately, these mobility issues cannot be fixed with minor technical changes or better staff training. The problem is the continued use of a Meiji-era, household-based model of nationality for a globalized population. To resolve these tensions, Japan needs reconsider the family-based, or jus koseki definition of citizenship and move toward a system that legally recognizes the complex realities of its citizens, eventually changing its definition of the Japanese.
