A method for manufacturing a magnetic recording medium that has a sufficiently flat surface and includes a recording layer having a concavo-convex pattern that provides favorable accuracy of recording and reproduction. The manufacturing method includes the steps of: forming a lower non-magnetic film over a recording layer having a concavo-convex pattern; and forming an upper non-magnetic film on the lower non-magnetic film to fill concave portions 34 of the concavo-convex pattern. A bias power is applied to an object to be processed at least in the step of forming the upper non-magnetic film, and no bias power or a smaller bias power than the bias power applied in the step of forming the upper non-magnetic film is applied in the formation of the lower non-magnetic film.