“We are short of workers and want to hire Specified Skilled Worker foreign nationals. But we have only ever taken on jobs under ¥5 million, so we do not hold a construction business licence.” This article is for owners and general affairs staff of construction companies who are thinking along these lines. In the construction field, holding a construction business licence (建設業許可) is a precondition for accepting Specified Skilled Workers (特定技能). Without a licence, you cannot obtain certification of the “Construction Specified Skilled Worker Acceptance Plan (建設特定技能受入計画)” from the Ministry of Land, Infrastructure, Transport and Tourism (MLIT), and the residence status application cannot move forward either. Based on published materials from MLIT, Chiba Prefecture and the Immigration Services Agency of Japan, this article sets out what a company without a licence needs to do, in what order and over roughly what period, before it can welcome Specified Skilled Worker foreign nationals.
Sources: “Policy on the Operation of the System Relating to the Residence Status of Specified Skilled Worker in the Construction Field and Policy on the Operation of the System Relating to Employment for Skill Development” (Cabinet decision of January 23, Reiwa 8 (2026)) / Ministry of Justice and MLIT, “Operational Guidelines on the Acceptance of Specified Skilled Worker Foreign Nationals in Specific Fields: Standards for the Construction Field” (partially revised January 31, Reiwa 7 (2025)) / MLIT, “Online Applications for the Construction Specified Skilled Worker Acceptance Plan [New]” (April 4, 2025), “Specified Skilled Worker System (Construction Field) FAQ,” “Licensing Requirements,” and “Comparison Table of Old and New Provisions: Revision of the Supervising Engineer System Operation Manual (December 13, Reiwa 6 (2024))” / e-Gov Law Search, “Construction Business Act,” “Order for Enforcement of the Construction Business Act,” “Employment Security Act” / Chiba Prefecture, “Construction Business Licence Guide (April Reiwa 8 (2026) edition)” / Japan Association for Construction Human Resources (JAC), “Manual for Accepting Foreign Nationals,” “FAQ,” “Membership Information” / Foundation for Construction Industry Promotion, “Construction Career Up System: Guide to the Business Operator Information Registration Application” / Immigration Services Agency of Japan, “Application for Certificate of Eligibility,” “Application for Change of Status of Residence,” “Notifications by Specified Skilled Worker Accepting Organizations and Registered Support Organizations,” “Approval Procedures for Application Agents,” “How to Fill In the Periodic Notification and Points to Note” / e-Gov Law Search, “Administrative Scriveners Act”
One-stop support for construction companies. From obtaining a construction business licence to the application for certification of MLIT’s acceptance plan, CCUS registration and residence status applications, our office, as an administrative scrivener (行政書士) office, takes on everything together. Labour and social insurance, accounts and tax filings, and legal issues are also accepted at our office’s counter, in cooperation with our partner labour and social security attorney, tax accountant and lawyer.
A Construction Business Licence Is a Prerequisite for Specified Skilled Workers in Construction
The field-specific operational policy (分野別運用方針) for the construction field lists, as the first of the conditions imposed on companies that accept Specified Skilled Worker foreign nationals (Specified Skilled Worker accepting organizations, 特定技能所属機関), “holding a licence under Article 3 of the Construction Business Act (建設業法) (Act No. 100 of Showa 24 (1949)).” MLIT’s public notice (MLIT Public Notice No. 357 of Heisei 31 (2019)) sets out the same requirement for certification of a Construction Specified Skilled Worker Acceptance Plan.
Why is a licence required? The policy points out that in the construction industry the place of work changes from job to job, so employment must be managed site by site, and that the workload rises and falls with the season and the order situation, so pay tends to fluctuate. For these reasons, it states that particular care is needed for the working environment of foreign nationals. The Operational Guidelines (運用要領) explain that one purpose of certifying the acceptance plan is “to maintain a fair competitive environment by not allowing companies found to have poor working conditions, such as employing workers on low wages or without social insurance enrollment, to enter the construction market.” The licence serves as the check at that entrance.
If You Only Do “Minor Construction Work,” No Licence Is Needed — But You Cannot Accept Workers
Under the proviso to Article 3, paragraph 1 of the Construction Business Act, a company that only takes on “minor construction work (軽微な建設工事)” can operate without a licence. Minor construction work is defined in Article 1-2 of the Order for Enforcement of the Construction Business Act as follows.
| Type of work | Work that may be contracted without a licence |
|---|---|
| Work other than comprehensive building construction work (建築一式工事) | Contract price per job under ¥5 million (tax included) |
| Comprehensive building construction work | Contract price per job under ¥15 million (tax included), or work on a wooden house with a total floor area under 150㎡ |
Even if the same work is split into two or more contracts, the total amount is used unless there is a legitimate reason. Where the client supplies materials, their market price and transport costs are added to the contract price (paragraphs 2 and 3 of the same Article). “Tax included” follows the wording of Chiba Prefecture’s guide.
A company that has operated within this range has no problem under the Construction Business Act. For accepting Specified Skilled Workers, however, holding a licence is itself a requirement. Everything starts with obtaining a licence.
The Type of Work in the Licence Does Not Have to Match the Foreign National’s Work
MLIT’s FAQ states that even if the type of work covered by the licence does not match the occupation in which the Specified Skilled Worker will work, a company that holds a construction business licence of any type does not need to obtain a new licence of the same type. However, the foreign national’s duties must constitute construction work, and the work category (civil engineering, building, lifelines and equipment) must correspond to the test the worker passed or the technical intern training (技能実習) the worker completed.
Another requirement is that, within the 5 years before the date of the acceptance plan application and thereafter, the company has not been subject to a supervisory disposition under the Construction Business Act (excluding revocation of the licence because grounds for a notification such as discontinuance of business arose, i.e. Article 29, paragraph 1, item 5 of the same Act). MLIT’s application guide cautions that, whether the disposition was an instruction order, a business suspension order or a revocation, acceptance is not possible for 5 years from the disposition.
In addition, under Employment for Skill Development (育成就労), which starts on April 1, Reiwa 9 (2027), accepting companies in the construction field will also be required to hold a construction business licence (Part Three of the same field-specific operational policy).
Main Requirements for a Construction Business Licence (Under Their Current Names)
To obtain a licence, you must meet the standards of Article 7 of the Construction Business Act (Article 15 for specified construction business) and must not fall under the grounds for disqualification in Article 8. Some requirements have been renamed by amendments, so we set them out under their current names.
| Requirement | Key points | Basis |
|---|---|---|
| Capacity to properly manage business operations | Appointing a full-time officer, etc. (常勤役員等; formerly the “manager of business administration,” 経営業務の管理責任者) — for example, a full-time officer with 5 years or more of experience as a manager of business administration in the construction business. Filing as an establishment covered by health insurance, employees’ pension insurance and employment insurance (enrollment in social insurance) is also part of this requirement | Act, Art. 7, item 1 |
| Office engineer (営業所技術者) | An engineer assigned full-time to each business office. A national qualification; graduation from a designated course plus practical experience (5 years or more after high school graduation, 3 years or more after university graduation); or 10 years or more of practical experience | Act, Art. 7, item 2 and Art. 15, item 2 |
| Integrity | It must not be evident that the company or its officers, etc. are likely to engage in dishonest or insincere conduct in relation to contracts for work | Act, Art. 7, item 3 |
| Financial basis | For general construction business, any one of: equity of ¥5 million or more; the ability to raise ¥5 million or more; or continuous operation under a licence for the preceding 5 years | Act, Art. 7, item 4 |
| Grounds for disqualification | Not falling under grounds such as being bankrupt without having had one’s rights restored, fewer than 5 years having passed since completing a sentence of imprisonment without work (禁錮) or heavier, or being a member of an organized crime group, etc. | Act, Art. 8 |
The office engineer used to be called the “full-time engineer” (専任技術者). Under the amendment of the Construction Business Act that took effect on December 13, Reiwa 6 (2024), the role is now called the “office engineer” for general construction business and the “specified office engineer” (特定営業所技術者) for specified construction business.
The part of the preparation that tends to take the longest is proving management experience and practical experience. Chiba Prefecture’s guide requires you to submit, for each year of the period being proved, one contract, purchase order or similar document that shows the content of the work. If a document does not bear the other party’s seal, a copy of a bank passbook or similar record confirming receipt of payment is also needed. If you meet the office engineer requirement through 10 years of practical experience, you will need to gather 10 years’ worth of documents.
Governor’s Licence and Minister’s Licence; General and Specified
Licences are classified by which authority grants them and by the scale of subcontracting you place.
| Category | Content | Basis |
|---|---|---|
| Governor’s licence (知事許可) | Where all business offices are located within one prefecture (if only within Chiba Prefecture, the Governor of Chiba Prefecture) | Act, Art. 3, para. 1 |
| Minister’s licence (大臣許可) | Where you have business offices in two or more prefectures | Act, Art. 3, para. 1 |
| Specified construction business (特定建設業) | Where, for a single job taken on as prime contractor, you conclude subcontracts whose total value is ¥50 million or more (¥80 million or more for comprehensive building construction work) | Act, Art. 3, para. 1, item 2; Enforcement Order, Art. 2 |
| General construction business (一般建設業) | All other cases | Act, Art. 3, para. 1, item 1 |
A company that has so far focused on minor work will in most cases start with a “governor’s licence for general construction business.” A licence is valid for 5 years and lapses unless it is renewed (Act, Article 3, paragraph 3).
As for public fees, Chiba Prefecture’s guide states that the fee for a new application for a governor’s licence is ¥90,000 (paid with Chiba Prefecture revenue stamps), and that a new minister’s licence requires registration and licence tax of ¥150,000. The fee is not refunded even if the licence is not granted or the application is withdrawn.
Review Period for a Chiba Prefecture Governor’s Licence
Chiba Prefecture’s guide gives the standard processing period as “45 days from submission of the application, unless corrections are particularly needed.” The count starts from acceptance at the Civil Engineering Office (土木事務所) or from the submission of correction materials. Paper applications are submitted to the Civil Engineering Office (or its branch office) with jurisdiction over the location of the main business office. Electronic applications (via the Construction Business Licence and Management Matters Review Electronic Application System, 建設業許可・経営事項審査電子申請システム) are also accepted.
If corrections are needed, the period is extended accordingly. The prefecture also advises applicants to “apply with time to spare.” It is important to plan the steps toward the licence early, including the time needed to gather documents.
Steps After the Licence, Up to Accepting Specified Skilled Workers
Obtaining the licence does not mean you can accept foreign nationals straight away. MLIT’s application guide requires CCUS business operator registration and JAC membership to be complete at the time you apply for certification of the acceptance plan (“You cannot apply while your registration application is pending”; “You cannot apply while your membership application is pending”). The overall flow is as follows.
- Obtain the construction business licence — For a Chiba Prefecture governor’s licence, the standard processing period is 45 days.
- CCUS business operator registration — The Construction Career Up System (CCUS) is an industry-wide system that records skilled workers’ qualifications and work history. You can apply for business operator registration without a construction business licence; if you obtain a licence after registering, you add the licence number through an application to change the registered details. This is a procedure you can start preparing while the licence is still under review.
- Join JAC — The Japan Association for Construction Human Resources (JAC), a general incorporated association, is the industry body responsible for the acceptance of Specified Skilled Workers in the construction field. You either join a construction industry association that is a regular member of JAC, or join JAC directly as a supporting member.
- Post a job opening at Hello Work — As confirmation of efforts to secure workers in Japan, you must attach a Hello Work (public employment security office) job posting (dated within 1 year of the application date) for the same occupation as the Specified Skilled Worker and with comparable conditions.
- Explain the employment conditions and conclude the employment contract — Explain the expected remuneration and the content of the work in advance, in writing and in a language the foreign national can fully understand, and then conclude the contract. Remuneration must be a monthly salary, at least equal to that of a Japanese worker with equivalent skills, and must increase as the worker’s skills develop.
- Apply for certification of the acceptance plan — Apply online through MLIT’s “Foreign Worker Employment Management System (外国人就労管理システム).”
- Apply for residence status — An application for a Certificate of Eligibility (在留資格認定証明書交付申請) if you are bringing the worker from overseas, or an application for change of status of residence (在留資格変更許可申請) for someone already in Japan, such as a person who has completed technical intern training. A support plan (which may be entrusted to a Registered Support Organization (登録支援機関)) is prepared at the same time.
- Entry and start of work — Submit an acceptance report to MLIT within 1 month of the start of acceptance.
The published guideline periods for each stage are as follows.
| Stage | Where to apply | Published guideline |
|---|---|---|
| Construction business licence | Chiba Prefecture (Civil Engineering Office) | Standard processing period of 45 days (if no corrections are needed) |
| JAC (supporting member) | JAC | Applications received by the 25th of each month are reviewed and approved on the 2nd business day of the following month. MLIT’s FAQ says it takes about 1 month until the membership certificate is issued |
| Certification of the acceptance plan | MLIT | About 1.5 to 2 months (excluding correction periods). Several months more in some regions |
| Residence status review | Immigration Services Agency of Japan | Standard processing period: 1 to 3 months for a Certificate of Eligibility, 1 to 2 months for a change of status |
You can apply for the acceptance plan from roughly 6 months before the employment start date. The immigration application can proceed in parallel with the acceptance plan, but a copy of the acceptance plan certificate is needed to receive permission or issuance. MLIT advises filing the immigration application about 2 to 3 months before the desired start date. Simply lining up these guideline periods shows that it takes several months from the licence application to the start of work. Allowing for document gathering and corrections, it is wise to plan for about half a year.
Costs, and Points to Watch When Looking for Workers
If you join JAC directly as a supporting member, the annual fee is ¥240,000, and there is a monthly acceptance contribution of ¥12,500 for each Specified Skilled Worker (i) (1号特定技能外国人) foreign national (JAC, “FAQ”). The acceptance contribution cannot be passed on to the foreign national. If you join through a regular member association, the fees differ by association. The CCUS business operator registration fee depends on capital (¥6,000 for capital under ¥5 million), and the administrator ID fee is ¥11,400 per ID per year.
There are also rules specific to the construction field when looking for workers. Under Article 32-11 of the Employment Security Act (職業安定法), fee-charging employment placement businesses may not introduce job seekers to occupations engaged in construction work. MLIT’s FAQ also states that fee-charging placement through job magazines or job websites is illegal and cannot substitute for a Hello Work job posting. In the construction field, the system is that JAC mainly collects companies’ job openings and mediates between job offers and job seekers; free placement services such as Hello Work can also be used (Operational Guidelines).
Annual Filings After Obtaining the Licence
Obtaining the licence is not the end. As long as you continue to accept Specified Skilled Workers, maintaining the licence is a precondition. MLIT’s FAQ states that even if all the foreign nationals leave, the obligations, such as membership of JAC or a similar body, CCUS registration and the construction business licence, continue for as long as you have a certified acceptance plan.
| Filing / procedure | Deadline | Basis |
|---|---|---|
| Business Year-End Report (事業年度終了届; commonly called the “financial statement change notification,” 決算変更届) | Within 4 months after the end of each business year | Act, Art. 11, para. 2 |
| Notification of change of trade name, officers, etc. | Within 30 days of the change | Act, Art. 11, para. 1 |
| Replacement of the office engineer | Within 2 weeks | Act, Art. 11, para. 4 |
| Licence renewal | Every 5 years (in Chiba Prefecture, apply between 90 days and 30 days before the expiry date) | Act, Art. 3, para. 3 |
Under Chiba Prefecture’s guide, the Business Year-End Report is filed together with a statement of construction work history, construction amounts for the previous 3 years, financial statements, a tax payment certificate and other documents. The financial statements must follow the forms prescribed by the Regulation for Enforcement of the Construction Business Act; the financial statements submitted to the tax office cannot be used as they are.
On the Specified Skilled Worker side, the following procedures also continue.
- Reports to MLIT — The acceptance report (within 1 month of the start of acceptance), resignation reports and so on. For a worker who entered from overseas, a document showing the worker’s CCUS skilled worker ID is submitted, in principle within 1 month of entry.
- Post-acceptance training and monitoring visits — The worker must attend the post-acceptance training designated by the Minister of Land, Infrastructure, Transport and Tourism, roughly between 3 and 6 months after acceptance. The Fair Employment Supervising Organization (適正就労監理機関; the Foundation for International Transfer of Skills and Knowledge in Construction, 一般財団法人国際建設技能振興機構) carries out monitoring visits, in principle at least once a year.
- Notifications to immigration — There are ad hoc notifications, such as for the termination of the employment contract (within 14 days of the day the event occurs), and the periodic notification, filed by May 31 of the following year for the period from April 1 of each year to March 31 of the following year.
- Notification to Hello Work — This is the notification of the employment status of foreign nationals. The deadlines are set out in Notification Calendar for Companies Employing Foreign Nationals.
Requirements specific to Specified Skilled Workers in the construction field (monthly salary, the cap on the number accepted, moving to Specified Skilled Worker (ii), etc.) are explained in detail in Specified Skilled Worker in the Construction Field｜Field-Specific Requirements Such as Acceptance Plan Certification, CCUS Registration and JAC Membership.
If You Entrust These Procedures to Our Office
The procedures described above are handled at separate counters: Chiba Prefecture, MLIT, CCUS, JAC, the Immigration Services Agency and Hello Work. If you ask a different professional for each one, just keeping the content of the documents consistent takes considerable effort.
Our office accepts all of a construction company’s concerns on a one-stop basis. From the construction business licence to MLIT’s acceptance plan, CCUS registration and the residence status application, our office, as an administrative scrivener office, takes them on together. Labour and social insurance matters are handled in cooperation with our partner labour and social security attorney (社会保険労務士), accounts and tax filings with our partner tax accountant, and legal issues with our partner lawyer. Our office can also take on the day-to-day bookkeeping that is essential for the Business Year-End Report.
What an Administrative Scrivener Can Do — How We Differ from an Ordinary Registered Support Organization
Support for Specified Skilled Workers can be entrusted to a Registered Support Organization, but that does not mean a Registered Support Organization can do everything on your behalf. Preparing documents to be submitted to government offices for a fee is the work of administrative scriveners (and attorneys) (Article 1-3 and Article 19, paragraph 1 of the Administrative Scriveners Act). The Immigration Services Agency also warns that anyone other than an attorney or administrative scrivener preparing application documents and the like as a business for a fee may be in violation of the Administrative Scriveners Act.
| Procedure | Ordinary Registered Support Organization | Our office |
|---|---|---|
| Providing support to Specified Skilled Worker (i) foreign nationals | Can | Can (our office is a Registered Support Organization) |
| Preparing residence status application documents | Cannot (this is the work of administrative scriveners and attorneys) | Can (our representative is an administrative scrivener who has filed notification as an application agent (申請取次) and can also submit applications to immigration on your behalf) |
| Preparing the accepting company’s periodic and ad hoc notification documents | Cannot (the Immigration Services Agency does not allow them to be prepared by a Registered Support Organization that is not an administrative scrivener or attorney) | Can |
| Acting as agent for the application for certification of MLIT’s acceptance plan and for post-acceptance reports | Cannot (acting as agent is limited to attorneys and administrative scriveners) | Can (our office has in fact filed many applications as agent) |
In addition, our office handles CCUS registration on your behalf. We can also help you join JAC. Our office also handles construction business licences and company formation.
About Our Office
- A 98% approval rate
- On the front line of acceptance as chairman of a cooperative — Our representative previously served as chairman of a cooperative (協同組合; a supervising organization and Registered Support Organization), standing on the front line of accepting technical intern trainees and Specified Skilled Worker foreign nationals and of the related procedures and support. He is now an advisor to that cooperative.
- Even if it is your first time employing foreign nationals — Our representative served as a foreign-employment counselor (advising on residence status and related matters) at the Chiba Public Employment Security Office (Hello Work Chiba), and has many times advised companies hiring foreign nationals for the first time.
- Regarding personnel — For Specified Skilled Workers, we work together with the company on job postings with Hello Work, JAC and so on. Acceptance under Employment for Skill Development (currently Technical Intern Training) is handled in cooperation with the cooperative (a supervising organization) for which our representative serves as advisor. Engineers for construction management, design and similar roles can be introduced in cooperation with the cooperative.
Your first consultation (60 minutes) is free of charge. Online consultations are also available. Our office is a 4-minute walk from the South Exit of JR Chiba Station, and consultations are available in Japanese and Chinese.
Summary
- A construction business licence is a prerequisite for accepting Specified Skilled Worker foreign nationals in the construction field. A company that only takes on jobs under ¥5 million can operate without a licence, but cannot accept such workers as things stand.
- The type of work covered by the licence does not have to match the work assigned to the foreign national. The company must also not have been subject to a supervisory disposition under the Construction Business Act within the 5 years before the acceptance plan application.
- The standard processing period for a Chiba Prefecture governor’s licence is 45 days. Because management experience and practical experience are proved with one document per year, gathering documents takes time.
- After the licence, complete CCUS business operator registration and JAC membership, then move on to the application for certification of the acceptance plan (about 1.5 to 2 months) and the residence status application. Planning for about half a year gives you peace of mind.
- Even after obtaining the licence, you need the Business Year-End Report (within 4 months after the financial year-end), change notifications and renewal every 5 years. After acceptance, reports to MLIT, post-acceptance training, monitoring visits and notifications to immigration continue.
This article is based on information published as of October 2026. Review periods, costs and requirements may change, so please check the latest information on the websites of MLIT, Chiba Prefecture, the Immigration Services Agency of Japan and the Japan Association for Construction Human Resources.