A company that employs a foreign national under Specified Skilled Worker (i) (特定技能1号) is obliged to provide “support” for the person’s work and daily life. Because building an in-house structure for interpreting, regular interviews and the like is a heavy burden, many companies entrust the support to a Registered Support Organization (登録支援機関). What can be entrusted, however, is only the provision of the support. Complying with the employment contract and filing notifications with immigration remain the company’s obligations even after outsourcing.
In this article, based on the Immigration Control Act and the Operational Guidelines of the Immigration Services Agency of Japan (hereinafter the “ISA”), we set out what can be entrusted, what stays with the company, and how to choose a Registered Support Organization. It is also written for construction companies considering accepting Specified Skilled Workers.
Sources: e-Gov Law Search, “Immigration Control and Refugee Recognition Act,” Articles 2-5, 19-18, 19-20 to 19-23, 19-28, 71-4 and 76-2 / same, “Ministerial Ordinance Prescribing the Standards for Specified Skilled Worker Employment Contracts and Support Plans for Specified Skilled Worker (i) Foreign Nationals,” Article 2 / Immigration Services Agency of Japan, “Operational Guidelines on the Acceptance of Specified Skilled Workers” (August, Reiwa 8 [2026]) / same, “Operational Guidelines on Support for Specified Skilled Worker (i) Foreign Nationals” / same, “Key Points of the Revision of the Operational Guidelines on the Acceptance of Specified Skilled Workers” (March, Reiwa 7 [2025]) / same, “Revision of the Requirements for the Support Structure for Specified Skilled Worker (i) Foreign Nationals (Effective April 1, Reiwa 9 [2027])” / same, “Register of Registered Support Organizations” / Ministry of Justice and Ministry of Land, Infrastructure, Transport and Tourism, “Operational Guidelines on the Acceptance of Specified Skilled Workers in Specified Fields (Construction Field)” / Ministry of Land, Infrastructure, Transport and Tourism, “Online Applications for Construction Specified Skilled Worker Acceptance Plans [New]” (April 4, 2025) / Immigration Services Agency of Japan, “Frequently Asked Questions on Ad Hoc Notifications by Specified Skilled Worker Accepting Organizations (Q&A)” (June, Reiwa 7 [2025]) / same, “Approval Procedure as an Application Agent” / e-Gov Law Search, “Administrative Scriveners Act,” Articles 1-3 and 19
One-stop support for construction companies. Our office is a Registered Support Organization run by an administrative scrivener. In addition to providing the support itself, we handle on a one-stop basis the document preparation and representation that ordinary Registered Support Organizations cannot take on: from the documents for Specified Skilled Worker residence applications and the periodic and ad hoc notifications the company must file, through to applications to the Ministry of Land, Infrastructure, Transport and Tourism for certification of the acceptance plan.
What Is “Support” in the First Place?
Under the Immigration Control Act, a company that employs a Specified Skilled Worker (i) foreign national is called a “Specified Skilled Worker accepting organization” (特定技能所属機関). The accepting organization must prepare a “Support Plan for Specified Skilled Worker (i) Foreign Nationals” (1号特定技能外国人支援計画; hereinafter the “support plan”) and provide support in accordance with it (Article 2-5, paragraph 6 and Article 19-22, paragraph 1 of the Immigration Control Act). Support means help that enables the foreign national to continue working and living in Japan in a stable way. No support plan is required for Specified Skilled Worker (ii) foreign nationals.
The ISA’s Operational Guidelines organize the “mandatory support” (義務的支援) that must be provided into the following 10 items.
| Item | Main Content |
|---|---|
| ① Prior guidance | Before the application, explaining the content of the employment contract, the activities in Japan, etc. |
| ② Transportation on entry and departure | Transportation between the airport, etc. and the destination on entry and on returning home |
| ③ Support for securing housing and contracts necessary for daily life | Helping to secure housing and to set up contracts such as a bank account and a mobile phone |
| ④ Life orientation | Providing information on the rules of daily life, medical care, disaster preparedness, etc. |
| ⑤ Accompaniment for public procedures, etc. | Accompanying the person, as necessary, for procedures at government offices, etc. |
| ⑥ Provision of opportunities to learn Japanese | Providing information on Japanese language classes, etc. |
| ⑦ Responding to consultations and complaints | Responding to consultations about work and daily life |
| ⑧ Promotion of interaction with Japanese people | Providing information on local events, etc. |
| ⑨ Support for changing jobs | Helping to find the next accepting employer when the contract is terminated for reasons on the company’s side |
| ⑩ Regular interviews and reporting to administrative agencies | Interviewing the person and their supervisor separately at least once every 3 months, and reporting to the relevant agencies if there is a problem |
There are three points to keep in mind.
- Language Prior guidance, life orientation, responses to consultations and complaints, and regular interviews must be conducted in a language the foreign national can sufficiently understand. The Operational Guidelines state that for complicated consultations, the involvement of an interpreter is considered indispensable.
- Costs The costs of mandatory support may not be borne by the foreign national, either directly or indirectly.
- Regular interviews Under the operational revision of April, Reiwa 7 (2025), interviews may be held online if both the person and the supervisor consent. In that case, the recording must be kept for at least 1 year from the day the contract ends. If the person wishes to meet in person, the interview is held in person.
In addition, from April, Reiwa 7, companies must check the “multicultural coexistence measures” (共生施策; for example, guidance on garbage disposal rules and Japanese language classes) of the municipalities where the foreign national’s workplace and home are located, and prepare the support plan in light of them. For details of each item, please see Support Plan for Specified Skilled Worker (i) | A Detailed Explanation of the 10 Items of Mandatory Support.
”Full Outsourcing” and “Partial Outsourcing” Are Treated Differently
The Immigration Control Act allows a company to entrust all or part of the support to another party (Article 19-22, paragraph 2). However, what is required of the company differs greatly depending on whether everything is entrusted to a Registered Support Organization or not.
A Registered Support Organization is an organization registered with the Commissioner of the Immigration Services Agency in order to be entrusted with providing support (Article 19-23). Registration must be renewed every 5 years.
| How Support Is Provided | What Is Required of the Company |
|---|---|
| All support provided in-house | The company itself has a structure capable of providing support appropriately |
| Only part entrusted to an outside party | Same as above. In addition, the scope of outsourcing is stated in the support plan |
| All support entrusted to a Registered Support Organization | The company is deemed to meet the standards for a support structure (Article 2-5, paragraph 5) |
The standards for the structure when a company provides support in-house are set out in detail in Article 2, paragraph 2 of the “Ministerial Ordinance Prescribing the Standards for Specified Skilled Worker Employment Contracts and Support Plans for Specified Skilled Worker (i) Foreign Nationals” (特定技能雇用契約及び一号特定技能外国人支援計画の基準等を定める省令; hereinafter the “Standards Ordinance”). For example, on the premise that the company has a track record of properly accepting foreign nationals with a status of residence permitting work within the past 2 years, or has officers or employees with experience in providing daily-life consultation to foreign nationals, it must appoint a support supervisor (支援責任者) and a support staff member (支援担当者) for each place of business. The support supervisor and the support staff must be people who are not in a position to supervise the foreign national. The company also needs a structure for providing support in a language the foreign national can sufficiently understand, and a structure for preparing records of the support and keeping them for at least 1 year.
For a company accepting foreign nationals for the first time, or one where only the supervisors on site have contact with the foreign nationals, meeting these standards is not easy. This is why full outsourcing to a Registered Support Organization is so often chosen.
Full outsourcing is also subject to the following rules.
- Even with full outsourcing, acceptance may not be approved if it is found that effective support cannot be provided in view of the Registered Support Organization’s structure.
- The entire support plan may not be split up and entrusted to multiple Registered Support Organizations.
- A Registered Support Organization that has been entrusted with all the support may not subcontract that support to another organization (using an interpreter, a taxi or the like as an auxiliary aid is acceptable).
Changes from April 1, Reiwa 9
Under the amending act that created the Employment for Skill Development (育成就労) system (Act No. 60 of Reiwa 6 [2024]), from April 1, Reiwa 9 (2027), only Registered Support Organizations may be entrusted with all or part of the support (Article 19-22, paragraph 2 of the Immigration Control Act as amended). If you currently entrust part of the support to a company or individual that is not a Registered Support Organization, you will need to review the arrangement before the effective date.
From the same date, the requirements for the support structure will also be revised. According to materials published by the ISA, the planned changes include limiting the people who may engage in support work to the support supervisor and the support staff, requiring the support supervisor to attend a training course (for the time being, not having completed it is acceptable), and, at Registered Support Organizations, setting caps on the number of companies each staff member may take on and the number of foreign nationals each may support. This revision also affects companies providing support in-house.
Obligations That Stay with the Company Even After Outsourcing
What full outsourcing makes the company “deemed” to meet is only the standards for a support structure. The following obligations remain with the company whether or not it outsources.
| Obligation Remaining with the Company | Content | Legal Basis |
|---|---|---|
| Preparing the support plan | Even with full outsourcing, the company prepares the support plan. The Registered Support Organization may assist in preparing it | Article 2-5, paragraph 6 of the Immigration Control Act; Operational Guidelines |
| Proper performance of the employment contract | Remuneration equal to or above that of Japanese nationals, prohibition of discriminatory treatment on the ground of being a foreign national, payment of remuneration by bank transfer, etc. | Article 2-5 of the Immigration Control Act; Article 1, paragraph 1 and Article 2, paragraph 1 of the Standards Ordinance |
| Legal compliance | Compliance with labor, social insurance and tax laws; workers’ accident compensation insurance procedures | Article 2, paragraph 1 of the Standards Ordinance |
| Bearing costs | Not having the foreign national bear the costs of mandatory support | Article 2, paragraph 1, item 8 of the Standards Ordinance |
| Cooperation with the local community | Submitting a “Confirmation of Cooperation” (協力確認書) to the municipality and responding to requests for cooperation with multicultural coexistence measures | Article 2, paragraph 1, item 12-2 of the Standards Ordinance; Operational Guidelines |
| Notifications to immigration | Ad hoc notifications and the once-a-year periodic notification | Article 19-18 of the Immigration Control Act |
| Responding to investigations and guidance | The company is the subject of the ISA’s requests for reports, on-site inspections and improvement orders | Articles 19-20 and 19-21 of the Immigration Control Act |
Notifications to Immigration Are Filed in the Company’s Name
The party obliged to file notifications is the company, not the organization it entrusts. Ad hoc notifications (随時届出) must be filed within 14 days from the day the event occurs (Article 19-17, paragraph 2 of the Regulation for Enforcement of the Immigration Control Act). The main ones are as follows.
- Change, termination or new conclusion of a Specified Skilled Worker employment contract
- Change of the support plan
- Conclusion, change or termination of a support outsourcing contract with a Registered Support Organization
- When acceptance becomes difficult (for example, when the person becomes unable to work for 1 month or more)
- When the company no longer meets the standards of the ministerial ordinance (for example, when taxes or social insurance premiums fall into arrears)
Under the revision of April, Reiwa 7, the periodic notification (定期届出) changed from quarterly to once a year. The status of acceptance, activities and support implementation from April 1 to March 31 of the following year is filed between April 1 and May 31 of the following year. With full outsourcing, the company compiles the status of support implementation from the Registered Support Organization and files it jointly in the names of the company and the Registered Support Organization.
Failing to file, or filing a false version of, the notifications concerning the employment contract or the status of acceptance is subject to a fine of up to ¥300,000 (Article 71-4, item 1 of the Immigration Control Act). Corporations are also punished (Article 76-2 of the same Act). Separately, the notification of the employment status of foreign nationals to Hello Work is also an obligation of the company, under a different law. The overall flow is summarized in Notification Calendar for Companies Employing Foreign Nationals.
Point: Only an administrative scrivener (gyoseishoshi, 行政書士) or an attorney can be entrusted from outside the company with preparing the notification documents. The ISA’s Q&A (June, Reiwa 7 [2025]) cautions that entrusting anyone else may violate the Administrative Scriveners Act and the like and, in addition, will be regarded as a failure to make a proper notification. What an ordinary Registered Support Organization can prepare is its own notifications as a Registered Support Organization. For companies that entrust the support to a Registered Support Organization while handling notifications in-house, it is important to agree in advance on how information will be passed on, so that the support records and the content of the notifications do not diverge.
Additional Requirements When a Construction Company Accepts Workers
A company that accepts Specified Skilled Worker (i) foreign nationals in the construction field is also subject to the standards of the Ministry of Land, Infrastructure, Transport and Tourism (MLIT). According to the Operational Guidelines (Construction Field), the main ones are as follows.
- Holding a construction business license (建設業許可) under Article 3, paragraph 1 of the Construction Business Act (建設業法)
- Registering both the company and the foreign national in the Construction Career Up System (CCUS)
- Being a member of the Japan Association for Construction Human Resources (JAC) or one of its member organizations
- Obtaining certification of a “Construction Specified Skilled Worker Acceptance Plan” (建設特定技能受入計画) from the Minister of Land, Infrastructure, Transport and Tourism (a copy of the certificate is required for immigration permission or issuance)
- Reporting the start and end of acceptance, etc. to the Minister of Land, Infrastructure, Transport and Tourism
- Cooperating with checks such as visits by the proper employment monitoring body (適正就労監理機関)
- Keeping the number of Specified Skilled Worker (i) foreign nationals no greater than the total number of full-time employees (excluding technical intern trainees and Specified Skilled Worker (i) foreign nationals)
Applications for certification of the acceptance plan are made online through MLIT’s “Foreign Worker Employment Management System” (外国人就労管理システム). MLIT’s application manual states that when applying as a representative, a power of attorney and an attorney’s or administrative scrivener’s identification card must be attached, and cautions that anyone who is not an administrative scrivener or attorney is prohibited from preparing Specified Skilled Worker applications and the like for a fee. Reports on the start and end of acceptance, etc. are also made through the same system.
These are standards the company itself must meet. Entrusting the support to a Registered Support Organization does not take care of them. Because an ordinary Registered Support Organization cannot file the acceptance plan application or the reports on the company’s behalf, the company must handle them itself or engage an administrative scrivener or attorney. For the full set of requirements in the construction field, see Specified Skilled Worker in the Construction Field | The Special Requirements of CCUS Registration and JAC Membership, and for how to obtain a construction business license, see Steps to Obtaining a Construction Business Licence.
How to Choose a Registered Support Organization
There are a great many Registered Support Organizations across Japan. Before comparing costs, we recommend checking the following points.
- Confirm the registration Check the Register of Registered Support Organizations published on the ISA’s website to confirm whether the organization is registered. The register also lists the offices providing the support and an outline of the structure for handling consultations (the languages available).
- Support in the person’s native language Can consultations and regular interviews be conducted in a language the foreign national can sufficiently understand? Also ask who the interpreter is, and until what time and how urgent consultations are handled.
- How interviews are conducted Who will hold the interviews required at least once every 3 months, and where? Online interviews require the consent of the person and the supervisor and the retention of the recording. For construction companies with many sites, whether the organization is close enough to come for interviews also matters.
- A clear breakdown of costs The Operational Guidelines require a Registered Support Organization to state clearly the amount and breakdown of the costs of the support when concluding a full outsourcing contract. They also advise that, because outsourcing costs can vary with the number of people and the number and location of places of business, companies should check the details by, for example, obtaining quotes from several Registered Support Organizations. Look not only at how low the monthly fee is, but at what is included and what will cost extra.
- Coordination between records and notifications The periodic notification is filed jointly in the names of the company and the Registered Support Organization. Check how the organization will share interview records and the status of support implementation with the company.
- Whether document preparation can also be entrusted Only administrative scriveners or attorneys can be entrusted with the documents for Specified Skilled Worker residence applications, the notifications the company files, and acceptance plan applications in the construction field. Although an ordinary Registered Support Organization’s approved staff can submit applications on the applicant’s behalf, the organization cannot take on preparing the documents.
- Readiness for the April Reiwa 9 revision Caps per staff member are planned. It is reassuring to ask in advance how many staff members the organization has and how many companies each one handles.
- Knowledge of the field In the construction industry, whether the organization understands MLIT procedures such as the acceptance plan and CCUS makes a difference to how easy it is to consult with them.
When You Engage Our Office
Kaneko Hidetaka Administrative Scrivener Office is a Registered Support Organization. And our representative is an administrative scrivener who has filed notification as an application agent (申請取次). This is the biggest difference from an ordinary Registered Support Organization.
| What You Need | Ordinary Registered Support Organization | Our Office (a Registered Support Organization that is an administrative scrivener) |
|---|---|---|
| Providing mandatory support (full outsourcing) | Yes | Yes |
| Submitting Specified Skilled Worker residence applications on the applicant’s behalf (filing the documents) | Yes, by approved staff | Yes (administrative scrivener application agent) |
| Preparing the documents for Specified Skilled Worker residence applications | No (limited to administrative scriveners and attorneys) | Yes |
| Preparing the periodic and ad hoc notifications the company files | No (it can prepare only its own notifications) | Yes |
| Representation for the certification application for a Construction Specified Skilled Worker Acceptance Plan and post-acceptance reports | No (representation is limited to administrative scriveners and attorneys) | Yes |
Because we handle the provision of support, residence applications, the company’s notifications and MLIT procedures on a one-stop basis, you do not have to give us the same information over and over, and the support records and the content of the notifications do not diverge.
- A 98% approval rate
- Representation for acceptance plan applications too We act as your representative for certification applications for MLIT’s Construction Specified Skilled Worker Acceptance Plan and for post-acceptance reports. Our office has in fact handled a large number of acceptance plan applications as a representative.
- Construction company procedures handled together We carry out CCUS registration on your behalf and can also help with joining JAC. Our office also handles obtaining and renewing construction business licenses and company incorporation.
- Working with you to find workers for your sites For Specified Skilled Worker personnel, we work together with the company on job postings with Hello Work, JAC’s job listings and the like. For accepting workers under Employment for Skill Development (currently Technical Intern Training (技能実習)), we work in partnership with a cooperative (協同組合; a supervising organization) for which our representative serves as an advisor.
- A representative who knows the front line of acceptance Our representative previously served as chairman of a cooperative (a supervising organization and Registered Support Organization), standing on the front line of accepting technical intern trainees and Specified Skilled Worker foreign nationals and handling their procedures and support. At the Chiba Public Employment Security Office (Hello Work Chiba), he has served as a consultant on the employment of foreign nationals and has responded many times to consultations from companies hiring a foreign national for the first time.
- All of a construction company’s concerns, handled one-stop For labor and social insurance matters we work with a partner certified social insurance and labor consultant (sharoushi, 社会保険労務士), for financial statements and tax returns with a partner certified public tax accountant (zeirishi, 税理士), and for legal issues with a partner attorney. Our office is your point of contact. Bookkeeping services are provided by our office.
Your first consultation is free for 60 minutes. Online consultations are also available, in Japanese or Chinese. Our office is a 4-minute walk from the South Exit of JR Chiba Station. After asking about the nationality and language of the people you plan to accept, we will explain the support structure in concrete terms.
Summary
- A company that employs Specified Skilled Worker (i) foreign nationals is obliged to prepare a support plan and provide mandatory support (10 items). With full outsourcing to a Registered Support Organization, the company is deemed to meet the standards for a support structure.
- With partial outsourcing or in-house support, the company itself must meet the standards for a support structure, such as appointing a support supervisor and support staff.
- From April 1, Reiwa 9 (2027), support may be entrusted only to Registered Support Organizations, and the requirements for the support structure will also be revised.
- Even with full outsourcing, preparing the support plan, properly performing the employment contract including remuneration, legal compliance, cooperation with the municipality, and notifications to immigration remain with the company. The periodic notification is once a year (April 1 to May 31), filed jointly with the Registered Support Organization in the case of full outsourcing.
- In the construction field, the company itself must also meet MLIT’s standards, such as the construction business license, CCUS, JAC and certification of the acceptance plan.
- Preparing the documents for Specified Skilled Worker residence applications and the company’s notifications, and representation for acceptance plan applications, are limited to administrative scriveners and attorneys. Ordinary Registered Support Organizations cannot take them on.
- Choose a Registered Support Organization by checking the register, support in the person’s native language, the interview arrangements, the cost breakdown, coordination between records and notifications, and whether document preparation can also be entrusted.
This article is based on information published as of October 2026. Systems and forms may be revised, so please check the websites of the Immigration Services Agency of Japan and the Ministry of Land, Infrastructure, Transport and Tourism for the latest information.