From April 2026: Tighter Monitoring of Student Part-Time Work | The 28-Hour Rule and New Checks by Japanese Language Institutions

On 10 April 2026 (Reiwa 8) the Immigration Services Agency of Japan began requiring Japanese language institutions to check the outside-status activities (part-time work) of their enrolled international students once every three months, to keep records, and to report to the immigration authorities where necessary. This article sets out the basics of permission for activities outside the status qualification, the substance of this tightening, the legal consequences of exceeding 28 hours per week, and what students, schools and employers should each prepare, based on primary sources.

Sources: Immigration Services Agency of Japan, “Partial Revision of the Handling of Persons Enrolling in Japanese Language Institutions”; the same agency’s summary document “Making the Student Status of Residence More Appropriate”; its Q&A (as of 19 May 2026); “Permission for Activities Outside the Status Qualification for the Student Status of Residence”; and e-Gov Law Search, “Immigration Control and Refugee Recognition Act” and its Enforcement Regulations

What is permission for activities outside the status qualification (Article 19)

The Student status of residence exists for the activity of receiving education at an educational institution in Japan. Article 19, paragraph 1 of the Immigration Control Act in principle prohibits a person residing under a status listed in Appended Table I from engaging in activities operating a business involving income, or activities for which remuneration is received, that do not belong to that status.

Paragraph 2 of the same Article then provides that, within a scope that does not hinder the performance of the original activity, such activities may be permitted upon application. Conditions may be attached to that permission, and where the conditions are breached the permission itself may be revoked under paragraph 3.

A student’s part-time work is carried out under this permission granted pursuant to Article 19, paragraph 2. For the wider picture of statuses of residence, please also see What is a status of residence? The basics.

Comprehensive permission versus individual permission

There are two types of permission: “comprehensive permission”, which is granted generally without designating a workplace, and “individual permission”, which designates the workplace and the content of the work case by case. The basis is Article 19, paragraph 5 of the Enforcement Regulations. The Agency states that it is possible to hold both, and that a person already holding one may additionally apply for the other.

	Comprehensive permission	Individual permission
Basis	Enforcement Regulations Art. 19, para. 5, item 1	Enforcement Regulations Art. 19, para. 5, item 3
Time limit	Within 28 hours per week (within 8 hours per day while the institution is in a long vacation period stipulated in its school regulations)	Designated case by case by the Director of the Regional Immigration Services Bureau
Designation of workplace	None (workplace not designated)	Yes (name, location and business content of the organisation are designated)
Excluded activities	Work at premises operating an adult entertainment business, a store-based sex-related special business, or a designated entertainment and restaurant business, etc.	The same (the general principles for permission must also be satisfied)
Typical examples	Ordinary part-time work at restaurants, retail stores and the like	Internships for final-year students, language teaching, interpreting and private tutoring, start-up preparation, and outsourcing or contracting work whose hours are hard to verify objectively

Note that under the Enforcement Regulations, comprehensive permission for a person holding the Student status is “limited to activities carried out while enrolled at an educational institution”. After graduation or completion, or after withdrawal or removal from the register, part-time work under comprehensive permission is no longer possible.

Multiple employment under work-related statuses of residence is a different framework. For that, please see Can you hold a second job on an Engineer/Specialist in Humanities/International Services visa?.

The tightening of “ascertaining outside-status activities” from April 2026

Following the “Comprehensive Measures for the Acceptance of Foreign Nationals and for an Orderly Society of Coexistence” (decided by the relevant Ministerial Meeting on 23 January 2026), the Agency notified Japanese language institutions of the following on 10 April 2026 and tightened its operational handling.

Educational institutions accepting international students are required, under item 2-2 of the Ministerial Ordinance prescribing the criteria under Article 7, paragraph 1, item 2 of the Immigration Control and Refugee Recognition Act, to have in place a system for properly managing students’ compliance regarding activities outside the status qualification. (Immigration Services Agency of Japan, “Partial Revision of the Handling of Persons Enrolling in Japanese Language Institutions”, Part 2)

Four specific measures are required of Japanese language institutions.

Required measure	Content
(1) Checks every three months	By any method, confirm from enrolled students: whether permission has been granted; the name of the public or private organisation in Japan where the activity is carried out (all of them where there is more than one); the specific content of the activity; and the number of hours worked each day
(2) Guidance where there is a breach	Where a state of affairs contrary to the terms of the permission is found, give appropriate guidance, have the situation corrected immediately, and confirm again that it has been corrected
(3) Retention of records	Properly retain records of the results of the checks and of the guidance given (the Agency has published a reference form, “List of the Status of Ascertaining and Guiding Outside-Status Activities”)
(4) Reporting to immigration	Where a student reports that “the employer is forcing me to work more than 28 hours a week”, or where a student does not improve despite guidance, report the information obtained to the nearest immigration services office

The Agency also states that it will use the Notification of Employment Status of Foreign Nationals to identify students working at multiple locations and share that information with schools. The summary document expressly says that “particularly careful checks should be made in respect of persons engaged in multiple work about whom the Agency provides information”, and that the Agency will investigate reports according to their content and reflect the results in residence examinations.

The Q&A adds two practical points. The check may rest on students’ self-declaration, but if the Agency requests it, the school must explain concretely how it ascertains the workplace, hours and content of the work and how it gives guidance (Q7). As to counting the hours, the Agency asks schools to “ascertain the daily hours of outside-status activity and confirm that the total remains within 28 hours per week no matter which day of the week the count begins” (Q9), so a rough monthly tally is not enough. Failure to carry out the checks may contravene item 2-2 of the Landing Criteria Ordinance (Q8).

What happens if you work more than 28 hours a week

The consequences are graduated according to severity. Set out by provision, they are as follows.

Situation	Provision	Content
Penalty (general)	Immigration Control Act, Art. 73, item 1	A person who, in breach of Art. 19, para. 1, engages in an activity operating a business involving income or receiving remuneration: imprisonment of up to 1 year or a fine of up to 2 million yen, or both
Penalty (exclusive engagement)	Immigration Control Act, Art. 70, para. 1, item 4	A person “clearly found to be engaging exclusively” in such activities: imprisonment of up to 3 years or a fine of up to 3 million yen, or both
Deportation	Immigration Control Act, Art. 24, item 4 (a)	A person “clearly found to be engaging exclusively” in such activities is subject to deportation
Deportation	Immigration Control Act, Art. 24, item 4 (f)	A person sentenced to imprisonment for an offence under Art. 73 is subject to deportation
Revocation of status of residence	Immigration Control Act, Art. 22-4, para. 1, item 5	Not engaging in the activity corresponding to the status of residence while engaging in, or intending to engage in, another activity (unless there is a justifiable reason)
Revocation of the permission	Immigration Control Act, Art. 19, para. 3	Where the attached conditions are breached, or where it is otherwise inappropriate to continue the permission, it may be revoked
Extension and change examinations	Guidelines on change and extension	”Having engaged in the activity corresponding to the current status of residence” and “not having poor conduct” are considered factors and may be assessed negatively

An extension of period of stay or a change of status of residence is granted only where the Minister of Justice finds reasonable grounds to deem it appropriate, and that judgment is discretionary. The Agency’s “Guidelines on Permission for Change of Status of Residence and Extension of Period of Stay” (established March 2008, last revised June 2026) list among the factors “3. Having engaged in the activity corresponding to the current status of residence” and “4. Not having poor conduct”. The Agency’s published examples of refusals include a case in which a change of status was refused because the applicant had been working without permission for activities outside the status qualification. This matters especially for those planning to move from Student to a work status. For the procedure see Changing from Student to Engineer/Specialist in Humanities/International Services, and for the revocation system itself see Revocation risks for a status of residence and how to prevent them.

When does it change

This revision has two pillars — ascertaining outside-status activities, and verifying Japanese proficiency — and they take effect at different times.

Item	Timing
Tighter ascertaining and guidance on outside-status activities	Operation began in April 2026 (Reiwa 8); notified to Japanese language institutions on 10 April 2026
Stricter verification of Japanese proficiency (change of status / extension of stay)	Applications filed on or after 1 July 2026 (Reiwa 8)
Stricter verification of Japanese proficiency (Certificate of Eligibility applications)	Applications for students planning to enrol from October 2026 (Reiwa 8) onwards

On Japanese proficiency, evidence of 150 or more hours of study will no longer suffice: a test certificate or verification by interview becomes mandatory. That change is explained in detail separately in Stricter Japanese proficiency checks for the Student visa.

How to prepare in practice

For students

First, manage your hours yourself. Since the requirement is expressly that the total stay within 28 hours “no matter which day of the week the count begins”, adding everything up at the end of the month is not enough. Record your hours day by day as soon as your shifts are fixed, and get into the habit of checking that the last seven days always total 28 hours or less.

Second, add up multiple workplaces. If you hold more than one job, it is a breach where the combined total exceeds the limit, even if neither job alone reaches 28 hours. The items schools must check expressly include “all workplaces where there is more than one”.

Third, the long vacation. Up to 8 hours per day is allowed only while the institution you are enrolled in is in a long vacation period stipulated in its school regulations. Even on days when classes happen not to be held, the ordinary 28-hour weekly cap applies unless the period is a long vacation under those regulations.

Fourth, enrolment. Part-time work under comprehensive permission is limited to the period of enrolment. If you have not secured employment by graduation, please consult us early about how to structure your stay.

For Japanese language institutions

We recommend building the three-monthly cycle into the academic calendar as a routine task. The method is left to each school, but you need to be able to explain concretely how you ascertain the position if immigration asks, so the safest course is to keep records covering the items in the Agency’s published reference form, “List of the Status of Ascertaining and Guiding Outside-Status Activities”.

What must be checked is the “daily” hours. Even where you rely on self-declaration, a form that asks students to list every workplace and to enter hours by day will let you verify the weekly position afterwards. Where a breach comes to light, record both the fact that guidance was given and the fact that improvement was confirmed. Where guidance does not lead to improvement, or where the employer appears to be at fault, a report to the nearest immigration services office is required.

For employers of part-time staff

At hiring, check the status of residence and period of stay on the front of the residence card, and the presence and conditions of permission in the relevant field. The Ministry of Health, Labour and Welfare encourages active use of the “Residence Card Reader Application” to detect forged or altered cards.

In addition, under the Act on Comprehensively Advancing Labor Measures and Stabilizing the Employment of Workers and Enriching Workers’ Vocational Lives, every employer must submit a “Notification of Employment Status of Foreign Nationals” to Hello Work when a foreign worker is hired and when they leave. Failure to notify, or false notification, carries a fine of up to 300,000 yen. This tightening expressly uses that notification data as a means of identifying students working at multiple locations.

Heaviest of all is the offence of promoting illegal work. Article 73-2 of the Immigration Control Act provides for imprisonment of up to 3 years or a fine of up to 3 million yen, or both, for a person who, in connection with business activities, has a foreign national engage in illegal work. Paragraph 2 provides that one cannot escape punishment on the ground of not having known that the person lacked permission for activities outside the status qualification (except where there was no negligence). “He told me it was fine” is not a defence.

Summary

From April 2026, Japanese language institutions must check every three months whether their enrolled students hold permission, the names of their workplaces, the content of the work and the hours worked each day, retain the records, and report to immigration where necessary. The 28-hour weekly cap is unchanged, but the essence of this reform is that compliance is now made visible at regular intervals and fed into residence examinations.

For students, a daily record of hours worked becomes the very material that will support a future extension of period of stay or a change to a work status of residence. We recommend that all three parties review their position from their own side.

How our office can help

For advice on permission for activities outside the status qualification, extension of period of stay, and change to a work-related status of residence, please turn to Kaneko Hidetaka Administrative Scrivener Office.

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