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[2026 Latest] The Full Picture of Stricter "Visa for Engineers/Specialists in Humanities/International Services" Screening and Practical Measures Companies Should Take

On April 15, 2026, the Immigration Services Agency of Japan (ISA) significantly revised the operational guidelines for the "Technical Intern Training" status of residence (hereinafter referred to as "Gijinkoku"). This revision can be described as the biggest "major shift towards emphasizing actual circumstances" in recent years.
The era when permission was granted based solely on formal documents, such as "because you have a university degree" or "under the guise of an interpreter," has definitively ended. This article explains the core of the changes happening at the forefront of practical affairs and the defensive measures that accepting companies should take immediately.
The "Three Cores" of Stricter Review
The targets of this revision are primarily "Categories 3 and 4," which apply to small and medium-sized enterprises.Affiliation, andIt is employment under the "dispatch system." Three major high hurdles have been newly established.
The mandatory requirement of CEFR B2 (equivalent to Japanese JLPT N2) for client-facing roles.
When primarily engaged in interpersonal tasks utilizing language skills, such as translation/interpretation, hotel front desk, multilingual customer support, international sales, etc., an international standard isCEFR B2 equivalent(Submission of proof of Japanese Language Proficiency Test JLPT N2 or higher, or BJT Business Japanese Proficiency Test score of 400 or higher is required.)
【Notice】Graduation from a Japanese language school alone does not grant exemption.
If you are employing an international student in a role that requires interaction with people, and they have graduated from a university in their home country and a Japanese language school (miscellaneous school) in Japan, a graduation certificate from the Japanese language school alone will not qualify them for an exemption. A JLPT N2 or higher passing certificate is required separately.
If you have graduated from a Japanese university, junior college, or vocational school (holding a Professional Degree), the "deemed provision" exemption will apply as before.
② Add "Declaration of the Representative of the Affiliated Organization" to hold management accountable
For companies in Categories 3 and 4, a declaration signed by a representative is now required, pledging that there are no falsehoods regarding the applicant's job duties or employment status. This is a strong indication of the Immigration Bureau's stance, aiming to prevent excuses such as "we were having them do simple labor based on on-site judgment" or "we didn't know," and is being considered in light of potential charges for aiding illegal employment.
3. Scandals in "Specified Skills" and "Technical Intern Training" Linked to "Technical and Specialist in Humanities/International Services"
Penalties for linking to other qualifications have been introduced. If our company engages in improprieties such as unpaid wages in accepting "Specified Skills" or "Technical Intern Training" workers,If a "5-year acceptance suspension penalty" is applied, it will be impossible to accept foreign nationals in the "Engineer/Specialist in Humanities/International Services" category (neither new applications nor renewals) during that period.
Why did Immigration go this far?
Behind this is the "quality optimization" of "skilled workers" who have surpassed permanent residents in number to over 450,000 domestically.
This is because malicious cases (so-called "disguised technical intern training") continue to occur, where companies extend job offers under the pretense of "interpreter" or "general employee" positions, but then actually employ individuals in illegal work (working beyond the scope of their permits) such as factory production lines, warehouse sorting, and restaurant serving.
The logic of immigration control is extremely simple.
"If you want to assign truly advanced interpretation or client negotiation tasks, N2 level ability that allows for equal discussion with Japanese people should be essential. If that cannot be proven, the job itself is questionable." This signifies a shift to an assessment of actual performance.
The "Four Defense Strategies" for Companies to Survive in an Era of Tightening Regulations
To counter the shift from formal review to substantive investigation by immigration authorities, it is essential for companies to "build evidence (proof) during normal times."
| Countermeasure steps | Specific actions |
| 1. Early confirmation of Japanese language requirements | Before extending a job offer, please be sure to confirm that the candidate has either passed the JLPT N2 or a higher level, or has a graduation qualification from a Japanese university or similar institution. |
| 2. "Quantification" of Job Responsibilities | In job descriptions and position statements, rather than simply categorizing tasks as “sales” or “administrative,” visualize the proportion of each task—for example, “Overseas Marketing: 40%, Business Negotiations in English: 30%, Document Preparation: 20%.” |
| 3. Transparency in dispatch employment | In the case of dispatched employment, establish a system that can immediately respond to on-site inspections (visits) by preparing "confidentiality agreements" for both the dispatching and client companies, as well as a dispatch management ledger and a work status report. |
| 4. Appropriate Transition to Specified Skills | When simple tasks or on-site work are unavoidable in actual operations, instead of forcefully trying to qualify for "Specified Skilled Worker (Technical Intern Training Program)," strategically consider switching to "Specified Skilled Worker" after thoroughly examining the system's limits and transition rules. |
Conclusion: Compliance Becomes the Ultimate Recruitment Strategy
This legal amendment and operational change presents an opportunity for companies that have properly accepted foreign workers to eliminate unscrupulous competitors. However, if you casually submit the "same application documents as before," you could face an unexpected risk of refusal.
If you have any concerns about your company's job duties or Japanese language requirements when hiring or renewing a visa for a foreign national, we strongly recommend consulting with an expert well-versed in both immigration law and labor management as early as possible.
