As of April 15, 2026, Japan’s Immigration Services Agency (ISA) has introduced new documentary requirements and eligibility criteria for applications involving the “Engineer/Specialist in Humanities/International Services” (技術・人文知識・国際業務, commonly known as the “Gijinkoku” visa) residence status. These changes apply to new applications, renewals, and changes of status.
This article provides a detailed, practical explanation of the key amendments from the perspective of a licensed administrative scrivener (gyoseishoshi) who regularly handles visa applications. Whether you are an employer hiring foreign talent or a foreign national seeking to work in Japan, understanding these changes is critical.
- ■ Background: Why Were These New Rules Introduced?
- ■ New Requirement #1: Declaration Regarding the Representative of the Sponsoring Organization
- ■ New Requirement #2: Proof of Language Proficiency at CEFR B2 Level or Above
- ■ Practical Implications: Key Points for Employers and Applicants
- ■ The Value of Consulting an Immigration Specialist (Gyoseishoshi)
- ■ Summary: Preparation Is Everything
■ Background: Why Were These New Rules Introduced?
The amendments serve two main objectives:
- Strengthening verification of employment management practices at companies managed by foreign nationals.
- Ensuring that applicants possess language proficiency commensurate with the duties they are expected to perform.
In recent years, there has been a significant increase in foreign-owned businesses in Japan. While this is a positive development, the ISA has observed cases where newly established or small-scale companies lacked adequate employment management systems — including proper employment contracts, rules of employment, and labor compliance systems.
Additionally, there have been instances where applicants were approved for communication-heavy roles — such as interpreting or sales — despite lacking sufficient proficiency in the language required for the job.
These new rules are the ISA’s response to those concerns, aimed at raising the bar for both corporate compliance and individual qualifications.
■ New Requirement #1: Declaration Regarding the Representative of the Sponsoring Organization
One of the newly required documents is the “Declaration Regarding the Representative of the Sponsoring Organization” (所属機関の代表者に関する申告書).
▼ What Information Must Be Provided?
The declaration requires the following details about the company’s representative:
- Full name
- Nationality (Japanese, Special Permanent Resident, or other)
- Residence card number (if the representative is a foreign national)
The document must be signed by the representative personally. Importantly, the form explicitly states that if any information is found to be inaccurate, the application may be treated as a separate matter — meaning its credibility could be fundamentally undermined.
▼ Why Was This Requirement Introduced?
The purpose of this declaration is to allow the ISA to verify whether companies led by foreign nationals are operating in compliance with Japanese labor laws and social norms. In practice, this means that companies with foreign representatives will be subject to an additional layer of scrutiny compared to those headed by Japanese nationals or Special Permanent Residents.
▼ Which Companies Are Affected? — Category 3 and Category 4 Only
This is an important point: the declaration is not required of all companies.
It applies only to organizations classified under:
- Category 4: Companies established within approximately one year that have not yet prepared or submitted a statutory record of withholding tax (法定調書合計表).
- Category 3: Smaller-scale companies whose total withholding tax amount in the previous year was ¥10 million or less.
In other words, large corporations and listed companies are exempt. The additional documentation requirement is targeted specifically at newly established companies, small businesses, and foreign-owned enterprises.
The declaration form is available for download from the ISA website:
https://www.moj.go.jp/isa/content/001460221.pdf
■ New Requirement #2: Proof of Language Proficiency at CEFR B2 Level or Above
The second major change is the introduction of a language proficiency requirement for certain job categories. Specifically, applicants may be required to demonstrate language ability at CEFR B2 level or higher.
CEFR (Common European Framework of Reference for Languages) is an internationally recognized standard for assessing language ability. B2 corresponds to an “independent user” — someone capable of interacting with a degree of fluency and spontaneity in a professional setting.
▼ Which Job Functions Are Subject to This Requirement?
The language proficiency requirement applies to roles where communication is a core part of the role, including:
- Interpreting, translation, and language instruction (classified as “International Services”)
- Management of Japanese employees
- Sales, public relations, and marketing involving interaction with Japanese clients
In contrast, technical positions such as IT engineering — where the primary skill set is technical rather than language-based — are generally not subject to this requirement at present (though exceptions may apply depending on the specific duties).
▼ How to Demonstrate Japanese Language Proficiency
For Japanese language ability at the CEFR B2 level, any of the following may be accepted as valid proof:
- JLPT (Japanese-Language Proficiency Test) N2 or above
- BJT Business Japanese Proficiency Test score of 400 or above
- Graduation from a Japanese university
- Completion of education in Japan (including compulsory education)
- Long-term residence in Japan (generally 20 years or more as a guideline)
▼ Foreign Language Proficiency — “Native Speaker” Does Not Mean Exemption
This is one of the most important practical considerations.
For example, if a native Mandarin speaker is hired to perform sales duties in English, they must provide proof of English proficiency at CEFR B2 or above. The rule is clear: proficiency must be demonstrated for each language used in the performance of duties, regardless of the applicant’s mother tongue.
Overlooking this requirement at the hiring stage could result in requests for additional documentation during the review process or, in the worst case, a denial of the application.
▼It applies only to organizations classified under:
- Category 4: Companies established within approximately one year that have not yet prepared or submitted a statutory record of withholding tax (法定調書合計表).
- Category 3: Smaller-scale companies whose total withholding tax amount in the previous year was ¥10 million or less.
In other words, large corporations and listed companies are exempt. The additional documentation requirement is targeted specifically at newly established companies, small businesses, and foreign-owned enterprises.
■ Practical Implications: Key Points for Employers and Applicants
The amendments have several significant implications for practical operations.
▼ Point 1: Corporate Employment Management Will Be Scrutinized More Closely
Companies must ensure that the representative’s residence status is clearly documented, that proper employment contracts are in place, and that internal rules of employment and labor management systems are properly maintained. Any deficiencies in these areas may now directly affect the outcome of a visa application.
This is particularly relevant for Category 3 and Category 4 companies, which are now required to submit additional documentation — effectively raising the bar for the documentary review stage.
▼ Point 2: Job Descriptions Must Be More Specific
In the past, it was often sufficient to describe a position in general terms — “sales,” “interpreter,” and so on. Going forward, applicants and their sponsors will need to clearly explain:
- Who the applicant will interact with
- In which language(s)
- What specific tasks they will perform
Vague or generic descriptions may delay the review process or lead to a denial.
▼ Point 3: Language Proficiency Documentation Should Be Prepared in Advance
Test scores, academic transcripts, and detailed work histories that demonstrate language ability should be compiled well before the application is filed. If test results are outdated or if the available evidence is limited, it is advisable to consult with an immigration professional early to explore alternative means of proof.
■ The Value of Consulting an Immigration Specialist (Gyoseishoshi)
At first glance, these amendments may appear to be simply the addition of a new form and a language requirement. In practice, however, they represent a fundamental shift in how applications are evaluated.
The following determinations, in particular, require professional expertise:
- Accurately identifying which category a company falls under
- Assessing whether a given job function triggers the language proficiency requirement
- Developing a coherent strategy that aligns the job description with the language evidence
An improperly prepared application can result not only in a denial but also in significant delays in resubmission and potential reputational harm to the sponsoring company.
If you are uncertain whether your company is subject to the new requirements, unsure which documents to prepare, or concerned about whether a prospective employee meets the eligibility criteria, it is strongly recommended to consult a qualified immigration professional as early as possible.
With the right preparation and a well-designed application strategy, the likelihood of a successful outcome can be significantly improved.
■ Summary: Preparation Is Everything
For Gijinkoku visa applications filed on or after April 15, 2026, the following three elements will be examined more rigorously than ever:
- Corporate reliability (employment management structure, representative information)
- Substance of job duties (specific and detailed job descriptions)
- Appropriateness of language proficiency (evidence that the applicant can perform the stated duties in the required language)
Companies classified under Category 3 or Category 4 should pay particular attention to the newly introduced documentation and requirements.
If any of these changes apply to your organization, now is the time to act — not after the application has been filed.
This article is based on immigration regulations and guidance as of April 2026. For the latest information and individualized advice, please consult a qualified immigration professional.
Reference: https://www.moj.go.jp/isa/applications/status/gijinkoku.html
