A commentary by an immigration specialist (gyoseishoshi)
- ■ Introduction: The Remark Wasn’t “Dismissive”—It Was the System Speaking.
- ■ Background: Balancing “Coexistence” and “Orderly Regulation”
- ■ Key Change ①: Enhanced Monitoring of Extra-Status Activities (Effective April 2026)
- ■ Key Change ②: Stricter Verification of Japanese Language Proficiency (Effective July 2026)
- ■ Impact on International Students: “I Didn’t Know” Is No Longer a Defense
- ■ Impact on Employers: The Risk of “Facilitating Illegal Employment”
- ■ Impact on Japanese Language Institutions: Rebuilding Guidance and Oversight Systems
- ■ Practical Advice from a Certified Administrative Lawyer
- ■ Conclusion: Turning Change from a “Risk” into an “Opportunity to Get Organized”
■ Introduction: The Remark Wasn’t “Dismissive”—It Was the System Speaking.
The year 2026 marks a significant turning point in Japan’s policy on accepting foreign nationals. The Immigration Services Agency of Japan (ISA) has announced a phased tightening of the operational rules for the “Student” residence status. Beginning in April 2026, a new framework will require Japanese language institutions to monitor the actual situation of part-time work (activities outside the scope of the permitted status) undertaken by international students. From July 2026 onward, the verification of Japanese language proficiency at the time of enrollment will also become significantly stricter.
Within hours, the clip began circulating on social media, and public debate quickly followed. Yet this incident should not be dismissed as a social media controversy. Behind the noise lies a structural story about how Japan’s residence status system actually operates — and why informed, calm responses matter more than ever.
In this article, as a certified administrative lawyer (gyoseishoshi) working daily on visa applications, I will provide a detailed analysis of these regulatory changes and outline the practical steps that international students living in Japan, as well as employers and HR personnel hiring such students, should take immediately.
■ Background: Balancing “Coexistence” and “Orderly Regulation”
These amendments are rooted in the government’s “Comprehensive Measures for Acceptance and Coexistence of Foreign Nationals.” In recent years, it has become increasingly apparent that a number of international students enrolled at Japanese language institutions have deviated from their primary purpose of study. Many have been found working at multiple part-time jobs simultaneously, far exceeding the maximum hours permitted under their “activities outside the scope of the permitted residence status” (shikakugai katsudo) authorization.
The 28-hour weekly cap on part-time work was originally designed to protect the student’s status as a full-time learner. However, in practice, many students — either unaware of the rule or pressured by living and tuition expenses — end up working beyond this limit. As a result, cases of visa renewal denials and deportation orders have been steadily increasing.
It is also worth noting how this fits within the broader architecture of Japan’s foreign worker policy. The Specified Skilled Worker (SSW) system, for instance, was established with the premise of admitting foreign nationals who already possess demonstrated skills and a certain level of Japanese proficiency — and, in certain fields, offers a Path to Permanent Residency through long-term, structured employment. The “Student” category sits upstream of many of these pathways, which is precisely why its integrity matters so much.
To maintain educational quality while preventing illegal employment, the Japanese government has decided to strengthen enforcement through the current reforms.
■ Key Change ①: Enhanced Monitoring of Extra-Status Activities (Effective April 2026)
● New Obligations of Japanese Language Institutions
From April 2026, Japanese language institutions will be required to verify the part-time work status of each enrolled international student once every three months. The four items to be confirmed are:
- Whether the student holds valid permission for activities outside the scope of the permitted status
- The name and location of the employer(s)
- The nature of the work performed
- The total working hours
Previously, part-time work by international students was largely self-reported, with limited active oversight by educational institutions. Under the new system, language schools will take on the combined roles of verifier, advisor, and reporter.
● Consequences of Non-Compliance
If a violation is identified, the school must immediately provide corrective guidance to the student. If no improvement is observed, or if illegal employment is strongly suspected, the school is legally obligated to report the matter to the nearest Regional Immigration Services Bureau.
It is also important to recognize that, when serious or systemic violations are identified at the institutional level, the issuance of new Certificates of Eligibility in that industry is, in principle, halted — a consequence that can ripple far beyond the individual student. In past cases, vacancies that would normally have been covered by incoming international students had to be filled through domestic hiring, forcing operational changes that were not simply an executive explaining a necessary shift, but a genuine restructuring of workforce plans.
In short, inappropriate employment by international students will no longer be a matter of “getting away with it if undetected.” With schools now functioning as an institutional checkpoint feeding information to the immigration authorities, the risk of detection will increase substantially.
■ Key Change ②: Stricter Verification of Japanese Language Proficiency (Effective July 2026)
● Previous Practice
Under the previous framework, the required Japanese language proficiency at enrollment was CEFR A1 or higher. Applicants could typically satisfy this requirement by demonstrating at least 150 hours of prior Japanese language study.
● New Practice
For applications filed on or after July 1, 2026 — including applications for change or renewal of residence status — and for applications for Certificate of Eligibility filed for the October 2026 intake and beyond, applicants must prove their CEFR A1-level proficiency by one of the following methods:
- A valid certificate of passage of a recognized Japanese language examination (such as JLPT N5 or above, J.TEST, or NAT-TEST)
- Confirmation through an interview
Where an interview is used, the institution must apply objective methods of evaluation and must submit detailed records of the interview — including materials used, questions asked, evaluation criteria, and the applicant’s responses — along with the application.
The existing exemption for applicants who have graduated from universities or equivalent institutions abroad, which waives the need to prove Japanese proficiency, remains unchanged.
■ On Subsidies and Public Perception
Some readers will wonder whether these tighter controls reflect a broader shift in how public resources are allocated to foreign residents and the institutions that support them. I must agree that this is a legitimate question, and even more concerningly, the public debate on this point often unfolds without accurate information about how the system actually works.
It is worth stating plainly: ensuring lawful status and fair treatment of foreign workers is not merely a matter of corporate goodwill. Under Japanese labor and immigration law, the compensation and working conditions offered to foreign employees must be at least equal to those of Japanese nationals performing comparable work. This is a legal floor, not an aspirational benchmark.
■ Impact on International Students: “I Didn’t Know” Is No Longer a Defense
● For Students with Multiple Part-Time Jobs
Students working at multiple employers must be especially cautious. The 28-hour weekly cap applies to the aggregate of all employment. If you work 20 hours at Employer A and 15 hours at Employer B, your total 35 hours clearly violates the regulation.
During officially designated long school vacation periods, the limit is relaxed to 8 hours per day. However, this exception applies only to periods formally recognized by your educational institution. Making this judgment yourself — “spring break has already started” — is extremely risky.
● Stricter Scrutiny at Renewal
Going forward, with language schools sharing information with the Immigration Bureau, immigration officers will increasingly cross-check past work activities at the time of renewal. Tax withholding slips, payslips, and municipal tax certificates can all be used to reverse-calculate actual working hours.
“Rushing to consult a professional only after renewal has been denied” is often too late. If you have any concerns, I strongly recommend consulting a certified administrative lawyer at the earliest opportunity.
■ Impact on Employers: The Risk of “Facilitating Illegal Employment”
● Ignorance Is Not a Defense
For employers of international students, the most serious risk is the crime of “facilitating illegal employment” (fuho shuro josei-zai). Under Article 73-2 of the Immigration Control and Refugee Recognition Act, a business operator who causes or allows a foreign national to engage in illegal employment may be punished by imprisonment of up to 3 years or a fine of up to 3 million yen.
Critically, this offense is generally not excused by a lack of knowledge. Employers bear an affirmative duty to verify the residence status and scope of permitted work of their foreign employees. A failure to conduct reasonable verification can give rise to liability for negligence.
● Three Compliance Checks Employers Must Implement Immediately
This is the key question for executives: is your current verification workflow actually robust enough to withstand scrutiny?
- Inspection of the original Residence Card, including the reverse side, to confirm whether “Permission to Engage in Activity Other Than That Permitted Under the Status of Residence Previously Granted” has been issued
- Establishment of a shift management system that enforces the 28-hour weekly limit
- Implementation of a self-declaration protocol regarding concurrent employment at other businesses
Item 3 is particularly important. By requiring periodic written declarations from employees, the employer can establish documentary evidence that reasonable due diligence was exercised.
● Industry-Specific Considerations
In industries that frequently employ international students — such as food service, convenience stores, cleaning services, and the hotel industry — these rules must be thoroughly communicated to on-site supervisors, not just HR staff. Even if the HR department is fully aware of the regulations, a single shift increase by a site manager saying “please come in for a few more hours” can trigger a violation.
● Looking Ahead: From “Student” to Longer-Term Status
For employers considering retaining talented international students after graduation, it is worth planning early for transitions into work-based residence statuses. A well-designed pathway — for example, one that removes the five-year limit associated with certain categories by moving the worker onto a more stable status — can meaningfully improve retention. How the application is structured is critical, and those that wait may struggle when deadlines approach. A thorough review of the individual’s background and the company’s position may reveal an immediate solution that had been overlooked.
■ Impact on Japanese Language Institutions: Rebuilding Guidance and Oversight Systems
For Japanese language institutions, these reforms represent a substantial operational burden. Quarterly verification work, record retention, corrective guidance, and reporting to the immigration authorities will all require a thorough review of internal workflows.
Institutions that choose to use interviews to verify Japanese proficiency will also need to formalize evaluation criteria and train their interviewers. Superficial or perfunctory checks may later be treated as deficient by the immigration authorities, so coordination with qualified professionals in system design is essential.
■ Communicating with Foreign Employees and Students
When addressing sensitive topics such as visa status, working hours, or compliance expectations, three elements should always be communicated together: the legal rule, the reason behind it, and the practical consequence of non-compliance. Communicating all three clearly — rather than issuing isolated instructions — is what ultimately protects a brand and the trust of its foreign workforce.
■ Practical Advice from a Certified Administrative Lawyer
● For International Students
For foreign nationals navigating Japan’s residence status system, small procedural details are not minor — they carry significant weight at the time of renewal or change of status. Do not leave everything to your employer or your school; keep your own records, retain your own documents, and raise questions early.
・Keep accurate records of your current part-time working hours
・If you work at multiple employers, track the aggregate hours every week
・Prepare and preserve documentation proving your Japanese language proficiency (such as examination certificates)
● For Employers
・Standardize the Residence Card verification process, both at the time of hiring and at each renewal
・Establish a proper system for retaining time cards and shift schedules
・Conduct compliance training for employees involved in hiring and shift management
● For Japanese Language Institutions
・Develop standardized quarterly verification forms
・Design objective and defensible interview evaluation sheets
・Clarify the internal point of contact for communications with the Immigration Bureau
■ Conclusion: Turning Change from a “Risk” into an “Opportunity to Get Organized”
Public debate on immigration can easily be driven by emotion, especially when a short video clip goes viral. But when the dust settles, what matters is whether we turned it into a genuinely useful case study — one that helps students, employers, and institutions understand the system better than they did yesterday.
The reforms outlined above are not a limited practice adopted by a small number of companies or schools; they are a system-wide recalibration. The healthiest response is for all stakeholders to communicate based on verified facts, rather than on headlines or assumptions.
Regulatory change inevitably imposes additional burdens on those affected. Viewed from another angle, however, it offers an invaluable opportunity to review previously ambiguous management practices and build a robust compliance framework.
If international students, employers, and educational institutions each respond calmly on the basis of accurate information, there is no need for excessive anxiety. Conversely, complacent inaction can lead to severe consequences, including denial of residence status, penalties against business operators, and the revocation of institutional accreditation.
Our office provides comprehensive support — from individual consultations on residence status, to corporate compliance system design, to the preparation and submission of application documents. What we value most is working alongside clients to support the lives and businesses they aim to build in Japan.
If you feel uncertain in the face of these regulatory changes, please do not hesitate to reach out. Whether the question is large or small, I would be happy to discuss it with you.
