Note: This article is based on Japanese laws and materials published by the Immigration Services Agency of Japan (ISA) and the Cabinet Secretariat as of October 9, 2026.
Under "Gijinkoku" (the common short name for the status of residence "Engineer/Specialist in Humanities/International Services", 技術・人文知識・国際業務), if on-site work (shop-floor or front-line work) or simple tasks that do not fall under Gijinkoku become the main activity, the activities are judged not to fall under Gijinkoku. The extension of the period of stay may be denied, and the case may also become subject to revocation of the status of residence or, on the company's side, to the offense of facilitating illegal work (不法就労助長罪).
On the other hand, practical training (on-the-job training) at the start of employment and at similar times is permitted under certain conditions. This article explains the gap between the work stated in the application and the actual work: the criteria for judgment, the cases of denial published by the ISA, and the procedures when duties change.
Contents
- What may happen if you assign work different from the application?
- Revocation of status of residence and the content of the penalties
- How is it judged whether the work falls under Gijinkoku?
- Conditions under which temporary on-site work and practical training are permitted
- Points to check for practical training
- Cases of denial published by the ISA
- Procedures when the content of the work changes
- When a notification is required and when it is not
- What published materials show about examinations and investigations of the actual situation
- Published numbers of revocations
- What the company should check
- Frequently Asked Questions
- Summary
- References
What may happen if you assign work different from the application?
If work that does not fall under Gijinkoku has become the main activity, the extension of the period of stay may be denied. The Immigration Control and Refugee Recognition Act (入管法) also has provisions on revocation of status of residence and on penalties.
| Who | What may happen | Conditions and basis |
|---|---|---|
| The foreign national | The extension of the period of stay is denied | Cases such as where it is found that work not falling under Gijinkoku has, as a result, become the main activity during the stay. The ISA states that "measures such as denial may be taken" (Attachment 5, on hotels and ryokan (Japanese-style inns)) |
| The foreign national | Revocation of status of residence | Where the person has not engaged in the Gijinkoku activities and is residing while engaging in, or seeking to engage in, other activities. Except when there are justifiable grounds (Immigration Control and Refugee Recognition Act, Article 22-4, paragraph 1, item 5) |
| The foreign national | Penalties | Where the person, without obtaining permission to engage in activities other than those permitted under the status of residence previously granted (資格外活動許可), has engaged in activities for which remuneration is received that do not belong to the Gijinkoku activities. Imprisonment (拘禁刑) for not more than one year or a fine of not more than 2 million yen, or both (Immigration Control and Refugee Recognition Act, Article 19, paragraph 1 and Article 73) |
| The company | Offense of facilitating illegal work | Where a person has had a foreign national engage in illegal work in relation to their business activities (Immigration Control and Refugee Recognition Act, Article 73-2, paragraph 1, item 1) |
Revocation of status of residence and the content of the penalties
On revocation of status of residence, the text of the Act says that the Minister of Justice "may revoke" the status.
The grounds for revocation also include the case where the person has been residing without continuously engaging in the Gijinkoku activities for three months or more (except when there are justifiable grounds; item 6 of the same paragraph) and the case where the person obtained permission by deceit or other wrongful means (item 2 of the same paragraph). As an example of item 2, the ISA gives the case where a person who intends to engage in unskilled labor declared that they would engage in activities falling under the status of residence "Engineer".
The penalties for the foreign national become heavier where the person "is clearly found to be exclusively engaged in" activities that do not belong to Gijinkoku. They are imprisonment for not more than three years or a fine of not more than 3 million yen, or both, and the person also becomes subject to deportation (Immigration Control and Refugee Recognition Act, Article 70, paragraph 1, item 4 and Article 24, item 4(a)).
In its Q&A, the ISA explains that where a dispatched worker is made to engage in work not falling under Gijinkoku at the client (the company receiving the dispatched worker), both the dispatching company and the client "may fall under" the offense of facilitating illegal work. The content of the penalties is summarized in our explanation of the offense of facilitating illegal work.
Source: Immigration Services Agency of Japan, "Attachment 5 (Clarification of the Status of Residence for Foreign Nationals Working at Hotels, Ryokan (Japanese-style Inns), etc.)" (in Japanese), Section 1, "Revocation of Status of Residence (Article 22-4 of the Immigration Control and Refugee Recognition Act)" (in Japanese), "Frequently Asked Questions on Applications concerning Work-related Statuses of Residence (Q&A)" (in Japanese; July 2026), Q42 and Q43; e-Gov Laws and Regulations Search, "Immigration Control and Refugee Recognition Act" (in Japanese), Articles 19, 22-4, 24, 70, 73 and 73-2
How is it judged whether the work falls under Gijinkoku?
The immigration office judges by looking at the activities during the period of stay as a whole. If the activities falling under Gijinkoku are only a very small part, and the rest is work that requires no particular skills or knowledge or work that can be performed after repetitive training, the activities are judged not to fall under Gijinkoku.
Work in the field of natural science or humanities must be an activity that requires specialized ability of at least a certain level, grounded in an academic background. The ISA gives the following two as work that is generally not covered.
- Work for which the hiring criteria in a job advertisement state something like "No experience required. You will get used to it quickly." (未経験可、すぐに慣れます。)
- Work generally performed by Japanese employees who do not meet the requirements for academic background or practical experience set out in the criteria for landing permission
The ISA's Q&A also answers that, under Gijinkoku, "work in which general service work, manufacturing work, etc. becomes the main activity is not permitted."
The ISA's clarification document and its Q&A explain this with the words "only a very small part," "the greater part" and "main activity." They do not give a figure for what proportion of on-site work is acceptable (as of October 2026).
Source: Immigration Services Agency of Japan, "Clarification of the Status of Residence "Engineer/Specialist in Humanities/International Services"" (in Japanese; last revised April 2026), Section 1(2)ア and ウ, "Frequently Asked Questions on Applications concerning Work-related Statuses of Residence (Q&A)" (in Japanese; July 2026), Q39
Conditions under which temporary on-site work and practical training are permitted
Practical training at the start of employment and at similar times is permitted under certain conditions. Where a person temporarily has no choice but to perform work that does not fall under Gijinkoku, this is stated to be "not immediately regarded as a problem." The ISA sets out how each situation is handled as follows.
| Situation | How the ISA handles it |
|---|---|
| In the course of work, the person temporarily has no choice but to perform work not falling under Gijinkoku (a statement about hotels and ryokan) | Under the Immigration Control and Refugee Recognition Act, this is not immediately regarded as a problem. In cases such as where it is found that this work has, as a result, become the main activity during the stay, measures such as denial of the extension may be taken |
| As practical training at the start of employment or at similar times, the person does customer service at a restaurant, in-store sales at a retail shop, factory line work, etc. | Where it is part of practical training also given in the same way to Japanese employees who are university graduates, etc., and, looking at the activities during the period of stay as a whole, it does not take up the greater part of the period of stay, it is permitted within the scope of Gijinkoku after its appropriateness is judged |
| The practical training exceeds one year from hiring | The ISA asks for a training plan to be submitted and examines the reasonableness of the practical training period |
| The practical training is set only for foreign employees, or differs from that for Japanese employees | It is not found to be appropriate, except when there are reasonable grounds (such as training intended for Japanese language learning) |
Points to check for practical training
The main text of the clarification document also states that this training must be something "absolutely necessary" for performing work falling under Gijinkoku in the future.
The example of temporary work given by the ISA is a case where, during front desk work, a tour group checks in and the person has to carry guests' luggage to their rooms on short notice.
The "period of stay" referred to for practical training is not the period of stay decided by a single permission. It refers to the whole of the period during which the person is expected to reside under Gijinkoku, as anticipated from the employment contract and the training plan.
For a full-time employee with no fixed term of employment, it is envisaged that the whole of a "1 year" period of stay may be practical training. Where the employment contract is for three years only with no plan for renewal, an application that makes the first two years from hiring practical training is not permitted.
Where there is a period of practical training, the period of stay granted when the status of residence is decided, and at similar times, is in principle "1 year." If, at the time of extension, the practical training is continuing beyond what was originally planned, an explanation of the circumstances is required. Without reasonable grounds, the extension is not permitted.
Practical training carried out in the middle of the contract period as part of the person's career steps is handled in the same way.
Source: Immigration Services Agency of Japan, "Attachment 1 (Practical Training Permitted under the Status of Residence "Engineer/Specialist in Humanities/International Services")" (in Japanese), "Attachment 5 (Clarification of the Status of Residence for Foreign Nationals Working at Hotels, Ryokan (Japanese-style Inns), etc.)" (in Japanese), Section 1
Cases of denial published by the ISA
In the cases of denial published by the ISA, what was checked was the content of the work actually to be performed, not the job title written on the application form. The following table shows cases where the work explained in the application differed from the content that was confirmed. All of them were denied at the application stage.
| Work explained in the application | Content that was confirmed | Case number |
|---|---|---|
| To be hired by a hotel | When detailed documents were requested, the main work turned out to be carrying guests' luggage and cleaning guest rooms | Attachment 5, denial ① |
| Front desk work at a hotel | For the first two years after hiring, the person was to engage exclusively in serving meals in the restaurant and cleaning guest rooms as practical training | Attachment 5, denial ⑥ |
| Front desk staff at a hotel (reservation management, interpretation). During the first year after joining, also to serve meals and clean guest rooms as training | A foreign national hired in the past by the same hotel for the same kind of reason had continued serving meals and cleaning guest rooms far beyond the planned training period | Attachment 3, 3-1, denial (7) |
| Translation and interpretation at the client | The job description in the written worker dispatch contract was "store staff." The client was a retail shop, and the explanation was that the person would be made to engage in in-store sales and customer service | Attachment 3, 3-1, denial (8) |
| Processing, assembly, inspection and packing of parts at a factory | Almost all of the work was the same as that of the technical intern trainees (技能実習生) at the same factory | Attachment 3, 3-1, denial (9) |
| Translation and interpretation | The place of work was a restaurant outlet. The interpretation consisted of taking orders in English, and the translation was only translating the menu | Attachment 3, 3-2, denial (5) |
| Manager candidate at the head office of a restaurant chain | The plan was that, after customer service and cooking at outlets for a period of several years with no fixed length, only those selected would take up work falling under Gijinkoku | Attachment 3, 2, denial (5) |
There is also a case that was permitted. It was a career-track position (総合職) at a large resort hotel, and the work partly included customer service in the restaurant and similar tasks. The main work was translation and interpretation at the front desk, reservation management, customer satisfaction analysis and the like, and it was the same kind of work as that of Japanese employees hired for career-track positions (Attachment 3, 3-1, permission (12)).
Attachment 5 states that the cases listed are examples of permission and denial, and that whether each application is permitted is decided through an individual examination.
Source: Immigration Services Agency of Japan, "Attachment 3 (Cases)" (in Japanese), "Attachment 5 (Clarification of the Status of Residence for Foreign Nationals Working at Hotels, Ryokan (Japanese-style Inns), etc.)" (in Japanese), Section 2
Procedures when the content of the work changes
When the work to be assigned changes, first check whether the new work falls under Gijinkoku. If it does not, a change of status of residence is required before the person takes up that work.
| Situation | Procedure | Who and when |
|---|---|---|
| You want to check whether the new work falls under Gijinkoku | Application for a Certificate of Authorized Employment (就労資格証明書交付申請) | The foreign national applies to the Regional Immigration Services Office that has jurisdiction over their place of residence. It is not mandatory |
| The contracting company has changed, for example through a job change | Notification of the Contracting Organization (所属（契約）機関に関する届出) | The foreign national files the notification within 14 days from the termination of the contract or the conclusion of a new contract |
| The new work does not fall under Gijinkoku | Application for Change of Status of Residence (在留資格変更許可申請) | The foreign national applies, and the Minister of Justice decides whether to grant permission |
A Certificate of Authorized Employment is a document in which the Commissioner of the Immigration Services Agency certifies the work activities the person is allowed to engage in. When the place of work or the content of the activities changes, the application is filed with documents showing the details of the new place of work or the new activities. The standard processing time is "the same day (one to three months in cases such as a change of place of work)."
A Certificate of Authorized Employment is not a permit to work. Nor is it something without which the person cannot work.
When a notification is required and when it is not
The Notification of the Contracting Organization covers a change of the name or location of the contracting organization, the organization ceasing to exist, the termination of the contract, and the conclusion of a new contract. A change of assigned duties within the same company is not listed among the events requiring notification. Secondment (出向) to a group company or the like requires notification as the conclusion of a new contract (Q16 of the ISA's Q&A on notifications).
Even when no notification is required, the content of the activities is looked at in the next extension. The ISA's guidelines make it a requirement for permission that the activities the person intends to engage in fall under the status of residence. It is also necessary that the person has been engaging in the activities corresponding to the status of residence currently held.
If on-site work is going to be central, consider a change to another status of residence, such as Specified Skilled Worker (特定技能), instead of Gijinkoku. An overview of Specified Skilled Worker is given in our Complete Guide to the Specified Skilled Worker Visa. If you are unsure how to judge, we will go over the content of the work with you in our consultation on applications for Engineer/Specialist in Humanities/International Services.
Source: Immigration Services Agency of Japan, "Application for a Certificate of Authorized Employment" (in Japanese), "Certificate of Authorized Employment (Article 19-2 of the Immigration Control and Refugee Recognition Act)" (in Japanese), "Notification of the Contracting Organization" (in Japanese), "Guidelines for Permission for Change of Status of Residence and Extension of Period of Stay" (in Japanese; last amended June 2026), Sections 1 and 3, "Frequently Asked Questions on Applications concerning Work-related Statuses of Residence (Q&A)" (in Japanese; July 2026), Q3; e-Gov Laws and Regulations Search, "Immigration Control and Refugee Recognition Act" (in Japanese), Articles 19-2, 19-16 and 20
What published materials show about examinations and investigations of the actual situation
In the Comprehensive Measures decided on January 23, 2026, the government listed "strict operation of the examination" for Gijinkoku as one of its measures. This is a document decided by the ministerial council.
| Time | What the published materials say |
|---|---|
| January 23, 2026 | Stated in the Comprehensive Measures as a measure being implemented. For cases where there is doubt about the actual state of the activities, a careful examination is carried out after an investigation of the actual situation, such as officials of a regional immigration services bureau visiting the place of work to investigate |
| Same as above | Stated as a measure to be implemented promptly. The activities of accepting organizations and clients suspected of having people engage in work that does not fall under the status of residence will be investigated, the examination will be operated strictly, and how permission should be granted will be considered |
| February 2026 | Regional immigration services bureaus were instructed to carry out an investigation of the actual situation at the client where, in a residence examination for a dispatched worker, there is doubt about the content of the activities (progress status document) |
| Applications filed on or after March 9, 2026 | The documents to be submitted for dispatched workers were changed. Written pledges by the dispatching company and the client, among others, were added |
| Applications filed on or after April 15, 2026 | The clarification document was revised. For work dealing directly with people that mainly uses language ability, Categories 3 and 4 submit documents on language ability according to the type of application |
In a residence examination, the immigration office may directly check the content of the work and the state of the activities not only with the dispatching company but also with the client. The inquiry into facts for residence examinations is provided for in Article 59-2 of the Immigration Control and Refugee Recognition Act. Immigration inspectors, etc. may question the persons concerned and ask them to present documents.
Published numbers of revocations
The figures that are published are those for revocation of status of residence. Revocations for Gijinkoku numbered 11, 23, 32, 69 and 63, in order from 2021. The grounds for the 63 revocations in 2025 were item 2 in 19 cases, item 3 in 23 cases, item 5 in 13 cases and item 6 in 8 cases.
The breakdown of the 13 cases under item 5 (whether or not they were due to a discrepancy in the content of the work), the number of investigations of the actual situation, and the number of Gijinkoku extensions that were denied are not given in the materials we checked this time (as of October 2026).
Source: Cabinet Secretariat, "Comprehensive Measures for the Acceptance of Foreign Nationals and Orderly Coexistence" (in Japanese; decided January 23, 2026), Measure Nos. 24 and 25, "Overview of Efforts for the Safety and Security of the Public (Progress Status, Detailed Version)" (in Japanese; as of the end of June 2026), Management No. 10; Immigration Services Agency of Japan, "Handling of Cases Where a Person Works as a Dispatched Worker under the Status of Residence "Engineer/Specialist in Humanities/International Services"" (in Japanese; July 2026), "Status of Residence "Engineer/Specialist in Humanities/International Services"" (in Japanese), Notices section, "Number of Revocations of Status of Residence in 2025" (in Japanese; March 27, 2026); e-Gov Laws and Regulations Search, "Immigration Control and Refugee Recognition Act" (in Japanese), Article 59-2
What the company should check
Compare the content of the work written in the application form and the employment contract with the work actually being assigned now. The following steps are our office's own summary, based on the ISA materials described so far.
- Take out the "Details of activities" (活動内容詳細) field of the application form and the job duties in the employment contract, and compare them with the actual work
- If on-site work is included, sort out whether it is temporary, practical training, or has become the main activity
- For practical training, check whether it is training needed for the later work, whether it is also given in the same way to Japanese employees, and when it ends. If it exceeds one year from hiring, prepare a training plan
- Before deciding on a reassignment or a change of duties, check whether the new work falls under Gijinkoku
- If you accept dispatched workers, check in the same way the work actually being assigned at the client
- Keep records of the work actually performed, such as daily work reports
If step 2 shows that the on-site work "has become the main activity," either return the content of the work to something that falls under Gijinkoku or consider a change of status of residence. If you apply for an extension as things are, it may be denied.
Frequently Asked Questions
Can an employee hired as an interpreter also do customer service in a store?
If customer service becomes the main activity, it is not permitted under Gijinkoku. The ISA states that, under Gijinkoku, work in which general service work becomes the main activity is not permitted.
For people who have graduated from a Japanese university and have a high level of Japanese language ability, among others, there is a separate status of residence, "Designated Activities" (特定活動; Public Notice No. 46: Graduate from a university in Japan). As examples for this status of residence, the ISA gives store management work at a restaurant and customer service work that also involves interpretation.
Does experience under Specified Skilled Worker or Technical Intern Training count as practical experience for Gijinkoku?
Merely having gained practical experience under Technical Intern Training (技能実習) or Specified Skilled Worker is not, by that alone, treated as satisfying the "practical experience" in the Gijinkoku criteria. The ISA explains that it does not envisage a person changing from Specified Skilled Worker (i) to Gijinkoku to advance their career on the basis of practical experience gained under Specified Skilled Worker.
Source: Immigration Services Agency of Japan, "Frequently Asked Questions on Applications concerning Work-related Statuses of Residence (Q&A)" (in Japanese; July 2026), Q38, Q39 and Q41
Summary
Whether the work falls under Gijinkoku is judged by looking at the activities during the period of stay as a whole. If on-site work or simple tasks that do not fall under Gijinkoku have become the main activity, the extension may be denied, and the case may also become subject to revocation of the status of residence or the offense of facilitating illegal work.
Practical training at the start of employment and at similar times is permitted under certain conditions. Where a person temporarily has no choice but to perform work that does not fall under Gijinkoku, the document on hotels and ryokan states that this is "not immediately regarded as a problem." First, compare the content of the work written in the application form and the employment contract with the actual work. When the work changes through a reassignment or the like, check first whether the new work falls under Gijinkoku, and if it does not, consider a change of status of residence.
References
- Immigration Services Agency of Japan, "Clarification of the Status of Residence "Engineer/Specialist in Humanities/International Services"" (in Japanese; last revised April 2026), "Attachment 1 (Practical Training)" (in Japanese), "Attachment 3 (Cases)" (in Japanese), "Attachment 5 (Hotels, Ryokan, etc.)" (in Japanese)
- Immigration Services Agency of Japan, "Frequently Asked Questions on Applications concerning Work-related Statuses of Residence (Q&A)" (in Japanese; July 2026)
- Immigration Services Agency of Japan, "Guidelines for Permission for Change of Status of Residence and Extension of Period of Stay" (in Japanese; last amended June 2026)
- Immigration Services Agency of Japan, "Revocation of Status of Residence (Article 22-4 of the Immigration Control and Refugee Recognition Act)" (in Japanese; accessed October 9, 2026)
- Immigration Services Agency of Japan, "Number of Revocations of Status of Residence in 2025" (in Japanese; March 27, 2026)
- Immigration Services Agency of Japan, "Number of Revocations of Status of Residence in 2025 (Press Material)" (in Japanese; March 27, 2026)
- Immigration Services Agency of Japan, "Application for a Certificate of Authorized Employment" (in Japanese), "Certificate of Authorized Employment (Article 19-2 of the Immigration Control and Refugee Recognition Act)" (in Japanese; accessed October 9, 2026)
- Immigration Services Agency of Japan, "Notification of the Contracting Organization" (in Japanese; accessed October 9, 2026)
- Immigration Services Agency of Japan, "Handling of Cases Where a Person Works as a Dispatched Worker under the Status of Residence "Engineer/Specialist in Humanities/International Services"" (in Japanese; July 2026)
- Immigration Services Agency of Japan, "Status of Residence "Engineer/Specialist in Humanities/International Services"" (in Japanese; accessed October 9, 2026)
- Cabinet Secretariat, "Comprehensive Measures for the Acceptance of Foreign Nationals and Orderly Coexistence" (in Japanese; decided by the ministerial council on January 23, 2026)
- Cabinet Secretariat, "Overview of Efforts for the Safety and Security of the Public (Progress Status, Detailed Version)" (in Japanese; as of the end of June 2026)
- Immigration Control and Refugee Recognition Act, Articles 19, 19-2, 19-16, 20, 22-4, 24, 59-2, 70, 73 and 73-2
