Note: This article is based on Japanese laws and materials published by the Immigration Services Agency of Japan (ISA) and the Organization for Technical Intern Training (OTIT) as of October 9, 2026.
An external auditor (外部監査人) under Employment for Skill Development (育成就労) is a person who audits, from outside the corporation, whether a supervising and support organization (監理支援機関) is properly carrying out its audits and other operations. Under the Employment for Skill Development (ESD) Program (育成就労制度), which begins on April 1, 2027, having an external auditor conduct audits has become a licensing criterion for supervising and support organizations.
The method of appointing a "designated external officer" (指定外部役員), which could be chosen under the Technical Intern Training Program (技能実習制度), is not among the licensing criteria of the ESD Program. Because the external auditor's name (for a corporation, its corporate name) is written in the license application form, the external auditor needs to be decided before the application. Below, we explain why it became mandatory, how it differs from the Technical Intern Training Program, an outline of the requirements, and when to appoint.
Contents
- What is an external auditor?
- What does an external auditor do?
- Why did it become mandatory?
- Differences from the external auditor and the designated external officer under the Technical Intern Training Program
- Requirements for external auditors
- Parties with whom a relationship prevents a person from becoming an external auditor
- Where is the training course (養成講習) taken?
- By when should the external auditor be decided?
- Frequently Asked Questions
- Summary
- References
What is an external auditor?
An external auditor is a person who audits, from outside the corporation, the performance of duties by the officers of a supervising and support organization. The supervising and support organization appoints the external auditor, and either a corporation or an individual can serve.
A supervising and support organization is the organization that replaces the supervising organization (監理団体) of the Technical Intern Training Program. It is a nonprofit corporation that mediates employment relationships between accepting companies (ESD implementing organizations, 育成就労実施者) and foreign nationals, and supervises the accepting companies.
The basis is the licensing criteria for supervising and support organizations set out in the ESD Act (育成就労法; Act on Proper Implementation of Employment for Skill Development and Protection of Skill Development Employees, 外国人の育成就労の適正な実施及び育成就労外国人の保護に関する法律). Below, the Regulation for Enforcement of this Act is referred to as "the Enforcement Regulation" (施行規則).
(v) in addition to auditing by inspectors (監事) and other persons responsible for auditing the business of the corporation, it has taken measures to have a person who does not have a close relationship as provided for by order of the competent ministries with the organization implementing supervising-organization-type ESD, and who satisfies the requirements provided for by order of the competent ministries, including having the knowledge, experience, etc. needed to perform the audit of the performance of duties fairly and properly, audit the officers' performance of duties pertaining to the supervising and support services, pursuant to order of the competent ministries. (Japanese original: 五 監事その他法人の業務を監査する者による監査のほか、監理型育成就労実施者と主務省令で定める密接な関係を有しない者であって、職務の執行の監査を公正かつ適正に遂行することができる知識又は経験等を有することその他主務省令で定める要件に適合するものに、主務省令で定めるところにより、役員の監理支援事業に係る職務の執行の監査を行わせるための措置を講じていること。)
What is required is to provide for an audit by an outside person in addition to the internal audit by the corporation's auditors (監事, rendered as "inspectors" in the provision above; internal officers who audit the corporation) and the like. What is audited is the officers' performance of their duties in relation to the supervising and support services.
| What has been decided | Basis |
|---|---|
| That measures to have an external auditor conduct audits are a licensing criterion | ESD Act, Article 25, paragraph 1, item 5 |
| The requirements for external auditors and the method of the external audit | Regulation for Enforcement of the ESD Act, Article 47 |
| That the name of the external auditor (氏名又は名称: an individual's name or a corporation's name) is written in the license application form | The same Regulation, Article 42, item 3 |
| The transitional measure for the training course, and the treatment of persons who were designated external officers | The same Regulation, Article 4, paragraph 3 and Article 5 of the Supplementary Provisions |
| The interpretation of the provisions, and the documents checked in the application | Operational Guidelines for the Employment for Skill Development Program (育成就労制度運用要領; revised August 2026), Chapter 5, Section 2, No. 5 |
The ESD Act and the Enforcement Regulation will come into effect on April 1, 2027, except for some provisions.
Source: e-Gov Laws and Regulations Search, "Act on Proper Implementation of Employment for Skill Development and Protection of Skill Development Employees" (in Japanese; Act No. 89 of 2016; as amended by Act No. 60 of 2024; effective April 1, 2027), Articles 2 and 25, "Regulation for Enforcement of the same Act" (in Japanese; Order of the Ministry of Justice and the Ministry of Health, Labour and Welfare No. 4 of 2025; effective April 1, 2027), Articles 42 and 47, and Articles 4 and 5 of the Supplementary Provisions; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program, revised August 2026, Chapter 5), "Overview of the Amended Act (Establishment of the Employment for Skill Development Program, etc.)" (in Japanese)
What does an external auditor do?
An external auditor does two things: periodic checks at the places of business, and accompanying audits of accepting companies. These are set out in Article 47, paragraph 3 of the Enforcement Regulation.
- At least once every three months for each place of business that conducts supervising and support services, check whether the audits of accepting companies and other operations are being carried out properly
- At least once a year for each place of business, accompany an audit that the supervising and support organization conducts on an accepting company, and check it
In both cases, a document stating the results is submitted to the supervising and support organization. How to proceed, and how the work is divided with the supervising and support organization's own operations, are summarized in What Does an External Auditor in Employment for Skill Development Do?.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 3
Why did it become mandatory?
The reason is to add an outside perspective and ensure the neutral operation of the supervising and support organization's work.
The Operational Guidelines state that, when a supervising and support organization provides supervising and support to accepting companies, there are aspects that make it difficult to operate its work neutrally. They explain that, for this reason, the external audit arrangement was made mandatory by law.
The ISA's "Overview of the Amended Act" also states, regarding the supervising and support organizations that replace supervising organizations, that "appointing an external auditor is made a requirement for the license" (外部監査人の設置を許可要件とする). The ISA's Q&A lists the following requirements, among others, as licensing criteria newly established for the structure of supervising and support organizations.
- An external auditor has been appointed
- There is no insolvency (liabilities exceeding assets)
- The number of accepting organizations (ESD implementing organizations) to which supervising and support is provided is, in principle, two or more
- There are two or more full-time officers and employees engaged in the practical work of the supervising and support services, and the staffing criteria according to the number of accepting organizations and the number of Skill Development Employees (育成就労外国人; foreign nationals accepted under the ESD Program) are met
A supervising organization under the Technical Intern Training Program cannot become a supervising and support organization as it is. It needs to newly obtain a supervising and support organization license. The program as a whole is summarized in What Is Japan's Employment for Skill Development Program? From April 2027: vs. Technical Intern Training, Employer Prep.
Source: Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program, revised August 2026, Chapter 5, Section 2, No. 5), "Overview of the Amended Act (Establishment of the Employment for Skill Development Program, etc.)" (in Japanese), "Q&A on the Employment for Skill Development Program" (in Japanese), Q33 and Q34
Differences from the external auditor and the designated external officer under the Technical Intern Training Program
Under the Technical Intern Training Program, either a "designated external officer" or an "external auditor" could be chosen, but the licensing criterion of the ESD Program is the external auditor only.
A designated external officer is a person whom a supervising organization, when it does not take the external audit arrangement, designates as the officer in charge of checking whether its operations are being carried out properly.
| Technical Intern Training Program (supervising organization) | ESD Program (supervising and support organization) | |
|---|---|---|
| Licensing criteria | Either one of two arrangements: an arrangement through the composition of the officers (appointing a designated external officer), or an external audit by an external auditor | An external audit arrangement by an external auditor |
| Qualifications of the external auditor | No provision listing qualifications | An attorney (弁護士), a Sharoushi (labor and social security attorney, 社会保険労務士) or a Gyoseishoshi (administrative scrivener, 行政書士) (including their respective corporations), or another person with expertise in Employment for Skill Development |
| Training course for the external auditor | Has completed, within the past three years, the training course for external auditors specified by public notice | The same. For the time being, a person who has completed the training course of the Technical Intern Training Program is also deemed to have completed it |
| Consent to the publication of one's name | No provision | Consent to the Organization (機構) publishing the name on the internet is a requirement |
| Frequency of the external audit | For each place of business, a check at least once every three months and accompaniment at least once a year | The same |
Can a person who was a designated external officer become an external auditor?
Officers and employees of the supervising and support organization, and persons who were its officers or employees within the past five years, cannot become its external auditor (Enforcement Regulation, Article 47, paragraph 2, item 3, sub-item (a) (イ)). However, this provision does not apply to a person to whom both of the following apply (Article 5 of the Supplementary Provisions of the same Regulation).
- The person was a part-time designated external officer of a supervising organization before April 1, 2027
- The person was not engaged in work related to the supervising business (other than the checks made as a designated external officer)
Only this provision is disapplied. The requirements on the training course, qualifications and other relationships need to be met in the same way as by anyone else.
Source: e-Gov Laws and Regulations Search, "Act on Proper Technical Intern Training and Protection of Technical Intern Trainees" (in Japanese; current), Article 25, paragraph 1, item 5, "Regulation for Enforcement of the same Act" (in Japanese; current), Article 26, item 3 and Article 30, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, and Article 4, paragraph 3 and Article 5 of the Supplementary Provisions; Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; on applications for a supervising and support organization license; updated July 10, 2026), 7-7 and 7-10
Requirements for external auditors
An external auditor needs to meet the following requirements throughout, from the time the license is applied for and for as long as the license is held.
| Requirement | Content | Enforcement Regulation |
|---|---|---|
| Training course | Has completed, within the past three years, the training course for external auditors specified by public notice by the Minister of Justice and the Minister of Health, Labour and Welfare | Article 47, paragraph 2, item 1 |
| Qualifications and expertise | Is an attorney, a Sharoushi or a Gyoseishoshi (including their respective corporations), or another person with expertise in Employment for Skill Development | Item 2 of the same paragraph |
| Relationships with accepting companies, the supervising and support organization and others; grounds for disqualification (欠格事由) | Does not fall under the relationships or the grounds for disqualification listed in the Enforcement Regulation (see the table in the next section) | Article 47, paragraph 1 and paragraph 2, item 3 |
| Consent to the publication of one's name | Has consented to the Organization (機構) publishing the name on the internet. What is published is the name for an individual and the corporate name for a corporation | Article 47, paragraph 2, item 4 |
The Operational Guidelines give two kinds of "another person with expertise in Employment for Skill Development" (その他育成就労に関する知見を有する者): a person with advanced knowledge and experience regarding the laws and regulations on immigration or labor, and an organization that has been announced by public notice as an organization conducting the training course for external auditors and has a substantial track record.
The first is described as a person who can be objectively evaluated, such as a university professor who researches the laws and regulations on immigration or labor. The second is described as a nonprofit corporation that has conducted the training course 20 times or more in either of the two most recent business years.
The ISA's Q&A also lists, as requirements for external auditors, attending the training course (養成講習), qualifications, not having a close relationship, externality (being outside the organization), and not falling under the grounds for disqualification, among others.
Whether a person can serve in each situation, such as a licensed professional with an advisory (retainer) contract or a former officer or employee, is summarized in Who Can and Cannot Become an External Auditor in Employment for Skill Development.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraphs 1 and 2; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program, revised August 2026, Chapter 5, Section 2, No. 5), "Q&A on the Employment for Skill Development Program" (in Japanese), Q36; Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; on applications for a supervising and support organization license; updated July 10, 2026), 7-19
Parties with whom a relationship prevents a person from becoming an external auditor
A person who has any of the following relationships with accepting companies, the supervising and support organization or others cannot become an external auditor even if the person holds a qualification.
| Party | Persons who cannot become an external auditor |
|---|---|
| An accepting company to which supervising and support is provided (including a company to which supervising and support was provided within the past five years) | That company, its officers and employees, and persons who were any of these within the past five years. The spouses and relatives within the second degree of kinship of these persons |
| The supervising and support organization that applies | Its officers and employees, and persons who were any of these within the past five years |
| Members (構成員; such as members of a cooperative or an association) of the supervising and support organization | The members, and their officers and employees. For members engaged in business in a field in which supervising and support is provided, persons who were any of these within the past five years are also included |
| Other accepting companies and other supervising and support organizations | Those companies and organizations, and their officers and employees |
| A foreign sending organization (送出機関) that acts as an intermediary for job applications to the supervising and support organization | That organization, its officers and employees, and persons who were any of these within the past five years |
| Grounds for disqualification for the license (ESD Act, Article 26) | A person who falls under any of sub-items (a) to (d) (イ to ニ) of item 5 of that Article. For corporations, a corporation that falls under any of the items of that Article, and a corporation that has, among its officers, a person who falls under any of sub-items (a) to (e) (イ to ホ) of Article 47, paragraph 2, item 3 of the Enforcement Regulation |
Members that are not engaged in business in a field in which supervising and support is provided, and their officers and employees, are ones that the Operational Guidelines state are not permitted.
In addition, a person for whom it is found that there is a risk that the fairness of the external audit will be impaired also cannot become an external auditor. This includes cases where there is a close relationship in social life, and cases where the person has in the past committed a wrongful or significantly unjustifiable act in relation to Employment for Skill Development.
- An attorney who has concluded an advisory (retainer) contract with an accepting company to which supervising and support is provided
- A corporation that receives membership fees, regularly or on an ad hoc basis, from an accepting company to which supervising and support is provided
- The spouse or a relative within the second degree of kinship of an officer or employee of the supervising and support organization
- A corporation that receives membership fees, regularly or on an ad hoc basis, from the supervising and support organization
The Operational Guidelines also state that an attorney or the like who has concluded an advisory contract with the supervising and support organization does not automatically fall under a "close relationship in social life."
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 1 and paragraph 2, item 3, "Act on Proper Implementation of Employment for Skill Development and Protection of Skill Development Employees" (in Japanese; effective April 1, 2027), Article 26; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program, revised August 2026, Chapter 5, Section 2, No. 5)
Where is the training course (養成講習) taken?
For the time being, a person who has completed the "training course for supervision managers, etc." (監理責任者等講習) of the Technical Intern Training Program can also be appointed as an external auditor. This is a transitional measure set out in Article 4, paragraph 3 of the Supplementary Provisions of the Enforcement Regulation. The Operational Guidelines and OTIT's guidance state that a person who attended this course before the ESD Act comes into effect can also be appointed.
The training courses are conducted by organizations announced by public notice by the competent ministers (training course providers, 養成講習機関). Even after being appointed, the external auditor needs to attend and complete the next course within three years from the date on which the previous course was completed. When a corporation serves as the external auditor, the person who conducts the audit on site and directs and takes charge of that audit (the person responsible for conducting the audit, 監査実施責任者) attends the course.
| Training course | Status (as of October 9, 2026) |
|---|---|
| Training course for supervision managers, etc. under the Technical Intern Training Program | The pages of the ISA and the Ministry of Health, Labour and Welfare (MHLW) give information on the training course providers, and the MHLW page gives the schedule. The MHLW list is as of April 10, 2026 |
| Training course for external auditors under the ESD Program | OTIT states that it "will announce this separately in the Operational Guidelines for the Employment for Skill Development Program and elsewhere" (改めて、育成就労制度運用要領などにおいてお知らせします) (Frequently Asked Questions updated July 10, 2026). On the ESD Program pages of the ISA and OTIT, we could not find information on the organizations conducting the course or the schedule. The Operational Guidelines state that the call for training course providers for fiscal year 2026 is planned to be held between December 1 and December 28, 2026, and that recruitment of participants can begin after the public notice |
In the license application, a copy of the certificate of attendance (受講証明書) for the training course is submitted. OTIT asks applicants to submit one for a course attended within the past three years as of the time of application.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 4, paragraph 3 of the Supplementary Provisions; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program, revised August 2026, Chapter 8), "Training Course Providers" (in Japanese); Ministry of Health, Labour and Welfare, "Training Courses under the Technical Intern Training Program" (in Japanese); Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; on applications for a supervising and support organization license; updated July 10, 2026), 7-17, and the list of application documents posted on "Application for a supervising and support organization license prior to the enforcement date" (in Japanese)
By when should the external auditor be decided?
The external auditor needs to be decided before applying for the supervising and support organization license. This is because the external auditor's name is written in the license application form, and a letter of acceptance of appointment and other documents are attached.
| Documents submitted in the application | What is written or submitted about the external auditor |
|---|---|
| Application for License of Supervising and Support Organization (監理支援機関許可申請書; Appended Form No. 15) | The name of the external auditor (an individual's name or a corporation's name) |
| Letter of Acceptance of Appointment, Written Pledge and Profile of the External Auditor (外部監査人の就任承諾書及び誓約書並びに概要書; Reference Form No. 2-5) | For a corporation, the name of the person responsible for conducting the audit who attended the training course is also written |
| Copy of the certificate of attendance for the training course for external auditors | One for a course attended within the past three years as of the time of application. For a corporation, one for every person responsible for conducting the audit |
The supervising and support organization license can be applied for before the program begins (application prior to the enforcement date, 施行日前申請). The corporation intending to become a supervising and support organization applies to the Annex of the Examination Division, Head Office (本部審査課分室) of the Organization for Technical Intern Training (OTIT, 外国人技能実習機構). The application period is from April 15, 2026 through March 31, 2027.
OTIT advises that the application be filed "six months or more before the supervising and support services are to begin" (監理支援事業を開始する6か月以上前まで). September 30, 2026, which had been indicated as the application date for those wishing to conduct the services from April 1, 2027, has passed. If you apply from now, complete the appointment of the external auditor and the attendance of the training course first, so that you can apply six months or more before the date on which you wish to begin the services.
If a matter stated in the application form changes after the application, a written request for change (変更申出書) is promptly submitted to OTIT. The external auditor's name is one of the matters stated in the application form.
If a written request for change is not submitted by December 28, 2026 (it must reach OTIT by that date), the application will be examined on the basis of the content before the change. If the license is obtained on that content, a notification of change is made on or after April 1, 2027 and within one month from the date on which the license was obtained.
The licensing criteria need to continue to be met after the license is obtained.
Our office also accepts appointment as an external auditor in Employment for Skill Development, and you can consult us starting with a check of whether independence can be secured.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 42, item 3 and Article 43, item 9; Organization for Technical Intern Training, "Application for a supervising and support organization license prior to the enforcement date" (in Japanese; updated October 8, 2026), and the list of application documents, "Application Procedures for a Supervising and Support Organization License [for Applications prior to the Enforcement Date]" and "Changes to the Matters Stated in the Application for License of Supervising and Support Organization, etc. [Applications prior to the Enforcement Date]" posted on the same page; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program, revised August 2026, Chapter 5, Section 2, No. 5)
Frequently Asked Questions
Can one external auditor serve multiple supervising and support organizations?
Yes. OTIT states that concurrently serving as the external auditor of multiple supervising and support organizations (including supervising organizations) is possible if the person satisfies the requirements and does not fall under the grounds for disqualification. However, a person who is an officer or employee of another supervising and support organization cannot become an external auditor.
Can a person who is serving as an external auditor under the Technical Intern Training Program become an external auditor under the ESD Program as is?
If the person is not an attorney, a Sharoushi or a Gyoseishoshi, having served as an external auditor under the Technical Intern Training Program is not, by itself, enough to become one. OTIT has answered that the persons without a qualification who may be recognized as external auditors are the two kinds of "another person with expertise in Employment for Skill Development."
Can a certified tax accountant (税理士), certified public accountant (公認会計士) or judicial scrivener (司法書士) become an external auditor?
Holding the qualification is not, by itself, enough. OTIT states that the person needs to fall under either of the two kinds of "another person with expertise in Employment for Skill Development," satisfy the other requirements, and not fall under the grounds for disqualification.
A person who is qualified as an attorney, a Sharoushi or a Gyoseishoshi also needs to complete the training course (養成講習) and meet the requirements on relationships and disqualification.
Source: Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; on applications for a supervising and support organization license; updated July 10, 2026), 7-5, 7-6, 7-8 and 7-10
Summary
Under the ESD Program, having an external auditor conduct audits is a licensing criterion for supervising and support organizations. The method of appointing a designated external officer, which could be chosen under the Technical Intern Training Program, is not among the licensing criteria of the ESD Program. For external auditors, there are requirements on the training course, qualifications, relationships with accepting companies and the supervising and support organization, and consent to the publication of one's name.
Because the external auditor's name is written in the license application form, the external auditor is decided before the application. Supervising organizations that will apply from now should first check whether the candidate meets the requirements and whether there is a certificate of attendance for the training course.
References
- Act on Proper Implementation of Employment for Skill Development and Protection of Skill Development Employees (Act No. 89 of 2016; as amended by Act No. 60 of 2024; effective April 1, 2027. Until the enforcement date, it is displayed on e-Gov under the title of the Technical Intern Training Act), Articles 2, 25 and 26
- Regulation for Enforcement of the Act on Proper Implementation of Employment for Skill Development and Protection of Skill Development Employees (Order of the Ministry of Justice and the Ministry of Health, Labour and Welfare No. 4 of 2025; as amended by Order of the Ministry of Justice and the Ministry of Health, Labour and Welfare No. 3 of 2026; effective April 1, 2027), Articles 42, 43 and 47, and Articles 4 and 5 of the Supplementary Provisions
- Act on Proper Technical Intern Training and Protection of Technical Intern Trainees (Act No. 89 of 2016; current), Article 25; Regulation for Enforcement of the same Act (Order of the Ministry of Justice and the Ministry of Health, Labour and Welfare No. 3 of 2016; current), Articles 26 and 30
- Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program; revised August 5, 2026), Chapters 5 and 8
- Immigration Services Agency of Japan, "Overview of the Amended Act (Establishment of the Employment for Skill Development Program, etc.)" (in Japanese)
- Immigration Services Agency of Japan, "Q&A on the Employment for Skill Development Program" (in Japanese; updated May 28, 2026)
- Immigration Services Agency of Japan, "Training Course Providers" (in Japanese; Technical Intern Training Program)
- Ministry of Health, Labour and Welfare, "Training Courses under the Technical Intern Training Program" (in Japanese; the list of training course providers is as of April 10, 2026)
- Organization for Technical Intern Training, "Application for a supervising and support organization license prior to the enforcement date" (in Japanese; updated October 8, 2026)
- Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; on applications for a supervising and support organization license; updated July 10, 2026)
