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.
The work of an external auditor (外部監査人) under Employment for Skill Development (ESD, 育成就労) consists of two things: checks at the places of business of the supervising and support organization (監理支援機関), and accompanying the audits that the organization conducts of accepting companies. The check is conducted at least once every three months for each place of business and the accompaniment at least once a year, and in both cases the results are put in writing and submitted to the supervising and support organization.
The audit of accepting companies itself is work performed by the officers and employees of the supervising and support organization. Below, we explain the frequency, the method and the handling of documents in line with the Regulation for Enforcement of the ESD Act (育成就労法施行規則), which comes into effect on April 1, 2027, and the ISA's Operational Guidelines (運用要領). The definition of an external auditor and the requirements are summarized in What Is an External Auditor in Japan's Employment for Skill Development?.
Contents
- The external auditor has two kinds of work
- How to count "at least once every three months" and "at least once a year"
- How the check proceeds, and how the result documents are handled
- How this differs from the supervising and support organization's own audits
- Work the external auditor does not perform
- How this differs from the work of the external auditor under the Technical Intern Training Program
- Frequently Asked Questions
- Summary
- References
The external auditor has two kinds of work
The work of the external auditor consists of two things: regular checks at the place of business, and accompanying the audits of accepting companies. Article 47, paragraph 3 of the Regulation for Enforcement of the ESD Act (hereinafter the "Enforcement Regulation") sets these out as the methods of the external audit.
| Check at the place of business (item 1) | Accompanying the audit (item 2) | |
|---|---|---|
| What is checked | Whether the audits of accepting companies and the other work of the supervising and support organization are being carried out properly | Whether the audits of accepting companies are being carried out properly |
| Frequency | At least once every three months for each place of business where supervising and support services are provided | At least once a year for each place of business where supervising and support services are provided |
| With whom and how | The external auditor receives reports from the officer in charge (責任役員) and the supervising and support manager (監理支援責任者), checks the equipment at the place of business of the supervising and support organization, and inspects the books and documents and other items | The external auditor accompanies the audits that the supervising and support organization conducts of accepting companies (the audits under Article 67, items 1 and 2 of the Enforcement Regulation) |
| Results | Documents stating the results are submitted to the supervising and support organization | Documents stating the results are submitted to the supervising and support organization |
The officer in charge is the officer who is responsible for the supervising and support services. The supervising and support manager is the person in overall charge of the supervising and support services, appointed by the supervising and support organization for each place of business.
Of the audits subject to accompaniment, the audit under Article 67, item 1 is the regular audit that the supervising and support organization conducts of an accepting company (ESD implementing organization, 育成就労実施者). The audit under item 2 of the same Article is the audit that it conducts of the dispatching company (派遣元) and the company receiving the dispatched worker (派遣先) where ESD is carried out in the form of worker dispatching, etc. (労働者派遣等).
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the Act on Proper Implementation of Employment for Skill Development and Protection of Skill Development Employees" (in Japanese; Order of the Ministry of Justice and the Ministry of Health, Labour and Welfare No. 4 of 2025; effective April 1, 2027), Article 42, item 2, Article 47, paragraph 3 and Article 67, items 1 and 2, "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), Article 40, paragraph 1; 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 and Section 16, No. 2)
How to count "at least once every three months" and "at least once a year"
The frequency is counted for each place of business where supervising and support services are provided, not for the supervising and support organization as a whole. This is because the Enforcement Regulation provides "for each place of business" (各事業所につき) for both the check and the accompaniment.
Taking a supervising and support organization with three places of business as an example, the calculation gives at least 12 checks at the places of business and at least 3 accompaniments a year.
For the "at least once a year" of the accompaniment, the Operational Guidelines describe how to count.
- An audit is conducted at least once during the business year (事業年度)
- In addition, the external auditor accompanies an audit at least once within one year counting from the date of the previous accompanied audit (同行監査)
- Example: where the first accompanied audit was conducted on May 10, the second is conducted on or before May 10 of the following year
Both need to be satisfied: conducting it at least once within the business year, and conducting it within one year from the date it was previously conducted. The Operational Guidelines say only "business year" and do not say which year this refers to (as of October 9, 2026).
For the "at least once every three months" of the check at the place of business, neither the Enforcement Regulation nor the Operational Guidelines explain the starting date for counting (as of October 9, 2026). The OTIT's "Frequently Asked Questions" (updated July 10, 2026) do not contain an answer on this point either.
Our office also accepts appointment as an external auditor for Employment for Skill Development, and you can consult us from the stage of planning how the work will be carried out, once we have heard the number of your places of business and the number of accepting companies.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 3; 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); Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; on applications for a supervising and support organization license; updated July 10, 2026)
How the check proceeds, and how the result documents are handled
The supervising and support organization keeps the documents stating the results of the external audit at its place of business, and submits copies to the Organization (機構) once a year. The Organization (機構) here is the Employment for Skill Development Organization (外国人育成就労機構), which will be established to replace the current Organization for Technical Intern Training.
- The external auditor prepares documents stating the results of the check and of the accompaniment respectively, and submits them to the supervising and support organization
- The supervising and support organization keeps those documents, as books and documents, at the place of business where supervising and support services are provided
- The supervising and support organization attaches copies of the documents for the reporting year to its business report, and submits it to the Examination Division of the Head Office (本部事務所の審査課) of the Organization (機構)
| Item | What has been decided |
|---|---|
| Name of the documents | The Operational Guidelines call them the "external audit report" (外部監査報告書) and the "external audit report (accompanied audit)" (外部監査報告書（同行監査）) |
| Form | The Operational Guidelines state that it is "planned to be shown later as a reference form" (追って参考様式として示す予定). It is not posted in the lists of forms of the ISA or the OTIT (as of October 9, 2026) |
| Period for which they are kept | One year counting from the end date of the ESD carried out by the accepting company for which supervising and support is provided |
| Electronic data | They can be prepared and kept as electromagnetic records (electronic data). There is also no objection to the external auditor submitting them to the supervising and support organization electronically |
| Submission of the business report | Prepared for each place of business. For each ESD business year (育成就労事業年度; April 1 to March 31 of the following year), it is submitted on or before May 31 of the following business year |
Books and documents can be received electronically before the on-site check
The Operational Guidelines describe how to handle the case where the books and documents are prepared and kept as electromagnetic records. They state that there is "no objection" (差し支えありません) to having them submitted electronically ahead of the check conducted on site, in order to make the check more efficient.
However, matters such as whether the books and documents are properly kept at the place of business, and whether the materials submitted in advance reflect the actual situation, need to be checked on site.
The supervising and support organization is called on to cooperate with the external audit, and to make improvements in response to the points for improvement raised in the external audit.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 1, item 5, Article 47, paragraph 3, Article 70 and Article 71, "ESD Act" (in Japanese; effective April 1, 2027), Article 41 and Article 42, paragraph 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, Section 18 and Section 19; the list of forms is on the same page), "Overview of the Amended Act (Establishment of the Employment for Skill Development Program, etc.)" (in Japanese); Organization for Technical Intern Training, "List of Forms for the Employment for Skill Development Program" (in Japanese)
How this differs from the supervising and support organization's own audits
The audit by the supervising and support organization covers accepting companies, while the external audit covers the work of the supervising and support organization.
| Audit by the supervising and support organization (regular audit) | External audit | |
|---|---|---|
| Basis | Article 67, item 1 of the Enforcement Regulation | Article 47, paragraph 3 of the Enforcement Regulation |
| Who conducts it | Officers and employees of the supervising and support organization, under the direction of the supervising and support manager | The external auditor |
| Subject | Accepting companies | The supervising and support organization |
| What is checked | Whether ESD is being carried out in accordance with the accredited ESD Plan (認定育成就労計画), whether there is any violation of the laws and regulations on immigration or labor, and so on | Whether the audits of accepting companies and the other work of the supervising and support organization are being carried out properly |
| Frequency | At least once every three months for an accepting company | For each place of business, a check at least once every three months and accompaniment at least once a year |
| Where the results are submitted | The audit report (Appended Form No. 23) is submitted to the Guidance Division of the regional office or branch office of the Organization (機構) that has jurisdiction over the address of the accepting company | The documents stating the results are submitted to the supervising and support organization |
| Deadline for submission | Within two months counting from the date the audit was conducted | Neither the Enforcement Regulation nor the Operational Guidelines set a deadline |
The regular audit is conducted by the following five methods.
- Check the status of implementation of ESD on site
- Receive reports from the ESD manager (育成就労責任者) and the ESD instructor (育成就労指導員)
- Interview one-fourth or more of the Skill Development Employees (育成就労外国人; foreign nationals accepted under the ESD Program) (two or more where there are two to four of them)
- Check the equipment at the accepting company's place of business and inspect the books and documents and other items
- Check the accommodation and other living environment of the Skill Development Employees
Where a different method is prescribed by public notice for a specific field, that method is used. Where, owing to the nature of the work, any of the five methods is extremely difficult, another appropriate method is used in place of that method.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 3, Article 67, item 1 and Article 71, paragraph 1, "ESD Act" (in Japanese; effective April 1, 2027), Article 42, paragraph 1; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program, revised August 2026, Chapter 5, Section 15, Section 16, No. 2 and Section 19)
Work the external auditor does not perform
The audit of accepting companies is work performed by the officers and employees of the supervising and support organization, and is not something the external auditor performs in their place.
The Operational Guidelines explain that the external auditor "is not an officer or employee of the supervising and support organization, and does not engage in audits or other work performed by the supervising and support organization" (監理支援機関の役職員ではなく、監理支援機関が行う監査等の業務に従事することがない). They also state that audits are the core work of the supervising and support services and cannot be outsourced.
What may be outsourced is work that is no more than that of an assistant, such as interpreting at interviews. They also state that, for audits conducted in excess of the frequency of once every three months required by the Enforcement Regulation, the audit work for the excess portion can be outsourced.
| Work the supervising and support organization performs itself | Frequency and deadline | Basis |
|---|---|---|
| Regular audit | At least once every three months for an accepting company | Article 67, item 1 of the Enforcement Regulation |
| Extraordinary audit | Immediately, when it finds that an accepting company is suspected of falling under any of the grounds for revocation of accreditation of an ESD Plan | Item 3 of the same Article |
| Visiting guidance (訪問指導) | At least once a month. It becomes mandatory where there is a foreign national whose total period as a subject of ESD is one year or less | Item 4 of the same Article |
| Submission of the audit report | Within two months from the date the audit was conducted. For an extraordinary audit conducted after obtaining information that gives rise to suspicion of an act infringing human rights, the outline is communicated immediately by telephone or other means, and within two weeks after the audit at the latest | Article 42, paragraph 1 of the ESD Act; Operational Guidelines |
| Submission of the business report | On or before May 31 of the following ESD business year | Article 42, paragraph 2 of the ESD Act; Article 71, paragraph 2 of the Enforcement Regulation |
Visiting guidance is where officers and employees of the supervising and support organization go to the accepting company, check the status of implementation of ESD on site, and provide the necessary guidance.
What Article 47, paragraph 3 of the Enforcement Regulation lists as subject to accompaniment are the audits under Article 67, items 1 and 2. The visiting guidance under item 4 is not listed.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 3, Article 67 and Article 71, "ESD Act" (in Japanese; effective April 1, 2027), Article 42; 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, Section 15, Section 16, No. 2 and Section 19)
How this differs from the work of the external auditor under the Technical Intern Training Program
The frequency and method of the check and the accompaniment are the same as under the Technical Intern Training Program; what differs is the audits that are subject to accompaniment and the scope within which copies of the documents are attached.
| Technical Intern Training Program (supervising organization, 監理団体) | Employment for Skill Development Program (supervising and support organization) | |
|---|---|---|
| Check at the place of business | At least once every three months for each place of business. The external auditor receives reports from the officer in charge and the supervision manager (監理責任者), checks the equipment of the place of business, and inspects the books and documents and other items | At least once every three months for each place of business. The external auditor receives reports from the officer in charge and the supervising and support manager, checks the equipment of the place of business, and inspects the books and documents and other items |
| Accompanying the audit | At least once a year for each place of business. The subject is the audit under Article 52, item 1 of the Regulation for Enforcement of the Technical Intern Training Act | At least once a year for each place of business. The subject is the audit under Article 67, item 1 or item 2 of the Enforcement Regulation |
| Where the result documents are submitted | The supervising organization | The supervising and support organization |
| Period for which the documents are kept | One year from the day the technical intern training ends | One year counting from the end date of the ESD |
| Organizations that attach copies to the business report | Supervising organizations that have an external audit arrangement in place | Supervising and support organizations (there is no limitation) |
The Technical Intern Training Program column shows the content of the Regulation for Enforcement of the Technical Intern Training Act in effect as of October 9, 2026. The Employment for Skill Development Program column shows the content of the Enforcement Regulation that comes into effect on April 1, 2027.
Article 67, item 2 of the Enforcement Regulation provides for the audits of the dispatching company and the company receiving the dispatched worker for ESD carried out in the form of worker dispatching, etc. Article 52 of the Regulation for Enforcement of the Technical Intern Training Act has no item corresponding to this.
Under the Technical Intern Training Program, there is also a method in which a supervising organization that does not have an external audit arrangement in place has a person designated from among its officers (designated external officer, 指定外部役員) take charge of the check. The documents in which a designated external officer states the results of the check are not listed among the documents to be attached to the business report.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the Act on Proper Technical Intern Training and Protection of Technical Intern Trainees" (in Japanese; Order of the Ministry of Justice and the Ministry of Health, Labour and Welfare No. 3 of 2016; currently in effect), Articles 30, 52, 54 and 55, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 3, Articles 67, 70 and 71
Frequently Asked Questions
Does the external auditor accompany the audits of all accepting companies?
It is not necessary to accompany the audits of all accepting companies. The OTIT answers that accompaniment at least once a year for each place of business is required, but that this does not mean the external auditor must accompany the audits of all accepting companies under the organization.
Does the external auditor also have the role of a contact point for reports from Skill Development Employees?
The Operational Guidelines state that it is also "desirable" (望まれます) for the external auditor to serve as an external reporting contact point for Skill Development Employees. This is not included in the methods of the external audit set out in Article 47, paragraph 3 of the Enforcement Regulation.
The written request of a foreign national who wishes to change employer (転籍; a change of the ESD implementing organization) can also be submitted through the external auditor, etc.
When the license of a supervising and support organization is revoked, is the external audit also publicly announced?
Where the external audit was being conducted properly, the Organization (機構) is to publicly announce that fact. This is what the Operational Guidelines state about a supervising and support organization whose license has been revoked.
Source: Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; on applications for a supervising and support organization license; updated July 10, 2026), 7-16; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program, revised August 2026, Chapter 4, Section 3, Chapter 5, Section 2, No. 5 and Section 14)
Summary
The work of the external auditor is a check at least once every three months for each place of business of the supervising and support organization, and accompanying an audit at least once a year. The documents stating the results are submitted to the supervising and support organization. The supervising and support organization keeps those documents at the place of business and attaches copies to its business report.
The regular audits and extraordinary audits of accepting companies and the visiting guidance are work that the supervising and support organization performs itself. Organizations that are going to apply for a supervising and support organization license should confirm the number of places of business where supervising and support services are provided, and count the number of checks and accompaniments. Those who take on the role of external auditor first confirm whether that number can be carried out on site.
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 25, 38, 40, 41 and 42
- 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 1, 42, 47, 67, 70 and 71
- Regulation for Enforcement of the Act on Proper Technical Intern Training and Protection of Technical Intern Trainees (Order of the Ministry of Justice and the Ministry of Health, Labour and Welfare No. 3 of 2016; currently in effect), Articles 30, 52, 54 and 55
- Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; Operational Guidelines for the Employment for Skill Development Program; revised August 5, 2026), Chapters 4 and 5
- Immigration Services Agency of Japan, "Overview of the Amended Act (Establishment of the Employment for Skill Development Program, etc.)" (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)
- Organization for Technical Intern Training, "List of Forms for the Employment for Skill Development Program" (in Japanese)
