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.
A person can become an external auditor (外部監査人) under Japan's Employment for Skill Development (ESD, 育成就労) if the person meets the training-course and qualification requirements, does not have certain relationships with the accepting companies, the supervising and support organization (監理支援機関) and others, and has consented to the publication of their name. An attorney (弁護士), Sharoushi (labor and social security attorney; 社会保険労務士) or Gyoseishoshi (administrative scrivener; 行政書士) who has an advisory (retainer) contract (顧問契約) with the supervising and support organization can become one, provided that they conform to the requirements and do not fall under the grounds for disqualification (欠格事由).
Where the advisory client is an accepting company to which the organization provides supervising and support, the Operational Guidelines (運用要領) list this as an example of a "close relationship". For the case where that company is a member (構成員) of the supervising and support organization, the Organization (機構) has answered that the person cannot become an external auditor. Below, we explain how each situation is treated, following Article 47 of the Regulation for Enforcement of the ESD Act (育成就労法施行規則), which will come into effect on April 1, 2027, and the materials published by the ISA and the Organization for Technical Intern Training.
Contents
- Who can become an external auditor: a person who meets all four requirements
- Persons who cannot become an external auditor because of their relationship with an accepting company
- Persons who cannot become an external auditor because of their relationship with the supervising and support organization and others
- Persons who fall under the grounds for disqualification cannot become one either
- After how many years can a person become an external auditor?
- Can you ask a licensed professional with whom there is an advisory contract or business dealings?
- Can you ask a former officer or employee, a relative or a member?
- Situations for which the published materials give no answer
- Training course, qualification, corporations and publication of the name
- Documents submitted with the application
- When the requirements are no longer met after assuming the position
- Frequently Asked Questions
- Summary
- References
Who can become an external auditor: a person who meets all four requirements
A person who can become an external auditor is one who meets all four requirements: the training course, qualification or expertise, relationships and grounds for disqualification, and consent to the publication of their name. The Operational Guidelines state that these requirements need to be met throughout, from the time of applying for the license and for as long as the license is held.
An external auditor is a person who audits, from outside the corporation, whether the audits and other operations of a supervising and support organization are being carried out properly. A supervising and support organization is the body that replaces the supervising organization (監理団体) of the Technical Intern Training Program (技能実習制度), and having an external auditor conduct audits is one of the criteria for its license (ESD Act (育成就労法), Article 25, paragraph 1, item 5).
The definition and the reason it became mandatory are summarized in What is an external auditor under Employment for Skill Development?, and the content of the work in What does an external auditor under Employment for Skill Development do?.
This article deals with the third requirement, "relationships and grounds for disqualification". The basis is Article 47, paragraph 1 and paragraph 2, item 3 of the Regulation for Enforcement of the ESD Act (hereinafter "the Regulation for Enforcement"). In the provisions, an accepting company is written as an "ESD implementing organization" (育成就労実施者).
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), Article 25, paragraph 1, item 5, "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), Article 47; 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)
Persons who cannot become an external auditor because of their relationship with an accepting company
A person who has a "close relationship" with an accepting company to which the organization provides supervising and support cannot become an external auditor even if they hold a qualification. Article 47, paragraph 1 of the Regulation for Enforcement sets the scope in three items. The "applicant" in the table is the supervising and support organization applying for the license.
| Item | Persons who cannot become an external auditor (wording of the provision) | Period and scope |
|---|---|---|
| Item 1 | An organization implementing supervising-organization-type ESD (監理型育成就労実施者) to which the applicant provides supervising and support, its officers and employees, and persons who were any of these within the past five years | Includes an organization implementing supervising-organization-type ESD to which the applicant provided supervising and support within the past five years |
| Item 2 | The spouse or a relative within the second degree of kinship of a person prescribed in item 1 | Spouse; relatives within the second degree of kinship |
| Item 3 | A person who has a close relationship in social life and who is found to pose a risk that the fairness of the external audit will be impaired | No number of years is set |
"Within the past five years" in item 1 applies in two places. It covers persons who were officers or employees, within the past five years, of an accepting company to which the applicant currently provides supervising and support, and persons connected with an accepting company to which the applicant provided supervising and support within the past five years.
- An attorney who has an advisory contract with an ESD implementing organization to which the supervising and support organization provides supervising and support
- A corporation that receives payment of membership fees, on a regular or occasional basis, from an ESD implementing organization to which the supervising and support organization provides supervising and support
The Operational Guidelines use the words "for example" (例えば) and "and the like are conceivable" (などが考えられます). The wording does not limit the cases to these two.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 1; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Section 2, No. 5)
Persons who cannot become an external auditor because of their relationship with the supervising and support organization and others
Who cannot become an external auditor is also determined by relationships with the supervising and support organization, its members, other accepting companies, other supervising and support organizations, and foreign sending organizations (送出機関). These are sub-items (a) through (e) (イ through ホ) and sub-item (h) (チ) of Article 47, paragraph 2, item 3 of the Regulation for Enforcement.
| Sub-item | Persons who cannot become an external auditor (wording of the provision) | "Persons who were any of these within the past five years" |
|---|---|---|
| (a) イ | An officer or employee of the applicant | Included |
| (b) ロ | A member of the applicant (limited to a member engaged in a business involving work that requires skills belonging to the ESD industrial field of the supervising-organization-type ESD for which supervising and support is provided), or an officer or employee of that member | Included |
| (c) ハ | An ESD implementing organization (excluding an organization implementing supervising-organization-type ESD to which supervising and support is provided), or its officer or employee | No such provision |
| (d) ニ | A supervising and support organization (excluding the applicant), or its officer or employee | No such provision |
| (e) ホ | A foreign sending organization that acts as an intermediary to the applicant for applications for supervising-organization-type ESD, or its officer or employee | Included |
| (h) チ | In addition to (a) through (g) (イ through ト), a person who is found to pose a risk that the fairness of the external audit will be impaired because the person has a close relationship in social life with the applicant or its officers, employees or members, because the person has in the past committed a wrongful or significantly unjustifiable act in relation to ESD, or because of other circumstances | No such provision |
Members are, for example, members of a cooperative (組合員) or members of an association (会員). As for members that do not fall within the parentheses in (b) (ロ) and their officers and employees, the Operational Guidelines also state that they "are not accepted, because there is a risk that the fairness of the external audit will be impaired" (外部監査の公正が害されるおそれがあるため、認められません).
- 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 payment of membership fees, on a regular or occasional basis, from the supervising and support organization
The Operational Guidelines go on to state that attorneys, etc. (弁護士等) who have an advisory contract with the supervising and support organization do 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 2, item 3; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Section 2, No. 5)
Persons who fall under the grounds for disqualification cannot become one either
Persons and corporations that fall under the grounds for disqualification for a supervising and support organization license (ESD Act, Article 26) also cannot become external auditors. These are sub-items (f) and (g) (ヘ and ト) of Article 47, paragraph 2, item 3 of the Regulation for Enforcement.
| Sub-item | Persons who cannot become an external auditor (wording of the provision) |
|---|---|
| (f) ヘ | A person who falls under any of sub-items (a) through (d) (イ through ニ) of Article 26, item 5 of the ESD Act |
| (g) ト | A corporation that falls under any of the items of Article 26 of the same Act, or that has among its officers a person who falls under any of (a) through (e) (イ through ホ) |
"(a) through (e) (イ through ホ)" in (g) (ト) means (a) through (e) in the table in the preceding section. Where a corporation is to become the external auditor, these relationships are checked for each of its officers individually.
- A person who has been sentenced to imprisonment (拘禁刑) or a heavier punishment, and for whom five years have not yet passed since the completion of the sentence or since the day on which the person ceased to be subject to the sentence
- A person who has been sentenced to a fine under, among others, the provisions specified by Cabinet Order of the ESD Act or other laws relating to immigration or labor, and for whom five years have likewise not yet passed
- A member of an organized crime group, or a person for whom five years have not yet passed since the day on which the person ceased to be a member of an organized crime group
- A person for whom five years have not yet passed since the day on which the person committed a wrongful or significantly unjustifiable act in relation to the laws and regulations on immigration or labor
- A person who was an officer of a supervising and support organization whose license was revoked, at the time the matter that caused the revocation occurred, and for whom five years have not yet passed since the date of the revocation (for a revocation under Article 37, paragraph 1, item 2, limited to the cases specified in the same Act)
The box lists only some of them. In addition, there are, among others, persons who have received an order to commence bankruptcy proceedings and have not yet had their rights restored, grounds relating to mental or physical disorder, fines for specified offenses, and grounds relating to the notification of discontinuation of the business.
Source: e-Gov Laws and Regulations Search, "ESD Act" (in Japanese; effective April 1, 2027), Articles 10 and 26, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 2, item 3; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Section 2, No. 5)
After how many years can a person become an external auditor?
For a relationship to which the "within the past five years" provision applies, once more than five years have passed since the person left that position, the person no longer falls under that item. The provision applies to relationships with an accepting company to which supervising and support is provided, with the supervising and support organization, with a member engaged in a business in a field for which supervising and support is provided, and with a sending organization that acts as an intermediary to the organization.
For other accepting companies and other supervising and support organizations ((c) ハ and (d) ニ), there is no "within the past five years" provision. For a close relationship in social life (paragraph 1, item 3, and paragraph 2, item 3 (h) チ), no number of years is set either.
The Organization for Technical Intern Training (外国人技能実習機構; hereinafter "OTIT") has given an answer concerning a person who was an officer of a supervising and support organization. OTIT will become the Employment for Skill Development Organization (ESDO, 外国人育成就労機構) on April 1, 2027. If, at the time of the application, more than five years have passed since the person left the position, and the person conforms to the other requirements and does not fall under the grounds for disqualification, the person can become an external auditor.
As for a member that is not engaged in a business in the field, according to OTIT's answer, the member and persons who are its officers or employees cannot become external auditors. Persons who were officers or employees within the past five years are added in the case of a member that is engaged in a business in the field.
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; Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; concerning applications for a supervising and support organization license; updated July 10, 2026), 7-7 and 7-9
Can you ask a licensed professional with whom there is an advisory contract or business dealings?
An advisory contract is treated differently depending on whether the other party is the supervising and support organization or an accepting company to which it provides supervising and support. For the following situations, the answers are found in the Operational Guidelines and OTIT's Frequently Asked Questions.
| Situation | Answer of the ISA or OTIT | Basis |
|---|---|---|
| An attorney, Sharoushi or Gyoseishoshi (including the respective corporations) who has an advisory contract with the supervising and support organization | Can become an external auditor, provided that they conform to the requirements and do not fall under the grounds for disqualification | OTIT 7-2; Operational Guidelines |
| An attorney who has an advisory contract with an accepting company to which supervising and support is provided | Listed as an example of a "close relationship" that poses a risk that the fairness of the external audit will be impaired (Regulation for Enforcement, Article 47, paragraph 1, item 3) | Operational Guidelines |
| Attorneys, etc. who have an advisory contract with a member of the supervising and support organization (where the member is an accepting company to which supervising and support is provided) | Cannot become an external auditor | OTIT 7-3 |
| Attorneys, etc. who have an advisory contract with a member of the supervising and support organization (where the member is not an accepting company to which supervising and support is provided) | Can become an external auditor, provided that they conform to the requirements and do not fall under the grounds for disqualification | OTIT 7-4 |
| A Sharoushi whom the supervising and support organization engages, for a fee, as the instructor for the legal protection subjects (法的保護科目) of the post-entry lectures (入国後講習) | Can become an external auditor, provided that they conform to the requirements and do not fall under the grounds for disqualification | OTIT 7-14 |
| A Gyoseishoshi who is the lessor of the supervising and support organization's office | Can become an external auditor, provided that they conform to the requirements and do not fall under the grounds for disqualification | OTIT 7-15 |
| A person who concurrently serves as the external auditor of another supervising and support organization (including a supervising organization) | Can serve concurrently, provided that they conform to the requirements and do not fall under the grounds for disqualification | OTIT 7-6 |
"Attorneys, etc." (弁護士等) means attorneys, Sharoushi, Gyoseishoshi and their corporations. When asking a retained licensed professional (士業; a professional such as an attorney, Sharoushi or Gyoseishoshi), first check whether that person's advisory clients include an accepting company to which supervising and support is provided.
Source: Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; updated July 10, 2026), 7-2, 7-3, 7-4, 7-6, 7-14 and 7-15; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Section 2, No. 5)
Can you ask a former officer or employee, a relative or a member?
A person who was an officer or employee of the supervising and support organization cannot become an external auditor if that was within the past five years. The treatment of relatives and members is also determined by the provisions and OTIT's answers.
| Situation | Answer of the ISA or OTIT | Basis |
|---|---|---|
| A person who was an officer of the supervising and support organization | Can become an external auditor if, at the time of the application, more than five years have passed since leaving the position, and the person conforms to the other requirements and does not fall under the grounds for disqualification | Regulation for Enforcement, Article 47, paragraph 2, item 3 (a) (イ); OTIT 7-7 |
| A person who, before April 1, 2027, was a part-time designated external officer (指定外部役員) of a supervising organization (and was not involved in the work of the supervising business, such as regular audits) | Can become an external auditor even within five years of leaving the position, provided that the person conforms to the other requirements and does not fall under the grounds for disqualification | Article 5 of the Supplementary Provisions of the Regulation for Enforcement; OTIT 7-7 |
| The spouse or a relative within the second degree of kinship of the representative of the supervising and support organization | Cannot become an external auditor | OTIT 7-12 |
| The spouse or a relative within the second degree of kinship of an officer or employee of an accepting company to which supervising and support is provided (including a person who was any of these within the past five years) | Cannot become an external auditor | Regulation for Enforcement, Article 47, paragraph 1, item 2 |
| A Gyoseishoshi corporation (行政書士法人) that is a member of the supervising and support organization, and a Gyoseishoshi who is an officer or employee of that corporation | Cannot become an external auditor | OTIT 7-9 |
| A person who is an officer or employee of another supervising and support organization | Cannot become an external auditor | Regulation for Enforcement, Article 47, paragraph 2, item 3 (d) (ニ); OTIT 7-8 |
A designated external officer is an officer that a supervising organization under the Technical Intern Training Program designates when it does not put an external audit arrangement in place. What ceases to apply under Article 5 of the Supplementary Provisions is only paragraph 2, item 3 (a) (イ).
The spouses and relatives within the second degree of kinship of officers and employees other than the representative are listed by the Operational Guidelines as an example of 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 and Article 5 of the Supplementary Provisions; Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; updated July 10, 2026), 7-7, 7-8, 7-9 and 7-12; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Section 2, No. 5)
Situations for which the published materials give no answer
For the following situations, there is no direct answer in the Regulation for Enforcement, the Operational Guidelines or OTIT's Frequently Asked Questions (as of October 9, 2026). As to whether a person is found to pose a risk that the fairness of the external audit will be impaired (Regulation for Enforcement, Article 47, paragraph 1, item 3, and paragraph 2, item 3 (h) チ), the published materials do not show a standard for how far this extends.
| Situation | What can be confirmed from the provisions and published materials | Our office's reading (not the view of the authorities) |
|---|---|---|
| A Gyoseishoshi who prepared the documents for the supervising and support organization's license application | Article 47 has no item that lists the preparation of documents. OTIT states that the submission of the application form and the receipt of the license certificate, etc. may be delegated to a third party such as a Gyoseishoshi | We do not find any item that applies solely because the person prepared the documents. Whether (h) (チ) applies depends on how the person was involved |
| A licensed professional who received one-off work, not under an advisory contract, from an accepting company to which supervising and support is provided | What the Operational Guidelines list as examples of paragraph 1, item 3 are an attorney who has an advisory contract and a corporation that receives payment of membership fees. They say "and the like" (など) | It cannot be said definitively that the person can become an external auditor on the ground that the case is not among the examples. We check the content and timing of the work received |
| A licensed professional who had an advisory contract in the past with an accepting company to which supervising and support is provided | "Within the past five years" in paragraph 1, item 1 is a provision concerning accepting companies and their officers and employees. Item 3 sets no number of years | It cannot be said definitively that item 3 does not apply solely because the contract has ended |
| An officer or employee of a registered support organization (登録支援機関; under the Specified Skilled Worker (特定技能) system), or a licensed professional that is a registered support organization | Article 47, the Operational Guidelines and OTIT's answers contain no statement that mentions registered support organizations in connection with the requirements for external auditors. Where that person or corporation is also another accepting company or another supervising and support organization, or an officer or employee of either, (c) (ハ) or (d) (ニ) applies | We were not able to confirm any provision under which a person cannot become an external auditor on the ground of being a registered support organization. If the party entrusting the support is an accepting company to which supervising and support is provided, we check the relationship with paragraph 1, item 3 |
"Our office's reading" is limited to what we have read from the provisions and the published materials, and is not the view of the ISA or OTIT.
Our office also accepts appointments as external auditor under Employment for Skill Development, and we begin by checking whether independence can be secured. Our representative Gyoseishoshi (Takuro Hidaka) has completed the training course for supervision managers, etc. (監理責任者等講習) under the Technical Intern Training Program. Under a transitional measure, a person who has completed this course is deemed to have completed the training course for external auditors.
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; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Section 2, No. 5); Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; updated July 10, 2026), 16-1
Training course, qualification, corporations and publication of the name
A person who does not fall under the relationship requirements also needs to separately meet the training-course and qualification requirements.
| Item | What has been decided | Basis |
|---|---|---|
| Training course | Has completed, within the past three years, the training course for external auditors specified in a public notice by the Minister of Justice and the Minister of Health, Labour and Welfare | Regulation for Enforcement, Article 47, paragraph 2, item 1 |
| Transitional measure for the training course | For the time being, a person who has completed the training course for supervision managers, etc. under the Technical Intern Training Program is also deemed to have completed it | Article 4, paragraph 3 of the Supplementary Provisions of the Regulation for Enforcement; Operational Guidelines, Chapter 8 |
| Training courses under the ESD Program | The Operational Guidelines state that the call for training course providers (養成講習機関) for fiscal year 2026 is planned to be held from December 1 to December 28, 2026, and that training course providers may begin recruiting participants after the public notice is issued (as of October 9, 2026) | Operational Guidelines, Chapter 8 |
| Qualification or expertise | Is an attorney, Sharoushi or Gyoseishoshi (including the respective corporations) or another person with expertise in Employment for Skill Development | Regulation for Enforcement, Article 47, paragraph 2, item 2 |
| Where a corporation becomes 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) takes the training course. More than one such person may be appointed from among the corporation's officers and employees | Operational Guidelines; OTIT 7-20 |
| Publication of the name | Has consented to the Organization (機構) publishing the name on the internet. What is published is the personal name for an individual and the corporate name for a corporation | Regulation for Enforcement, Article 47, paragraph 2, item 4; OTIT 7-19 |
The Operational Guidelines state that, even after being appointed, the person needs to take and complete the next training course within three years from the date on which the course was completed.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 47, paragraph 2 and Article 4, paragraph 3 of the Supplementary Provisions; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Section 2, No. 5, and Chapter 8); Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; updated July 10, 2026), 7-19 and 7-20
Documents submitted with the application
The external auditor pledges, in the letter of acceptance of appointment and written pledge, as to the requirements of Article 47 of the Regulation for Enforcement. The supervising and support organization applying for the license submits it to the Organization (機構), attached to the application form.
| Document | Details |
|---|---|
| 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) | A document attached to the license application form (Regulation for Enforcement, Article 43, paragraph 1, item 9). In the case of a corporation, the names of the persons responsible for conducting the audit who have taken the training course are also entered |
| Copy of the certificate of attendance (受講証明書) for the training course for external auditors | For a course taken within the past three years as of the time of the application. In the case of a corporation, for all of the persons responsible for conducting the audit. Also submitted when applying for renewal of the period of validity of the license |
The pledge items in Reference Form No. 2-5 include the following sentence.
I understand that if, in the future, I cease to fall under either paragraph 1 or paragraph 2 of the same Article, I must immediately report this to the above applicant and resign from the position of external auditor, and a properly appointed person must newly assume the same position. (今後、同条第１項及び第２項のいずれかに該当しなくなったときは、直ちに上記申請者に申告するとともに、外部監査人の地位を退き、適切に選任された者が新たに同役職に就任しなければならないことを理解しています。)
In substance, if the requirements are no longer met, the external auditor immediately reports this to the supervising and support organization and steps down, and a new external auditor assumes the position. The pledge items also include consent to the Organization (機構) publishing the name.
The profile has fields for entering the person's history of involvement in Employment for Skill Development and their relationships with supervising and support organizations other than the applicant.
Source: e-Gov Laws and Regulations Search, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 43, paragraph 1, item 9; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Section 2, No. 5, and the appended list of attached documents; Reference Form No. 2-5 is on the same page); Organization for Technical Intern Training, the list of application documents posted on "Application for a supervising and support organization license prior to the enforcement date" (in Japanese; updated October 8, 2026)
When the requirements are no longer met after assuming the position
When the external auditor no longer meets the requirements, a new external auditor is selected and the supervising and support organization gives notification of the change. The personal name or corporate name of the external auditor is a matter stated in the license application form (Regulation for Enforcement, Article 42, item 3).
| Timing | Procedure |
|---|---|
| After the license is granted | Within one month from the date of the change, the supervising and support organization submits a notification of change (変更届出書; Appended Form No. 20) to the Examination Division of the Head Office of the Organization (機構) |
| After filing an application prior to the enforcement date (施行日前申請) and before the license is granted | Where a new external auditor is to be appointed, a written request for change (変更申出書) is submitted to OTIT, together with Reference Form No. 2-5 and a copy of the certificate of attendance for a course taken within the three years before the date of the request |
Changes that have no substantial effect on the implementation of the supervising and support services are excluded from those subject to notification (Regulation for Enforcement, Article 61). A list of which changes fall under this has not yet been shown in the Operational Guidelines. The Operational Guidelines also state that the materials to be attached to a notification of change "will be shown later in these Guidelines" (追って本要領においてお示しします) (as of October 9, 2026).
The written request for change is handled only for requests that reach OTIT on or before December 28, 2026. If it is not submitted by the deadline, the application is examined based on its content before the change. Where the license is granted, the notification of change is made on or after the enforcement date and within one month from the date of the license.
If, after accepting a notification of change, the Organization (機構) confirms that the requirements for the license are not met, it gives guidance to correct this (corrective guidance, 是正指導). The Operational Guidelines state that, if it is not corrected, this may lead to an order for improvement, revocation of the license or the like.
The external audit arrangement is one of the licensing criteria. When the competent ministers find that the organization no longer conforms to any of the licensing criteria, they may revoke the license. They may also order the suspension of all or part of the business for a specified period (ESD Act, Article 37, paragraph 1, item 1, and paragraph 2).
Source: e-Gov Laws and Regulations Search, "ESD Act" (in Japanese; effective April 1, 2027), Articles 32 and 37, "Regulation for Enforcement of the ESD Act" (in Japanese; effective April 1, 2027), Article 42, item 3, Article 61 and Article 62; Immigration Services Agency of Japan, "Operational Guidelines" (in Japanese; revised August 2026, Chapter 5, Sections 9 and 14); Organization for Technical Intern Training, "List of Materials to Be Submitted When Making a Request for Change to the Matters Stated in the Application for License of Supervising and Support Organization" posted on "Application for a supervising and support organization license prior to the enforcement date" (in Japanese; updated October 8, 2026)
Frequently Asked Questions
Can an auditor (監事; an internal officer who audits the corporation) who is qualified as a Gyoseishoshi become an external auditor?
No. OTIT has answered that, because the auditor (監事) of a supervising and support organization is an officer, such a person cannot become an external auditor, regardless of whether or not they are a Gyoseishoshi and whether or not they are a member of the cooperative (組合員).
Can a person who has passed the examination but has not registered become an external auditor?
No. OTIT has answered that a person who is not registered as an attorney, Gyoseishoshi or Sharoushi cannot become an external auditor.
If it has employees qualified as Gyoseishoshi or the like, can an ordinary corporation also become an external auditor?
Not merely because it has qualified employees. OTIT has given an answer concerning corporations other than qualified-professional corporations such as attorney corporations (弁護士法人等の有資格法人以外の法人). Such a corporation needs to be an organization designated by public notice as a provider of the training course for external auditors, and one with a considerable track record.
Source: Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; updated July 10, 2026), 7-11, 7-13 and 7-21
Summary
Whether a person can become an external auditor is determined by, in addition to the training course and qualification, relationships with accepting companies, the supervising and support organization, its members, other accepting companies and supervising and support organizations, and sending organizations. An advisory contract with the supervising and support organization is not automatically an obstacle. Where the advisory client is an accepting company to which supervising and support is provided, the Operational Guidelines list this as an example of a "close relationship". For the case where that company is a member, OTIT has answered that the person cannot become an external auditor.
Before deciding on a candidate, please prepare a list of the accepting companies to which supervising and support is provided and of the members. Check the candidate's history of positions held (past five years), spouse and relatives within the second degree of kinship, and advisory clients against that list. When a relationship for which the published materials give no answer is found, make the decision after checking specifically how the person is involved.
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 10, 25, 26, 32 and 37
- 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, 47, 61 and 62, 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 5, 2026), Chapters 5 and 8, Reference Form No. 2-5
- Organization for Technical Intern Training, "Frequently Asked Questions" (in Japanese; concerning applications for a supervising and support organization license; updated July 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)
