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The Immigration Services Agency announced on July 28, 2026 (Reiwa 8), the “Revision of Requirements for the Support System for Specified Skilled Worker (i) (to be enforced on April 1, 2027 (Reiwa 9))”. The four main pillars are: full-time employment of Support Managers and Support Staff, appointment for each business site, criteria for the number of Support Staff, and training courses for Support Managers.
This revision applies not only to Registered Support Organizations but also to accepting organizations that provide support in-house. In this article, we will delve into the provisions of the ministerial ordinances that form the basis, and organize them from the perspectives of both HR professionals at companies and foreign nationals themselves.
The overall framework of the policy is covered in ” Second Immigration and Residence Management Basic Plan | Key Points of the Revision After 7 Years “. Regarding the item where the plan only announced “tightening the registration requirements for Registered Support Organizations from April 2027,” this article will discuss its specifics.
According to the announcement by the Immigration Services Agency, this revision is being made “to ensure that support for Specified Skilled Worker (i) can be provided more appropriately,” and the following two ministerial ordinances have been revised:
The substance of the revision is Ministry of Justice Ordinance No. 45 (September 30, Reiwa 7), “Ministerial Ordinance on the Establishment of Ministry of Justice Ordinances and Transitional Measures Accompanying the Enforcement of the Act Partially Amending the Immigration Control and Refugee Recognition Act and the Act on Proper Technical Intern Training for Foreigners and Protection of Technical Intern Trainees.” Article 1 of the supplementary provisions of the said ordinance stipulates that the enforcement date is April 1, 2027 (Reiwa 9), the enforcement date of the revised act.
| Stage | Content |
|---|---|
| Law | Act Partially Amending the Immigration Control and Refugee Recognition Act and the Act on Proper Technical Intern Training for Foreigners and Protection of Technical Intern Trainees (Act No. 60 of Reiwa 6) |
| Ministerial Ordinance | Ministry of Justice Ordinance No. 45 (September 30, Reiwa 7) |
| Announcement | July 28, 2026, “Revision of Requirements for the Support System for Specified Skilled Worker (i)” |
| Enforcement | April 1, 2027 (Reiwa 9) |
April 1, 2027, is also the start date of the Employment for Skill Development (ESD; Japanese: Ikusei Shuro) Program. While this date is often mentioned as the start of a new system, the standards for the accepting side’s Support System will also be raised on the same day.
The Immigration Services Agency has organized the main points of revision regarding the necessary support system into the following four:
Of the four points, ① and ② define “who provides support,” ③ defines “how to ensure the competence of that person,” and ④ defines “how many individuals one person can oversee.” This revision can be interpreted as concretizing the Support System from both the aspects of personnel numbers and qualifications.
Reading the comparative provisions of the old and new ministerial ordinances, the changes are quite clear. Before the revision, Support Managers only needed to be selected “from among officers or employees,” with no restriction on being per business site or full-time. After the revision, it is required to appoint at least one Support Manager per business site (office) from among full-time officers or employees.
| Item | Before Revision | After Revision (from April 1, 2027) |
|---|---|---|
| Employment Type of Support Manager | Officer or Employee | Full-time Officer or Employee |
| Appointment Unit for Support Manager | Sufficient at the corporate/organizational level | At least one per business site (office) |
| Employment Type of Support Staff | Officer or Employee | Full-time Officer or Employee |
| Appointment Unit for Support Staff | At least one per business site (office) | At least one per business site (office) (criteria for number of staff added) |
| Criteria for the Number of Support Staff | No provision | Exceeding the criteria of 50 individuals / 10 organizations |
| Training for Support Managers | No provision | Completion of training within the past 3 years (grace period for the time being) |
| Persons Permitted to Engage in Support Activities | — | Limited to Support Managers, etc. |
For companies accepting foreign nationals at multiple locations, or Registered Support Organizations providing support services at multiple offices, the change to a “per business site” system is the most significant in practical terms. A system where one person at the head office was sufficient may no longer meet the standards after April 2027.
In the revised provisions, a Support Manager is defined as a person responsible for comprehensively managing the following matters. There are 6 items for accepting organizations that provide their own support, and 5 items for Registered Support Organizations, with the difference being whether the creation of a support plan is included (as creation is the role of the accepting organization).
📋 Matters to be comprehensively managed by the Support Manager of an accepting organization providing its own support (6 items)
For Support Managers of Registered Support Organizations, 5 items, excluding item 1 (creation of the support plan) from the above, are designated as matters for comprehensive management.
The revised Ordinance for Enforcement of the Immigration Control Act defines a Support Manager as a person who has “completed a training course specified by the Minister of Justice in a public notice for persons responsible for implementing support plans within the past three years.” The support ordinance also refers to the same training course.
What is important here are the Transitional Measures. Article 3 of the Supplementary Provisions of Ministry of Justice Ordinance No. 45 stipulates that the part concerning this training course shall be read as not applicable for the time being. The Immigration Services Agency also clearly states, “Even after April 1, 2027, for the time being, it is not problematic if the training course has not been completed.”
⚠️ “For the time being” is a grace period, not an exemption. As long as it is a reinterpretation by supplementary provisions, once the training course is specified in a public notice and the grace period ends, it will become an active requirement. Furthermore, since there is a deadline of “within the past three years,” it is not a one-time completion.
This point is presented in two different ways in the Immigration Services Agency’s materials, which can be confusing for first-time readers.
The wording is different, but the content is the same. The provisions of the ministerial ordinance (Ordinance for Enforcement of the Immigration Control Act) are even more precise, requiring Registered Support Organizations to appoint “at least one support staff member per office conducting support operations, and exceeding the greater of the numbers listed in (a) or (b) below.”
In other words, the required number of personnel is determined by the stricter of the two criteria.
The Immigration Services Agency’s PDF document provides examples such as “3 support staff are required when entrusted by 25 organizations” and “3 support staff are required when supporting 120 Specified Skilled Worker (i).” Applying this approach, the following results are obtained:
| Number of Specified Skilled Worker Accepting Organizations Entrusting Support | Number of Specified Skilled Worker (i) Foreign Nationals Being Supported | Required Number of Support Managers (per office) |
|---|---|---|
| 5 Organizations | 30 people | 1 person |
| 9 Organizations | 49 people | 1 person |
| 10 Organizations | 50 people | 2 people |
| 15 Organizations | 40 people | 2 people |
| 25 Organizations | 100 people | 3 people |
| 20 Organizations | 120 people | 3 people |
| 40 Organizations | 250 people | 6 people |
The provision states “exceeds,” while the PDF document uses “less than.” Therefore, when there are exactly 10 organizations or exactly 50 people, one support manager does not meet the criteria. This means that even with exactly 10 organizations or exactly 50 people, two support managers are required. This is why the numbers jump only for the rows with 10 organizations and 50 people in the table above.
When formulating a business plan, considering “up to 49 people per person” instead of “up to 50 people per person” can help avoid unexpected additional hires.
While “support system requirements” may seem to refer to Registered Support Organizations, they also apply to Specified Skilled Worker Accepting Organizations that provide in-house support. However, the scope of the applicable criteria differs.
🏢 For Registered Support Organizations
🏭 For Accepting Organizations Providing In-house Support
The revised Ministerial Ordinance on Support newly establishes a provision stating that “the number of Support Managers appointed for each business site where foreign nationals engage in activities based on a Specified Skilled Worker employment contract must exceed the number obtained by dividing the number of foreign nationals being supported by 50.” Companies planning to continue in-house support must verify whether this calculation holds true for each base.
Furthermore, the system whereby an accepting organization is deemed to have met the support system criteria if it entrusts the entire support plan to a Registered Support Organization remains unchanged. For an overview of the system, please also refer to “Differences between Specified Skilled Worker (i) and (ii).”
Article 4 of the Supplementary Provisions of Ministry of Justice Ordinance No. 45 stipulates transitional measures in two stages. This is the most crucial part for Registered Support Organizations.
| Status | Treatment |
|---|---|
| Not registered by the enforcement date (those who intend to become Registered Support Organizations) | If an Application for Registration is filed before the enforcement date, the eligibility for registration will be judged based on the requirements prior to the enforcement date. |
| Registered Support Organizations registered before the enforcement date | If the registration period expires by July 31, 2027, renewal can be received under the requirements prior to the enforcement date, but only if an Application for Renewal is filed before the enforcement date. |
| Registration that is to follow previous examples as per the above | Until the expiration date of said registration period, the previous examples shall still apply. |
The third row is the critical point. Article 4, Paragraph 2 of the Supplementary Provisions limits the period during which previous examples can be followed to “until the expiration date of said registration period.” The Immigration Services Agency also explains, “When applying for registration renewal thereafter, renewal cannot be received unless the requirements after the enforcement date are met.”
Registration for Registered Support Organizations is valid for five years and requires an Application for Renewal. Therefore, even if registration or renewal is completed before the enforcement date, the next renewal will be judged under the new requirements. Transitional measures are intended to buy time, not to evade the requirements.
Another easily overlooked premise exists. The Immigration Services Agency advises that if you wish to renew, you should “submit your renewal application from the first day of the month six months prior to the expiration date of your registration’s validity period until the last day of the month four months prior to it.”
In other words, whether or not you can utilize the transitional measures is not a matter of freely choosing when to apply. It is a question of whether you can apply before the enforcement date within the acceptance period automatically determined by the expiration date.
| Registration Validity Expiration Date | Renewal Application Acceptance Period | Can application be submitted before the enforcement date (April 1, 2027)? |
|---|---|---|
| April 30, 2027 | October 1, 2026 – December 31, 2026 | Yes |
| May 31, 2027 | November 1, 2026 – January 31, 2027 | Yes |
| June 30, 2027 | December 1, 2026 – February 28, 2027 | Yes |
| July 31, 2027 | January 1, 2027 – March 31, 2027 | Yes (The last day of acceptance is the day before the enforcement date) |
| August 31, 2027 | February 1, 2027 – April 30, 2027 | Not subject to transitional measures |
The fact that the cutoff for transitional measures is “when the registration period expires by July 31, Reiwa 9 (2027)” is consistent with this rule for the acceptance period. If the expiration date is July 31, 2027, the final day of the acceptance period is March 31, 2027, which is the day before the enforcement date.
⚠️ Furthermore, the Agency strongly recommends submitting a new registration application if applying after the end of the month three months prior to the month in which the registration’s validity period expires, as renewal within the validity period will not be granted and the Application Fee will not be refunded. Please note that it is difficult to recover once the acceptance period has passed.
Transitional measures are merely a grace period, meaning “this time, it will still pass under the old standards.” Practical preparation involves determining by when to establish full-time personnel and a system for each base, counting backward from the registration expiration date.
This amendment does not directly involve foreign nationals themselves undertaking any procedures. However, there are points that are useful to know as a recipient of support.
For those considering changing jobs or workplaces, whether the new workplace has a support system in place can also be a deciding factor. For Period of Stay management, please also refer to “When to apply for Extension of Period of Stay.”
The issues from the company’s perspective can be organized into the following three points:
If you are accepting Specified Skilled Worker (i) at multiple business sites, the first point to confirm is whether a full-time Support Manager and support staff can be assigned to each business site. While concurrent positions are permitted (a Support Manager also serving as support staff), a system that entrusts support duties to part-time staff will require review.
The standard of 50 individuals per support staff member will be a constraint on expansion plans. If there are plans to increase the number of accepted individuals at a base, it is necessary to consider increasing the number of support staff in conjunction.
With the requirements clarified, it has become easier to compare the “cost of continuing in-house support” and the “cost of outsourcing to a Registered Support Organization.” If choosing to outsource, it is safe to confirm whether the outsourced Registered Support Organization can meet the requirements for April 2027 and beyond (especially regarding the system for each office and the number of support staff) before renewing the contract.
Furthermore, there is an indication that from April 2027, the outsourcing of support will be limited to Registered Support Organizations. As this timing coincides with the preparation for the Employment for Skill Development (ESD) Program, we recommend scheduling “Application for ESD Plan before Enforcement Date” concurrently.
📅 Things to do by the end of 2026
📅 Things to do by the end of March 2027
A. The Immigration Services Agency clearly states that “a Support Manager may also serve as Support Staff.” However, even in such cases, it is required that they be full-time and appointed for each business office (or office).
A. The enforcement date is April 1, 2027. However, there are transitional measures for Registered Support Organizations, and they may be able to follow previous regulations until the expiration date of their registration period. For Accepting Organizations that provide their own support, these transitional measures regarding registration do not apply. Please consult with an expert for individual judgments.
A. The training course is “as specified by the Minister of Justice in a public notice,” and the announcement of its content is a prerequisite. The Immigration Services Agency states that even after April 1, 2027, it will be permissible for the time being not to have completed the training course. It would be advisable to take the course systematically once it is announced.
A. The provisions require appointment “for each business office” or “for each office.” It is necessary to check whether the criteria are met on a per-location basis, not by the total number for the entire company.
A. The provision states “exceeding the number obtained by dividing by 50,” while the materials state “fewer than 50 people per person.” According to this interpretation, one person would not be sufficient for exactly 50 people. Please consider a system with ample capacity.
A. For Registered Support Organizations that registered before the enforcement date and whose registration period expires by July 31, 2027, renewal under the previous requirements is possible only if the renewal application is submitted before the enforcement date. However, its validity is only until the expiration date of the registration period. The next renewal will be judged under the new requirements.
A. If the scale is one location and only a few individuals are subject to support, it is unlikely to be caught by the personnel criteria (50 people / 10 organizations). On the other hand, the full-time requirement and the restriction on who can provide support services apply regardless of scale. It is particularly worthwhile for companies where general affairs staff provide support concurrently to check this.
This revision replaces the previously relatively abstract “support system” with four concrete measures: full-time status, per-location basis, number of personnel, and training courses. The purpose of the system is to ensure the quality of support, and for organizations that have provided appropriate support, it is also an opportunity to formalize and organize their system.
The practical conclusion for businesses and Registered Support Organizations is simple. By April 1, 2027, check these two points on a per-location basis: ① whether a full-time Support Manager and Support Staff can be assigned to each business office, and ② whether the number of individuals per Support Staff meets the criteria. And Registered Support Organizations should proceed with preparations counting back from the expiration date of their registration period.
For foreign nationals themselves, this revision can be seen as a step towards making support more accessible, as the support providers will be clearly defined, and there will be criteria for the number of individuals handled by one staff member.
Our office provides consultations for both foreign nationals and accepting companies, based on the latest system trends.
Please feel free to use our free consultation service.
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This article is written based on publicly available information as of September 2026. Details of the system and implementation dates may be subject to change in the future. For actual applications, please refer to the official information from the Immigration Services Agency or contact our office.
Author of this article: Satoshi Nakayama, Administrative Scrivener Authorized to File Applications
Representative, Administrative Scrivener Corporation Miyazaki International Legal Office
Location: Miyazaki City, Miyazaki Prefecture
