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On October 19, 2026, the Immigration Services Agency (hereinafter, “Immigration Agency”) revised its operational guidelines for the “Sworn Statement Regarding the Business Activities of Specified Skilled Worker (ii) Foreign Nationals” (Reference Form 1-32), which has been required for Status of Residence applications for Specified Skilled Worker (ii) since August 20, 2026. The relevant sections of the “Operational Guidelines for Accepting Specified Skilled Worker Foreign Nationals” and the form for the sworn statement were amended, and Q&A 102-105 of the “Q&A Regarding the Specified Skilled Worker System” were updated.
In Q&A 102, the Immigration Agency cited inquiries regarding how to handle situations where the number of individuals to be supervised is temporarily insufficient or not full-time as the reason for the revision. This article, following up on the previous article that explained the handling from August 20, will clarify what has changed and what should be written in the application for both accepting companies and foreign nationals working under Specified Skilled Worker (ii).
The following updates were posted on the Immigration Agency’s Specified Skilled Worker system page on October 19, 2026:
| Published Item | Content |
|---|---|
| Operational Guidelines for Accepting Specified Skilled Worker Foreign Nationals (October 2026) | Revised 【Notes】 in Chapter 3, Section 2 “Specified Skilled Worker (ii)” (with comparison table of old and new versions) |
| Reference Form 1-32 “Sworn Statement Regarding the Business Activities of Specified Skilled Worker (ii) Foreign Nationals” | Revised Notes 3-5 and the remarks for sectors where individuals to be supervised are not required |
| Q&A Regarding the Specified Skilled Worker System | Updated Q102-Q105 |
The revised operational guidelines state that Specified Skilled Worker (ii) individuals “normally need to supervise more than the number of individuals stipulated for each specified industry sector, and are required to do so stably and continuously,” and then add three cases where the counting of individuals to be supervised will be handled flexibly.
A comparison of the August 20 form and the October 19 form/operational guidelines is as follows:
| Item | Before Revision (from August 20, 2026) | After Revision (from October 19, 2026) |
|---|---|---|
| Business Establishment | Limited to those who work at the same business establishment as the Specified Skilled Worker (ii) | Principle is the same business establishment. If there are reasonable circumstances depending on the characteristics of the sector, it may be handled flexibly even if not the same business establishment. |
| Department | In principle, the same department | Principle is the same department. If not the same business establishment/department due to the characteristics of the sector, it will be judged individually considering the circumstances (reason to be stated in the sworn statement). |
| Full-time | Limited to those engaged in full-time work | This description has been removed from the operational guidelines and the sworn statement’s Notes (Q102 cites inquiries about “circumstances such as not being full-time” as the reason for the revision). |
| Individuals supervised by other Specified Skilled Worker (ii) individuals | Not stated (not included in the target individuals) | If there are reasonable circumstances, such as when Specified Skilled Worker (ii) individuals with different specializations supervise the same person, they may be included as target individuals. |
| When the number of individuals is temporarily insufficient | No exception stipulated (supervision of more than the required number is necessary) | If there are reasonable circumstances, such as being in the hiring process, it will be handled flexibly. Check item 5 of the sworn statement’s Notes and state the reason. |
| Sectors where individuals to be supervised are not required | Sectors/job categories where the required number is not specified | Explicitly stated as Aviation sector (aircraft maintenance category), Fisheries sector, and Food Service Industry sector. |
💡 The removal of the full-time description does not mean that the Immigration Agency indicates that individuals working in any capacity can be listed as individuals to be supervised. The operational guidelines require “stable and continuous” supervision. If you plan to list part-time individuals, we recommend confirming before applying whether you can specifically describe the actual supervision situation.
The Immigration Services Agency cites the following two examples in Q103:
Revised Sworn Statement Note 5 requires applicants to check the box and provide a reason (with an attached separate sheet if necessary) if the required number of trainees for each field is temporarily not met, such as when the trainee is in the hiring process and not yet confirmed at the time of application. The wording in the checkbox generally states the following:
⚠️ Note 5 is “a section to explain that the number of people is insufficient only this time.” Both the individual and the company must understand that if it is used without a plan to complete hiring and meet the required number by the next renewal, the next renewal may be denied.
There is no fixed format for writing in the reason column. As an example considered by our office, writing specific facts such as the following will make it easier to convey that the situation is temporary:
As a general rule, trainees must commute to the same office and belong to the same department as the Highly Skilled Professional (ii). However, in Q104, the Immigration Services Agency states that if the Highly Skilled Professional (ii) or the trainee works at multiple locations, or if it is deemed that appropriate supervision is being provided due to the structure of the affiliated organization or department, etc., they will handle cases flexibly even if they are in different offices or different departments.
In this case, the circumstances of not being in the same office or department should be written in the reason column of Sworn Statement Note 3. As an example envisioned by our office, a description that clarifies the actual supervision situation, such as “the work site changes daily, and the Highly Skilled Professional (ii) and the trainee work together at the same site,” could be considered.
Before the revision, individuals receiving supervision from another Highly Skilled Professional (ii) could not be listed as trainees. After the revision, if there are reasonable grounds, such as when Highly Skilled Professionals (ii) with different specializations supervise the same person, or in cases specific to the field, they may be included as trainees.
Applications submitted between August 20 and October 19, 2026, until the revision, will also be reviewed under the revised handling procedures. Therefore, the Immigration Services Agency states that, in principle, a new form of the sworn statement will need to be resubmitted.
However, if the old form of the sworn statement already lists the required number of trainees for each field, it is not necessary to use the new form, and a replacement is not required.
| Status of Pending Application | Action |
|---|---|
| Submitted using the old form, with the required number of trainees written | No request to replace with the new form |
| Submitted using the old form, with an insufficient number of trainees or unable to write the number | In principle, resubmit the new form (if necessary, state the reason in the remarks column of Notes 3 and 5) |
Q105 does not specify when or how to submit the new form. If you had an insufficient number of trainees on the old form, we recommend preparing the new form and then confirming the submission method with the Immigration Services Agency where you will be applying.
The required number of trainees has not changed before or after the October 19 revision.
| Specified Skilled Worker (ii) Field | Required Number of Trainees |
|---|---|
| Building Cleaning | 2 or more |
| Industrial Product Manufacturing | 2 or more |
| Construction | 2 or more |
| Shipbuilding and Marine Industry | 2 or more |
| Automobile Maintenance | 1 or more |
| Aviation | Airport Ground Handling category: 1 or more |
| Accommodation | 2 or more |
| Agriculture | 2 or more |
| Fisheries | Not specified (may be 0) |
| Food and Beverage Manufacturing Industry | 2 or more |
| Food Service Industry | Not specified (may be 0) |
In the Aviation field (aircraft maintenance category), Fisheries field, and Food Service Industry field, it is stated that it is acceptable for there to be no trainees. However, if trainees are present, they must be listed in “2 List of Trainees to be Supervised by the Specified Skilled Worker (ii) Foreign National” on the sworn statement.
The sworn statement is a “document that accurately reflects the actual situation.” Note 1 of the sworn statement states that if there is a discrepancy between the description and the actual content, the Status of Residence may be revoked, and if false information is written, it may constitute a disqualifying factor for the Specified Skilled Worker (SSW) accepting organization.
Q1. Has the requirement for the number of trainees been eliminated with the October 19 revision?
No, it has not been eliminated. The revised operational guidelines also state that, ordinarily, it is necessary to supervise at least the number of trainees specified for each field. It is accurate to understand that if the number is temporarily insufficient, an application can be submitted with a written reason, and if reasonable circumstances are recognized, it will be handled flexibly.
Q2. One trainee resigned, and the number of trainees is now insufficient. Can I still apply for renewal?
A shortage due to resignation or leave is cited by the Immigration Services Agency in Q103 as an example of “temporary” (whether it is recognized as temporary is subject to individual judgment). You would check Note 5 on the sworn statement and apply by writing the timing of the resignation and the recruitment status in the reason column. However, if the number of trainees is still insufficient at the time of the next renewal, the renewal may be denied.
Q3. My mentee works at a different site. Can I still write about them?
In principle, it should be the same business establishment and the same department. However, if there are multiple workplaces, it is stated that a flexible approach will be taken even for different business establishments or departments (Q104). In the reason column of Remark 3, describe how the guidance is actually provided.
Q4. I applied for an extension in September using the old form. Do I need to do anything?
If you submitted the application with the required number of mentees, you are not required to replace it with the new form. If the number was insufficient, you will, in principle, need to resubmit the new form (Q105).
Q5. I am a Specified Skilled Worker (ii) in the Food Service Industry, but I don’t have any mentees.
In the Food Service Industry, it is stated that it is acceptable not to have any mentees. If mentees are employed, they should be listed in the mentee list of the Sworn Statement.
With the revision on October 19, 2026, the Sworn Statement for Specified Skilled Worker (ii) can now be submitted with a reason if there is a temporary absence of mentees, or if the mentee is receiving guidance from another business establishment/department or another Specified Skilled Worker (ii). However, the basic principle of the required number for each sector and providing guidance to more than that number remains unchanged (after the revision, it was also explicitly stated that it should be done “stably and continuously”). When the number is insufficient, it is important for the company and the individual to articulate the reason and the plan to meet the required number by the next renewal.
💴 Support fees for Status of Residence changes and extensions for Specified Skilled Worker are listed in the “Fee” section. The first consultation is free for up to 60 minutes online.
As an Administrative Scrivener Corporation in Miyazaki City, Miyazaki Prefecture, our office assists with Specified Skilled Worker (ii) applications and the organization of acceptance systems.
For procedures that can be filed online, such as applications for a Certificate of Eligibility, change of status of residence and extension of period of stay, we accept requests from clients nationwide. Meetings are held online (Google Meet, LINE) and documents are exchanged by mail or electronically, so there is no need to visit our office. Applications for Permission for Permanent Residence and for Permission of Naturalization cannot be filed online and must be submitted at the counter, so they are limited to residents of Miyazaki Prefecture. Depending on the procedure and its urgency, you may need to collect your Residence Card at the counter of the immigration office covering the area where you live. Online applications cannot be filed on the last day of your period of stay, so please consult us as early as possible.
Please feel free to use our free consultation service first.
📞 To book a phone consultation: 0985-68-0851
Before you submit, let us take a look.
Free Immigration Pre-Submission Check ›
For those who will apply for a status of residence at the Immigration Services Bureau by themselves. Before you submit, we check your application form and supporting documents and tell you about any missing documents and points to watch. We accept checks online (Google Meet, about 20 minutes) or via LINE.
・Eligible: applications for a Certificate of Eligibility, change of status of residence and extension of period of stay (applications for permanent residence are accepted only from residents of Miyazaki Prefecture). Naturalization is not covered.
・Online (Google Meet): once per application. Replies via LINE: available for the same application until you submit it.
・Our guideline for replies via LINE is, in principle, within 2 business days (we are closed on Saturdays, Sundays and public holidays; replies may take longer when we are busy).
・Please send copies of your documents by LINE or email. For your residence card, send the front side only; please do not send the side showing your My Number.
・What we tell you is our office’s opinion. It does not guarantee approval; the outcome depends on the decision of the Immigration Services Bureau.
・We only point out missing documents and points to watch. We do not prepare or rewrite your application documents for you or draft text for them, and we do not tell you whether your application is likely to be approved (if you would like to engage us, we will introduce the Self-Prep Course, the Light Plan and the Standard Plan).
・If we find that a document contains information that is not true, or that the application is not your own (or a family member’s), we will decline the check.
This article was written based on publicly available information as of October 2026. Details of the system and implementation dates may change in the future. For actual applications, please confirm with the official information from the Immigration Services Agency or our office.
Author of this article: Administrative Scrivener Authorized to File Applications Satoshi Nakayama
Representative, Administrative Scrivener Corporation Miyazaki International Legal Office
Location: Miyazaki City, Miyazaki Prefecture
