Representative Declaration Required from April 15, 2026: What Employers Should Check Before Filing Immigration Applications
Immigration practice from April 15, 2026
For applications filed on or after April 15, 2026, certain immigration procedures involving Category 3 or Category 4 sponsoring organizations may require a “Declaration Regarding the Representative of the Sponsoring Organization.” This is especially important for work-related statuses where the relationship between the foreign national and the sponsoring organization is central to the application, such as Engineer/Specialist in Humanities/International Services, Researcher, Nursing Care, Skilled Labor, Business Manager in certain management cases, and certain Designated Activities.
This document should not be treated as a simple formality. It indicates that the representative of the sponsoring organization understands and is involved in the acceptance of the foreign national, the planned job duties, the employment conditions, and the actual structure of the company. For small and medium-sized companies, newly established companies, companies with foreign national representatives, and first renewals after job changes, consistency between the company’s explanation and the actual situation becomes even more important.
1. What changed?
On several status-of-residence pages, the Immigration Services Agency of Japan now indicates that, for applications filed on or after April 15, 2026, a Declaration Regarding the Representative of the Sponsoring Organization may be required. For example, for Engineer/Specialist in Humanities/International Services, the declaration is listed as an additional document when the sponsoring organization falls under Category 3 or Category 4.
Around the same time, the guidance for Engineer/Specialist in Humanities/International Services also clarified additional evidence regarding language ability where the applicant will mainly engage in customer-facing work using language ability. Therefore, this update should be understood as part of a broader trend toward checking the actual job duties, company-side understanding, and consistency of immigration documents more concretely.
This does not mean that every immigration application now requires this document. Required documents differ depending on the status of residence, type of application, employer category, and application content. Before filing, the relevant status-of-residence page and the latest document checklist should always be checked.
2. What is this declaration intended to confirm?
The Representative Declaration is not merely a document listing the representative’s information. In practical immigration terms, it can be understood as a document confirming that the representative of the sponsoring organization is involved in and takes responsibility for the foreign national’s acceptance, planned job duties, employment contract, and the actual operation of the company.
Even before this update, immigration practice has always required consistency between the company’s actual business, the applicant’s job duties, salary, work location, working hours, and the explanation in the application documents. The introduction of this declaration makes it more difficult for Category 3 and Category 4 employers to file applications without the representative and company-side personnel properly understanding the application content.
This declaration asks the company, in effect: “Do you understand the application content?” “What duties will the foreign national perform?” and “Are those duties appropriate for the status of residence being applied for?”
3. Statuses and applications where this may be relevant
Based on publicly available information, the Representative Declaration is indicated for statuses such as Engineer/Specialist in Humanities/International Services, Researcher, Nursing Care, Skilled Labor, Business Manager in certain management cases, and certain Designated Activities. However, the conditions and category treatment may differ depending on each status of residence, so each case should be checked individually.
| Status / Field | Practical caution | Points to check |
|---|---|---|
| Engineer/Specialist in Humanities/International Services | Impact is especially large for Category 3 and 4 employers. If the role involves customer-facing work using language ability, language evidence may also become an issue. | Job duties, connection with education/work history, employment conditions, company explanation, consistency with the Representative Declaration |
| Researcher | The contract with the sponsoring organization, research content, and actual structure of the host organization are important. | Research content, contract details, organization overview, representative information |
| Nursing Care | The care facility’s actual operation, employment conditions, and consistency with qualification-related documents are important. | Facility overview, job duties, employment contract, qualification-related documents |
| Skilled Labor | For cooks and other skilled roles, the actual business operation, skilled experience, and job duty explanation are important. | Business overview, job duties, proof of work experience, employment conditions |
| Business Manager | For certain cases where the applicant will engage in business management, the Representative Declaration may be required for Category 3 or 4 organizations. | Business plan, capital, full-time employees, office, representative or manager involvement, business continuity |
| Certain Designated Activities | Depending on the activity, the actual structure of the sponsoring organization may be carefully reviewed. | Activity content, contract details, organization explanation, relevant document checklist |
4. Why Category 3 and Category 4 employers are more affected
In immigration procedures, sponsoring organizations are classified into categories depending on their size, reliability, and available public records. Category 1 and Category 2 organizations often include listed companies, large companies, public institutions, and similar organizations, and their company-side documents may be simplified. By contrast, Category 3 and Category 4 often include small and medium-sized companies, newly established companies, and companies that cannot submit certain tax withholding summary records.
The additional declaration appears to require such companies to explain, at the representative level, that they understand the application content and will accept the foreign national responsibly. This is especially important for companies with foreign national representatives, newly established corporations, companies with limited employment management systems, or companies that have had short-term resignations or past refusals.
Submitting the Representative Declaration alone is not enough if the other documents contradict it. The employment contract, working conditions notice, job description, statement of reasons, company profile, financial documents, withholding summary records, and explanation of status eligibility should all be consistent.
5. Points to consider when the representative is a foreign national
If the representative of the sponsoring organization is a foreign national, it may be necessary to review the representative’s own status of residence, stay situation, involvement in company management, and compliance structure. In particular, if the representative is not residing in Japan, or if there is a gap between the representative’s status of residence and the actual company management structure, additional explanation may be advisable.
However, the fact that the representative is a foreign national does not automatically create a disadvantage. The core question is whether the company is actually operating, whether the planned duties of the foreign employee match the status of residence, and whether the company can manage employment and legal compliance properly.
It is risky for a representative to sign without understanding the application content, to describe job duties that differ from the actual work, or to submit company-side documents that do not match the applicant-side explanation.
6. Checklist before filing
For applications filed on or after April 15, 2026, employers should check at least the following points before preparing the application documents.
- Have you confirmed whether the Representative Declaration is required for the relevant status of residence and application type?
- Have you confirmed whether the sponsoring organization falls under Category 3 or Category 4?
- Does the representative understand the application content, job duties, employment conditions, and acceptance structure?
- Are the employment contract, working conditions notice, job description, and statement of reasons consistent?
- Can the connection between the applicant’s education or work history and the planned job duties be explained?
- If the case involves customer-facing work, translation, interpretation, hotel work, or similar duties under Gijinkoku, has the need for language ability evidence been checked?
- If the representative is a foreign national, have the residence card number, status of residence, and involvement in company management been accurately organized?
- If there has been a past refusal, short-term resignation, office relocation, representative change, or business change, can the background be explained?
7. How should we understand the background of this new document?
The addition of the Representative Declaration should not be seen merely as an increase in paperwork. It appears to be part of a broader trend in immigration screening toward closer review of the company’s actual situation and the company-side responsibility for explaining the application.
In Gijinkoku cases in particular, Immigration increasingly focuses on whether the actual job duties are professional activities, whether the work is close to simple labor or simple customer service, and whether there are issues with dispatch-type work or post-job-change employment situations. In this context, the representative of the sponsoring organization is expected to understand the application content and provide a responsible explanation on behalf of the company.
Going forward, not only the applicant’s education and work history, but also the company’s acceptance structure, representative involvement, actual job duties, and consistency of all documents will become even more important. Employers should not treat this as simply “one more form,” but as a sign that the overall explanation responsibility of the application has increased.
8. Practical preparation flow
In cases where the Representative Declaration is required, the following sequence can help prevent contradictions and insufficient explanations.
Need a pre-filing check for Gijinkoku or foreign employee hiring in Japan?
Tommy’s Legal Service supports applications for Engineer/Specialist in Humanities/International Services, Business Manager, Researcher, Nursing Care, Skilled Labor, and Designated Activities. We assist with required document checks, job duty organization, statement of reasons preparation, and consistency review of company-side documents. For Category 3/4 employers, newly established companies, companies with foreign national representatives, and first renewals after job changes, early review before filing is especially important.
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- Immigration Services Agency of Japan: Status of Residence “Engineer/Specialist in Humanities/International Services”
- Immigration Services Agency of Japan: Document list for “Engineer/Specialist in Humanities/International Services”
- Immigration Services Agency of Japan: Clarification of “Engineer/Specialist in Humanities/International Services”
- Immigration Services Agency of Japan: Status of Residence “Researcher”
- Immigration Services Agency of Japan: Status of Residence “Nursing Care”
- Immigration Services Agency of Japan: Status of Residence “Skilled Labor”
- Immigration Services Agency of Japan: Status of Residence “Business Manager”
- Immigration Services Agency of Japan: Designated Activities for graduates of Japanese universities and their family members
This article is based on publicly available information as of May 2026 and summarizes practical immigration points. The conclusion may differ depending on the status of residence, type of application, sponsoring organization category, representative situation, and documents submitted in each individual case.
