Can you deduct dormitory and meal costs from foreign workers' pay? The full-payment principle of wages and the practice of deductions

In short: Wages must in principle be paid in full, and you cannot deduct dormitory or meal costs at will (Labor Standards Act, Article 24, paragraph 1). You can deduct only where there is a provision in law, or a written labour-management agreement (a wage-deduction agreement) with the representative of the majority of the workplace. Further, for foreign workers, under the operation of the technical intern and specified skilled worker systems, dormitory and meal costs should be a reasonable amount based on actual cost, shown in advance in a language the person fully understands, with consent kept in writing. You also need to check that the take-home pay after deduction does not fall below the minimum wage. From the viewpoint of a shakai hoken roumushi's labour management, this page sets out the full-payment principle and the lawful requirements for deductions, the idea of actual cost, the relationship with the minimum wage, showing it in the person's language, and the division of property, residence status and support.

At companies that take in foreign workers through technical intern training, employment-for-skill-development, or specified skills, and provide company housing, dormitories or meals, people often wonder "may we deduct dormitory or meal costs from pay" and "how much may we deduct." This page is for such managers and labour staff. (Technical intern training is scheduled to move to the employment-for-skill-development system, but the framework for wage deductions — Labor Standards Act, Article 24 — is common across the systems.)

Why, when wages must in principle be paid in full, can dormitory and meal costs be deducted in some cases?

Wages must be paid in currency, directly to the worker, in their full amount (Labor Standards Act, Article 24, paragraph 1, the full-payment principle). But the proviso to that paragraph provides that a part of the wages may be deducted where there is a separate provision in law (such as withholding income tax or social-insurance premiums) and where there is a written agreement with the labour union organising the majority of the workers of the workplace, or a person representing the majority of those workers.

Dormitory costs, meal costs and utility costs are not deductions provided for in law, so to deduct them the latter — a wage-deduction agreement — is needed. Withholding dormitory or meal costs without an agreement breaches the full-payment principle.

Type of deduction	Basis	Which are dormitory/meal costs
Deduction provided for in law	Income Tax Act, Health Insurance Act, Employees' Pension Insurance Act, etc.	Not applicable
Deduction by labour-management agreement	Labor Standards Act, Article 24, paragraph 1, proviso	This one (an agreement is needed)

What is the labour-management agreement needed for a deduction, and what must you write for it to be lawful?

A wage-deduction agreement is concluded in writing with the representative of the majority of the workplace (the majority labour union or a person representing the majority). The agreement sets at least the items to be deducted (dormitory costs, meal costs, utility costs, etc.), the amount or the method of calculation, and the day on which the deduction is made (the pay day). You also place a provision on deductions in the work rules and wage rules.

Unlike a 36 Agreement, a wage-deduction agreement does not require filing with the Labour Standards Inspection Office (you do draw it up and keep it). It is understood that what may be deducted under an agreement is limited to clearly reasonable items — purchase prices, company housing/dormitory costs, union dues and the like — and it cannot be used as a means for the employer to unilaterally set off damages or similar.

How much of the dormitory and meal costs may you deduct — the idea of actual cost and the ceiling?

There is no single provision setting a ceiling on the amount itself, but for foreign workers the operation guidelines of the technical intern and specified skilled worker systems require a reasonable amount based on actual cost. Collecting an amount with a profit margin added is not contemplated.

Item	Idea of actual cost (guide)
Residence cost (dormitory)	For an owned property, a reasonable amount based on the cost of construction/renovation and the like; for a leased property, the rent and management fees, etc. — divided by the number of people actually living there
Meal cost	A reasonable amount taking into account the cost actually required, such as the ingredients and cooking costs of the meals provided
Utility cost	The cost actually incurred, divided by the number of residents

In each case, the premise is that you explain it in advance in a language the person fully understands and keep the consent in writing. The basics of providing company housing or meals in kind and deducting the consideration from wages are also covered in Company housing, in-kind wages and the standard remuneration. A qualified professional checks the specific method of apportionment and the reasonableness of the amount, taking into account the property's contract terms and the number of people.

In relation to the minimum wage, how do you check the take-home pay after deduction?

An employer must pay a worker to whom the minimum wage applies wages at or above the minimum wage amount (Minimum Wage Act, Article 4, paragraph 1). The point to note here is that some wages are not counted in the wage used to judge the minimum wage. Wages other than those paid for a period not exceeding one month, and wages other than those for the ordinary working hours or working days that are set by Ministry of Health, Labour and Welfare ordinance, are not counted (the same Article, paragraph 3).

The deduction of dormitory and meal costs is a matter of "how wages are paid," and the minimum wage is judged by whether the wages that should be paid (the countable wages) are at or above the minimum wage. In practice, you avoid deducting to a level where the person's living becomes unsustainable, and first check that the pre-deduction wages meet the regional minimum wage. How the provision of meals or housing in kind is reflected in the minimum-wage calculation is highly individual, so check with the Labour Standards Inspection Office or Labour Bureau having jurisdiction (this article does not make a definitive judgment). The movement of the minimum wage amount itself is covered in The raising of the minimum wage.

How do you show the deduction to the foreign worker in their language and keep the consent?

When concluding a labour contract, you must show labour conditions such as wages and working hours in writing or the like (Labor Standards Act, Article 15, paragraph 1; the same Act's Enforcement Regulation, Article 5). For foreign workers, the Ministry of Health, Labour and Welfare's "Guidelines for employers to appropriately address the improvement of employment management of foreign workers" (the guidelines for foreign workers) require showing the labour conditions in a way the person can understand.

For the deduction of dormitory and meal costs too, it is safest to show the amount (or method of calculation), the breakdown, and the deduction day in a language the person can understand, and keep the consent in writing. For people from China and Taiwan, prepare it in traditional and simplified Chinese and otherwise arrange an explanation in the person's language. The relationship with the residence-status requirement of remuneration equal to or above a Japanese person's is covered in Foreign workers' equal remuneration and the labour-condition notice.

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For the property, residence status and support, to whom do you divide consultations?

The deduction of dormitory and meal costs is within labour matters, but the party in charge of the surrounding procedures differs.

What to do	Whose work it is
The labour-management agreement for wage deduction, the work rules and wage ledger, checking the lawfulness of the deduction amount, and collating with the minimum wage	A Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant) (this office)
Selecting the dormitory property itself and the lease contract	A real estate transaction agent (real estate company)
Acting as agent for residence-status applications, and support for securing housing as a registered support organisation	A gyoseishoshi / a registered support organisation
Filing the dormitory rules for a dormitory that counts as a dormitory attached to the business	A shakai hoken roumushi (supports the filing with the Labour Standards Inspection Office)

This office is limited to providing information and handling procedures for labour management. Shakai hoken roumushi work and the work of a real estate company, gyoseishoshi, or registered support organisation are each carried out by an independent business entity and contracted separately; we do not take these on together under a single contract. The filing of dormitory rules where a dormitory counts as a dormitory attached to the business under the Labor Standards Act is covered in Filing dormitory rules for foreign workers.

What can 四葉社会保険労務士事務所 do for you?

四葉社会保険労務士事務所 in Kohinata, Bunkyo Ward, handles, for the deduction of foreign workers' dormitory and meal costs, drawing up the wage-deduction labour-management agreement, reflecting it in the work rules and wage rules, checking the lawfulness of the deduction amount and collating it with the minimum wage, putting the wage ledger in order, and designing how the deduction is shown in the person's language. The initial consultation is free. We quote according to the content and the number of employees; for how fees are thought about, see the fee schedule, and the questions we are asked most often are collected on the FAQ page.

For the dormitory property and the residence-status procedures, we will guide you to contract separately with a real estate company, gyoseishoshi, or registered support organisation, each an independent business entity. This office does not accept referral fees.

Frequently asked questions

Q. If we conclude a labour-management agreement, can we deduct any amount of dormitory or meal costs from pay?
A. No, not any amount. You need a wage-deduction agreement (Labor Standards Act, Article 24, paragraph 1, proviso) setting the items, amount (method of calculation) and deduction day, and for foreign workers the operation of the technical intern and specified skilled worker systems requires a reasonable amount based on actual cost. Collecting an amount with a profit margin added is not contemplated. The person's understanding and written consent are also a premise.

Q. Does a wage-deduction agreement need to be filed with the Labour Standards Inspection Office?
A. No. Unlike a 36 Agreement, a wage-deduction agreement only needs to be drawn up and kept; there is no duty to file it with the Labour Standards Inspection Office. However, it must be in writing with the representative of the majority of the workplace, what may be deducted is limited to clearly reasonable items such as dormitory and meal costs, and a provision should also be placed in the work rules and wage rules.

Q. Is it acceptable if the take-home pay after deducting dormitory and meal costs falls below the minimum wage?
A. The minimum wage is judged by whether the wages that should be paid (the countable wages) are at or above the minimum wage amount (Minimum Wage Act, Article 4). Deduction is a matter of how wages are paid, but you avoid deducting to a level where living becomes unsustainable, and first check that the pre-deduction wages meet the regional minimum wage. How in-kind wages are reflected in the minimum wage is highly individual, so check with the Labour Standards Inspection Office or Labour Bureau having jurisdiction.

Q. How should the content of the deduction be conveyed to the foreign worker?
A. It is safest to show the amount (method of calculation), the breakdown, and the deduction day in advance in a language the person can understand, and keep the consent in writing. The showing of labour conditions (Labor Standards Act, Article 15, paragraph 1) and the guidelines for foreign workers require showing them in a way the person can understand. For people from China and Taiwan, prepare it in traditional and simplified Chinese and otherwise arrange an explanation in the person's language.

Sources for this article

• Labor Standards Act (労働基準法, Act No. 49 of 1947), Article 24, paragraph 1 (the full-payment principle of wages, and the deduction of a part where there is a provision in law or a written agreement with the representative of the majority of the workplace), Article 15, paragraph 1 (showing labour conditions), Article 95 (drawing up and filing the dormitory rules of a dormitory attached to the business); Enforcement Regulation, Article 5 (matters to be shown) (confirmed against e-Gov on October 17, 2026)
• Minimum Wage Act (最低賃金法, Act No. 137 of 1959), Article 4, paragraph 1 (the duty to pay wages at or above the minimum wage amount), paragraph 3 (wages not counted in calculating the minimum wage = wages other than those paid for a period not exceeding one month that are set by Ministry of Health, Labour and Welfare ordinance, etc.) (confirmed against e-Gov on October 17, 2026)
• Guidelines for employers to appropriately address the improvement of employment management of foreign workers (the guidelines for foreign workers, Ministry of Health, Labour and Welfare). Showing labour conditions in a way the person can understand (referenced October 17, 2026)
• The thinking on accommodation and cost collection in the operation guidelines of the Immigration Services Agency and the Organization for Technical Intern Training (residence, meal and utility costs are a reasonable amount based on actual cost, shown in advance with the person's consent). The apportionment per item and the reasonableness of the amount are individual judgments, so they are not given as fixed values (referenced October 17, 2026)

This article does not go so far as to decide whom you should consult. Drawing up the wage-deduction labour-management agreement, work rules and wage ledger, checking the lawfulness of the deduction amount, and collating with the minimum wage are the work of a shakai hoken roumushi. Selecting and leasing the dormitory property is the work of a real estate transaction agent; acting as agent for residence-status applications and support for housing as a registered support organisation is the work of a gyoseishoshi or a registered support organisation; each is carried out by an independent business entity and contracted separately. This office does not accept referral fees. The cost of consulting 四葉社会保険労務士事務所 is set out in the fee schedule, and the questions we are asked most often are collected on the FAQ page.

This article is general information. Judgments that fit your particular circumstances are made by a qualified professional after a meeting. Written by Joji Uramatsu (Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist).