How do you revise the work rules before receiving workers?

In short: receiving foreign workers does not itself change the obligation to draw up work rules. What changes is the distance between the rules and reality. Work rules function only when made known (Labor Standards Act, Article 106), and posting them solely in a language the person cannot understand raises the question of whether that is sufficient. Under a system where transfers are a premise, the provisions on lent property, housing and cost burdens become the new points of contention.

This page is for owners and back-office staff preparing their work rules before receiving workers under the Employment for Skill Development system (or technical intern training). From how many workers the obligation arises is covered in the dedicated article; this one is about what to fix before receiving.

Does receiving foreign workers require revising the rules?

The trigger for the obligation (ten or more workers regularly employed — Labor Standards Act, Article 89) does not depend on nationality. The need to revise arises because realities the rules never contemplated come in:

• Housing — the company provides dormitories more often; the collections and in-kind compensation need anchoring in rules and a deduction agreement
• Lent property — workwear, tools, bicycles, Wi-Fi routers; lending accumulates without return rules
• Living rules and discipline — dormitory rules run outside the work rules leave discipline without a footing
• Consistency with the application documents — the certification application includes the contract and conditions document (reference form 1-2) and treatment statements. If the rules and the application papers diverge, one of them is false

Without a translation, has "making known" happened?

No translation obligation as such exists in the statutes. At the same time, work rules must be made known to workers by posting or keeping them in a visible place at each workplace, distributing them in writing, or other methods prescribed by ministerial order (Labor Standards Act, Article 106, paragraph 1).

Making known exists so that workers can actually know the rules — not merely so that a document sits somewhere. Whether rules displayed only in a language the person cannot understand satisfy that purpose is precisely the question — and it comes back as whether, in a dispute, you can truly say "they were made known." As practice, we recommend providing at least the parts that touch the person directly — working conditions, deductions, discipline, leaving the dormitory — in summary form in their language or one they understand. How far to translate is a cost decision; the multilingual approach is also covered in our foreign-employment service.

With transfers as a premise, which provisions do you revisit?

A transfer is, in labour terms, a separation plus a hire. Reread the rules on the assumption that people move, and the places to fix become visible.

Provision	Angle
Dormitory/housing rules	Vacating deadlines on departure or transfer, restoration costs, settlement of housing charges. Form 1-39 requires explaining moving and relocation costs
Lent property	What must be returned, by when, and compensation rules
Wages and deductions	The agreement basis for housing and utility deductions, and settlement on departure
Training and licence costs	The treatment of company-funded courses. A casually drafted repayment-on-departure clause can collide with Article 16 of the Labor Standards Act (prohibition of predetermined damages) — an easy place to mis-design; take individual advice
Discipline and service rules	Whether dormitory living rules are anchored as service discipline

By when should the rules be fixed?

Before the application. The certification application includes the contract templates and treatment statements (the calendar), so applying with inconsistent rules only multiplies later corrections. Amending work rules also requires hearing the majority representative's opinion, attaching the written opinion, and making the amended rules known (Labor Standards Act, Articles 90 and 106) — build that into the count-back. The procedure runs as described in Can work rules drafted by an AI actually be filed?.

What can 四葉社会保険労務士事務所 do?

四葉社会保険労務士事務所, in Kohinata, Bunkyo City, revises and drafts the work rules, housing rules and wage-deduction agreements before receiving workers, designs the native-language summaries, and runs the procedure from opinion-hearing to filing and making known. Fees: the "work rules" rows of the fee schedule. Consultation is free of charge. Bring your current rules and we start with a stocktake of what to fix before receiving.

Whom to consult

The plan-certification and licence application documents, and residence status, go to 四葉行政書士事務所 (a separate business from this office, engaged under a separate contract). Housing property and corporate leases go to 四葉不動産株式会社 (likewise). Payroll taxation is for a tax accountant; matters already in dispute for an attorney. No referral fees change hands.

Frequently asked questions

Q. Must the work rules be translated in full?
A. No translation obligation as such exists. But given the purpose of making known (Article 106), we recommend summaries in a language the person understands for the parts that touch them directly — conditions, deductions, discipline, dormitory departure. Full versus summary translation is designed around cost and reality.

Q. We have fewer than ten workers and no work rules. Should we still make them?
A. The obligation applies from ten workers (Article 89). Even without the obligation, unwritten rules on housing, lent property and deductions mean case-by-case negotiation at every transfer or departure. The threshold question is covered in the dedicated article.

Q. Can dormitory curfews and living rules go into the work rules?
A. Design via service discipline is possible, but constraints on private life are tested for reasonableness. The practical shape is to carve living rules out into dormitory rules and limit what connects to discipline. Consult on the specific drafting.

Q. We pay for Japanese lessons. Can we require repayment if the person quits?
A. A casual repayment clause can collide with the prohibition of predetermined damages (Labor Standards Act, Article 16); whether it can be drafted safely cannot be answered in the abstract. We lay out the design options and the issues, with an attorney's check where needed.

Sources for this article

• Labor Standards Act (労働基準法, Act No. 49 of 1947), Article 89 (obligation to draw up and file), Article 90 (opinion hearing), Article 106, paragraph 1 (making known), Article 16 (prohibition of predetermined damages), Article 24 (deduction agreements) — current text confirmed on e-Gov on 14 August 2026
• OTIT, "Pre-enforcement applications for training-employment plan certification" (updated 5 August 2026; checked 14 August 2026) — the contract and conditions document (reference form 1-2), the treatment statements, the moving and relocation costs statement (form 1-39)
• Whether a translation is needed and whether making-known is sufficient are questions on which assessments differ case by case. This article confines itself to the general approach

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).