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2026.09.01Procedures and deadlines

When a worker transfers, what happens to social and employment insurance?

Joji Uramatsu

Joji Uramatsu

Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist — 四葉社会保険労務士事務所/四葉行政書士事務所

Seen from the labour side, a transfer is a separation and a hire happening at once. The old employer files losses of insured status, the new employer files acquisitions, and the foreign worker employment status notification is required on both sides. Relocation costs are a matter to be explained in writing at the application stage. We lay out both sides with deadlines.

In short: seen from the labour side, a transfer (tenseki) is a separation and a hire happening at the same time. The old employer files the losses of insured status for social and employment insurance, the new employer files the acquisitions, and the foreign worker employment status notification is required on both sides (Act on Comprehensive Promotion of Labour Measures, Article 28, paragraph 1). Relocation costs are a matter to be explained in writing at the application stage (reference form 1-39).

This page is for back-office staff of companies receiving, or preparing to receive, workers under the Employment for Skill Development system. The conditions under which a transfer is permitted are the territory of ministerial orders and the immigration authorities — this article does not cover them; for that side, consult 四葉行政書士事務所 (a separate business), which maintains the external auditor page. This article covers only what labour administration does when a transfer happens.

What is a transfer, legally speaking?

The labour and social insurance world has no special "transfer" procedure. It is the end of the employment contract with the old employer and the conclusion of one with the new employer — a separation plus a hire. So the procedures arise on both sides, exactly as usual. Assume "it's an intra-system move, so the paperwork must be simplified" and the notifications get missed.

Note that the plan-certification application set includes seven forms on changes of implementer (reference forms 1-16 to 1-22; OTIT, checked 14 August 2026). As the number of forms shows, transfer is not an edge case in this system but the centre of its design. Prepare the procedures on the assumption that it will happen — not "we'll think about it if it does."

What does the old employer file, and by when?

ProcedureDeadline (guide)
Health insurance and employees' pension loss notificationsWithin 5 days of the event
Employment insurance loss notification (confirm with the person whether a separation certificate is wanted)Within 10 days from the day after separation
Employment status notification (separation side)The employment insurance loss notification doubles as it; for non-insured workers, Form 3 by the end of the following month
Handover and settlement of company housing, if providedPer the contract and the in-kind compensation treatment

Delay the loss notifications because "the person is just moving to another company," and both the premium calculations and the person's health-insurance switch stall. The deadlines are the same as an ordinary departure.

What does the new employer file, and by when?

ProcedureDeadline (guide)
Health insurance and employees' pension acquisition notificationsWithin 5 days of the event
Employment insurance acquisition notificationBy the 10th of the month following the hire
Employment status notification (hire side)The acquisition notification doubles as it (complete the residence-status fields correctly)
Employment contract and conditions document (reference form 1-2), treatment statementsKept consistent with the application-side documents

The hire-side skeleton is the same as What to file, and by when, after incorporating and Hired a foreign worker? Notify Hello Work. What makes transfers distinctive is that the separation-side and hire-side filings run simultaneously across two companies — familiar from ordinary job changes, and just as easy to drop.

Who bears the moving and relocation costs?

The application forms point to where the answer lives. Reference form 1-39 is the statement covering remuneration, accommodation and amounts collected plus "moving and relocation costs" (OTIT, checked 14 August 2026). In other words, who bears relocation costs is a matter to be explained in writing at the entrance — not something to negotiate after a transfer happens.

The standards for amounts and shares belong to the operating guidelines and sector-specific rules, which this article does not enter. What labour administration does is clear: put the treatment of housing, the return of company property, and the cost rules into the contract and the internal rules. The rules side is covered in How do you revise the work rules before receiving workers?.

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, handles the loss and acquisition filings and the employment status notifications when a transfer occurs, and designs the contract, housing and cost rules on the assumption that transfers can happen. Consultation is free of charge. Fees are in the fee schedule; the full "what to do now" calendar is in The Employment for Skill Development system — what to do now.

Whom to consult

The application side of transfer conditions and procedures, supervising support organisation licences 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 and corporate leases go to 四葉不動産株式会社 (likewise). Payroll taxation is for a tax accountant, disputes for an attorney. No referral fees change hands.

Frequently asked questions

Q. Can't the social insurance simply continue across the transfer?
A. There is no "continuation" mechanism: the old employer files losses and the new employer files acquisitions, each within its deadline. If the paperwork stalls, the person's health-insurance switch is delayed — in practice both companies' back offices move simultaneously once the transfer date is set.

Q. Which company files the employment status notification?
A. Both. A transfer is, in labour terms, a separation plus a hire, so the old employer files the separation-side notification and the new employer the hire-side one (Act on Comprehensive Promotion of Labour Measures, Article 28, paragraph 1). For insured workers, the loss and acquisition notifications each double as the notification.

Q. Can we prevent transfers?
A. The conditions and permissibility of transfers are the territory of ministerial orders and the immigration authorities; this office does not judge them. What labour administration can do is build a workplace people do not transfer out of — transparent treatment, a working life-advisor arrangement, language support. As set out in the comparison article, the axis shifts to designing for retention.

Q. Must the company bear the relocation costs?
A. This article gives no blanket answer. The cost rules are checked against the operating guidelines and sector-specific provisions, and then made explicit in writing at the entrance (the form 1-39 statement). Having no rule at all is the biggest risk.

Sources for this article

  • Act on Comprehensive Promotion of Labour Measures (労働施策総合推進法, Act No. 132 of 1966), Article 28, paragraph 1 (the foreign worker employment status notification) — 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) — reference forms 1-16 to 1-22 on changes of implementer; the statement covering moving and relocation costs (form 1-39)
  • The deadlines for acquisitions and losses follow the enforcement ordinances of the Health Insurance Act, the Employees' Pension Insurance Act and the Employment Insurance Act (the acquisition-side provisions are set out in the incorporation article)
  • The detailed conditions under which transfers are permitted belong to ministerial orders, the operating guidelines and the immigration authorities. This article covers the labour-side procedures only

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).

Let’s start by sorting out where things stand.

四葉社会保険労務士事務所 (Kohinata, Bunkyo-ku; a 5-minute walk from Myogadani Station on the Tokyo Metro Marunouchi Line) helps you, starting with a review of your current labour practices.

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