Certified kodomoen hoiku-kyoyu: how do you draw the line on shifts and social insurance?

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
A nursery-kindergarten combined centre (yoho-renkei-gata ninteikodomoen) mixes, in one building, Type 1 children who receive education only and Type 2 and 3 children in long-hours childcare. Type 1 is the standard education time (4 hours a day as the norm), while Type 2 and 3 are the childcare standard time (up to 11 hours a day) or short childcare time (up to 8 hours a day), so hoiku-kyoyu shifts overlap these long and short spans. A hoiku-kyoyu is in principle required to hold both a kindergarten-teacher licence and childcare-worker registration (Ninteikodomoen Act, Article 15), but a special measure allowing either one has been extended to the end of FY2029 (March 2030). Short-hours staff are insured if they work three-quarters or more of a regular worker's hours, and otherwise if they meet 20-plus hours a week, a prospect of employment over two months, not being a student, and the employer's size (over 51 insured persons until September 2027) — the 88,000-yen monthly wage requirement was abolished on October 1, 2026. Applications for approval go to a gyoseishoshi, accounting and tax to a tax accountant, and premises to a real-estate agent, under separate engagements.
In short: A nursery-kindergarten combined centre (yoho-renkei-gata ninteikodomoen) mixes, in one building, Type 1 children who receive education only and Type 2 and 3 children in long-hours childcare. Type 1 is the standard education time (4 hours a day as the norm); Type 2 and 3 are the childcare standard time (up to 11 hours a day) or short childcare time (up to 8 hours a day), so hoiku-kyoyu (childcare teacher) shifts are built by overlapping these long and short spans. A hoiku-kyoyu is in principle required to hold both a kindergarten-teacher licence and childcare-worker registration (Ninteikodomoen Act, Article 15), but a special measure under which either one alone qualifies you has been extended, by the 2024 amendment, to the end of FY2029 (March 2030). For short-hours staff, social insurance (health insurance and employees' pension) applies if they work three-quarters or more of a regular worker's hours, and otherwise if they meet 20-plus hours a week, a prospect of employment over two months, not being a student, and the employer's size (over 51 insured persons until September 2027) — the 88,000-yen monthly wage requirement was abolished on October 1, 2026. This page organises opening hours and shifts, the hoiku-kyoyu qualification, short-hours staff's social insurance, and the labour side of the processing-improvement addition from a shakai hoken roumushi's viewpoint, sending applications for approval and certification to a gyoseishoshi, accounting and tax to a tax accountant, and premises to a real-estate agent — each contracted separately as an independent business entity.
A yoho-renkei-gata ninteikodomoen combines the functions of a kindergarten and a nursery, so opening hours, staff qualifications and the line on social insurance all become problems at once. This page is for directors and office staff who are opening or running a ninteikodomoen. The final judgment on whether a particular centre meets the standards or the addition requirements must be checked against the approving/certifying authority (prefecture or municipality) and the Children and Families Agency's guidelines.
How do a ninteikodomoen's opening hours change across Type 1, 2 and 3 certification?
Opening hours are set by the certification category of the children admitted. Under the Child and Childcare Support Act, a child aged 3 or over who does not fall under a ground requiring childcare is Type 1 (standard education time); a child aged 3 or over who does fall under such a ground is Type 2; and a child under 3 who falls under such a ground is Type 3. Type 1 follows the standard education time (4 hours a day as the norm), while Type 2 and 3 split, according to the amount of childcare needed, into the childcare standard time (up to 11 hours a day) or short childcare time (up to 8 hours a day).
So in the same centre there are Type 1 children who arrive in the morning and go home in the early afternoon, alongside Type 2 and 3 children who stay 11 hours from morning to evening. Hoiku-kyoyu shifts must staff the education time generously while running early, late and extended childcare without gaps, so the busy-and-slack swing and the skew by time of day are large. This early-late-extended shift design is the same issue in nursery labour; Labour when opening a nursery sets out the staffing standards and how to build a variable working-hours system.
| Certification category | Who | Time category |
|---|---|---|
| Type 1 | Age 3+, no ground for childcare | Standard education time (4 hours/day as the norm) |
| Type 2 | Age 3+, with a ground for childcare | Childcare standard time (up to 11h) / short childcare time (up to 8h) |
| Type 3 | Under 3, with a ground for childcare | Childcare standard time (up to 11h) / short childcare time (up to 8h) |
Actual opening hours and extended-childcare settings differ by centre, so working hours are designed against the centre's operating rules and the expected mix of certification categories.
How does the hoiku-kyoyu qualification bear on shift design?
The chief hoiku-kyoyu, instructional hoiku-kyoyu, hoiku-kyoyu and others placed in a yoho-renkei-gata ninteikodomoen must in principle hold a kindergarten-teacher licence and be registered as a childcare worker (Ninteikodomoen Act, Article 15). This flows from the centre's character, where the same staff handle both education (Type 1 children) and childcare (Type 2 and 3 children).
Because holding both at once is hard, a special measure under which either one qualifies you as a hoiku-kyoyu is in place and, by the 2024 amendment, was extended to the end of FY2029 (March 2030). The separate measure allowing a chief or instructional hoiku-kyoyu to serve with only one of the two has a shorter extension, to the end of FY2026 (March 2027). As the deadlines approach, staff who hold only one side will need to acquire the other, so in building shifts it is essential to track who must satisfy the dual qualification by when.
| Category | Principle | Deadline of the measure |
|---|---|---|
| Hoiku-kyoyu etc. (dual-holding measure) | Kindergarten-teacher licence + childcare registration | Either one accepted until end of FY2029 (March 2030) |
| Chief / instructional hoiku-kyoyu (one-side-only measure) | Same | Until end of FY2026 (March 2027) |
The scope of the measure and the credits needed to acquire a licence should be checked against the latest guidance of MEXT and the Children and Families Agency and the prefecture's handling. The final check on whether the dual qualification is met is made by a qualified professional.
By what standard are short-hours staff enrolled in social insurance?
A ninteikodomoen often supports early, late and extended childcare with short-hours part-time staff, so the social insurance (health insurance and employees' pension) enrolment test is essential. The test has two stages. First, if a person's weekly scheduled hours and monthly scheduled working days are three-quarters or more of those of a regular worker in the same work, they are insured (this three-quarters rule is covered in detail in Part-timers' social insurance and the three-quarters rule).
Short-hours staff below three-quarters are still insured if they meet all of: ① 20 or more scheduled hours a week; ② a prospect of employment over two months; ③ not being a student; and ④ the employer's number of employees' pension insured persons being at or above a threshold (over 51 until September 2027; expanding to over 36 from October 2027). There used to be a "monthly scheduled wage of 88,000 yen or more" wage requirement, but it was abolished on October 1, 2026 under the 2025 pension-system reform act, so the test now runs on 20-plus hours and the rest regardless of wage amount. The full picture of this phased expansion of the size requirement is set out in Expansion of social insurance coverage (from 2027).
| Test | Content |
|---|---|
| Three-quarters rule | Weekly scheduled hours / monthly scheduled days are three-quarters or more of a regular worker's → insured |
| Short-hours worker requirements | 20+ hours/week / prospect over 2 months / not a student / size (over 51 until Sept 2027, over 36 from Oct 2027) |
| Wage requirement (88,000 yen/month) | Abolished on October 1, 2026 |
When the enrolment prospect changes, the premium and standard-remuneration filings change too. The final judgment on whether a particular staff member is insured is made by a qualified professional in light of the employer's size and the actual way of working.
When reflecting the processing-improvement addition in wages, what do you put in order on the labour side?
The processing-improvement addition (shogu-kaizen-to-kasan) is added on top of the facility-type benefit on the premise of raising staff wages, so how the addition received is distributed to which staff must be written into the work rules and wage rules. The methods of deciding, calculating and paying wages, and matters on pay raises, are absolute mandatory items of the work rules (Labor Standards Act, Article 89), and a centre that regularly uses 10 or more persons is obliged to draw up and file work rules. Writing the allowances and distribution rules that correspond to the addition into the rules, so there is no gap with actual payment, is the foundation for explanation at audits and performance reports.
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| What to put in order | Basis / aim |
|---|---|
| Wage rules (allowances, distribution rules) | Mandatory items under LSA Art. 89; make the basis for distributing the addition explicit |
| Drawing up / filing work rules | Obligatory where 10 or more are regularly used (LSA Art. 89) |
| Wage ledger, attendance records | Consistency between the addition's performance report and actual payment |
The calculation of the addition amount, its accounting and tax treatment, and the performance-report figures themselves are the field of a tax accountant and the local guidelines. What labour handles is the rules and the attendance/wage-ledger management needed to deliver the addition to staff as wages. The final judgment on whether the distribution is appropriate is made by a qualified professional against the centre's reality and the local guidelines.
Who handles the approval/certification application, accounting and premises?
Opening or reviewing a ninteikodomoen sets several specialist fields in motion at once. The application for approval/certification and the setting-up permits are the work of a gyoseishoshi, and the flow and requirements of the application are set out in Approval/certification application for a ninteikodomoen. The accounting and tax filing for the facility-type benefit and the processing-improvement addition are for a tax accountant, and the use and equipment of the building and the lease terms are the field of a real-estate transaction agent. As an independent business entity separate from these, a shakai hoken roumushi takes on only the labour part — social and labour insurance application and procedures, work and wage rules, and variable-working-hours shift design — contracted separately.
From the labour side, fixing the opening-hours and shift design, managing hoiku-kyoyu dual-qualification status, the short-hours staff social insurance test, and the wage rules matching the processing-improvement addition early, in parallel with the opening schedule, is what most reduces later re-doing of procedures.
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 labour of a yoho-renkei-gata ninteikodomoen, shift and variable-working-hours design reflecting opening hours and Type 1 to 3 certification, management of hoiku-kyoyu licence/qualification (dual-holding), the social and employment insurance test and enrolment procedures for short-hours staff, and work and wage rules matching the processing-improvement addition. The initial consultation is free. We quote according to the content and number of employees; for how fees are thought about, see the fee schedule, and the questions we are asked most often are on the FAQ page.
The approval/certification application and setting-up permits are the field of a gyoseishoshi, accounting and tax of a tax accountant, and premises of a real-estate agent; we will guide you to contract with each separately, as an independent business entity. This office does not accept referral fees.
Frequently asked questions
Q. Do a ninteikodomoen's opening hours differ between Type 1 and Type 2/3?
A. Yes. Type 1 is the standard education time (4 hours a day as the norm), while Type 2 and 3 split, by the amount of childcare needed, into the childcare standard time (up to 11 hours a day) or short childcare time (up to 8 hours a day). Because short-hours Type 1 and long-hours Type 2/3 children mix in the same centre, hoiku-kyoyu shifts must overlap the education time with early, late and extended childcare. Actual opening hours differ by centre.
Q. Does a hoiku-kyoyu need both a kindergarten-teacher licence and a childcare-worker qualification?
A. Dual-holding is the principle (Ninteikodomoen Act, Article 15). However, a special measure lets either one qualify you, and by the 2024 amendment it was extended to the end of FY2029 (March 2030). The measure for a chief or instructional hoiku-kyoyu to serve with only one side runs only to the end of FY2026 (March 2027), so you must track who satisfies the dual qualification by when.
Q. Do short-hours part-time hoiku-kyoyu join social insurance?
A. If they work three-quarters or more of a regular worker's hours, they are insured. Even below three-quarters, they are insured if they meet 20-plus hours a week, a prospect of employment over two months, not being a student, and the employer's number of employees' pension insured persons being at a threshold (over 51 until September 2027, over 36 from October). The 88,000-yen monthly wage requirement was abolished on October 1, 2026. The final judgment is made by a qualified professional against the actual way of working.
Q. Can a shakai hoken roumushi do the procedures and accounting for the processing-improvement addition?
A. A shakai hoken roumushi handles the work and wage rules and the wage-ledger/attendance management needed to deliver the addition to staff as wages. The calculation of the addition amount, accounting and tax filing, and the performance-report figures themselves are the field of a tax accountant and the local guidelines. The approval/certification application is a gyoseishoshi's; each is contracted separately as an independent business entity.
Sources for this article
- Ninteikodomoen Act (認定こども園法, the Act on the Comprehensive Provision of Education, Childcare, etc. for Preschool Children, Act No. 77 of 2006), Article 15 (qualifications of staff). Chief/instructional hoiku-kyoyu, hoiku-kyoyu etc. are in principle to hold an ordinary kindergarten-teacher licence and be registered as a childcare worker (MEXT's explanation and the heading of the article; referenced October 28, 2026)
- Extension of the hoiku-kyoyu qualification measure. The 2024 amendment extended by five years, to the end of FY2029 (March 2030), the measure allowing either a kindergarten-teacher licence or a childcare-worker qualification; the one-side-only measure for chief/instructional hoiku-kyoyu was extended by two years, to the end of FY2026 (March 2027) (guidance of MEXT, the Children and Families Agency and prefectures; referenced October 28, 2026)
- Certification categories and times (Type 1 = standard education time; Type 2/3 = childcare standard time [up to 11 hours a day] / short childcare time [up to 8 hours a day]) are under the certification based on the Child and Childcare Support Act (municipal usage guidance; referenced October 28, 2026)
- Short-hours staff social insurance: insured where weekly scheduled hours and monthly scheduled days are three-quarters or more of a regular worker's. Below three-quarters, insured where meeting 20-plus hours a week, a prospect of employment over two months, not being a student, and the employer's employees' pension insured persons being at a threshold (over 51 until September 2027, over 36 from October 2027) (Health Insurance Act, Employees' Pension Insurance Act; Japan Pension Service guidance; referenced October 28, 2026)
- The wage requirement (monthly scheduled wage of 88,000 yen or more) was abolished from October 1, 2026 under the 2025 pension-system reform act (Act No. 74 of 2025) (Japan Pension Service notice; referenced October 28, 2026)
- The obligation to draw up and file work rules and their mandatory items, and working hours = Labor Standards Act, Article 89 (obligation to draw up and file work rules; absolute mandatory items), Article 32 (working hours) (confirmed against e-Gov on October 28, 2026)
This article does not go so far as to decide whom you should consult. The opening-hours and variable-working-hours shift design, management of hoiku-kyoyu dual-holding, the short-hours staff social and employment insurance test and procedures, and the work and wage rules matching the processing-improvement addition are the work of a shakai hoken roumushi. The approval/certification application and setting-up permits are a gyoseishoshi's, accounting and tax a tax accountant's, and premises a real-estate agent's; each is contracted separately as an independent business entity. 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 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).
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