Employing an international student — how do you count the 28 hours a week?

In short: part-time work by international students is limited by the permission for activities outside the residence status to 28 hours per week (Regulation for Enforcement of the Immigration Control Act, Article 19, paragraph 5, item 1; during long school holidays set by the institution's rules, 8 hours per day). The permission is an immigration institution, but counting and keeping the hours is labour management. The hard part: hours worked at other employers are invisible to your company.

This page is for owners, store managers and back-office staff employing international students part-time. It is written not about obtaining the permission but about managing the hours after the hire.

What counts toward the 28 hours?

Three points can be confirmed in the provision itself (Regulation for Enforcement of the Immigration Control and Refugee Recognition Act, Article 19, paragraph 5, item 1):

• 28 hours per week; during long holiday periods set by the educational institution's rules, 8 hours per day
• Limited to work while enrolled at the institution (after graduation or withdrawal, the premise changes)
• Work at adult-entertainment establishments is outside the permission

The finer points of counting — where the week starts, how multi-employer hours are aggregated — follow the Immigration Services Agency's guidance and case-by-case practice. The one principle to hold on to: 28 hours means the person's total, not your company's share. Two jobs at 15 hours each look lawful to each employer — and the student is over.

How do you learn about work at other employers?

What you cannot see, you must build a reporting system for, in advance. Three practical pieces:

Mechanism	Substance
Checks at hiring	Confirm the activity permission on the residence card, and have the student declare in writing whether and how many hours they work elsewhere
A duty to report changes	Put into the contract or service rules a duty to report when other work starts or its hours change
Shift caps by design	Do not build your shifts up to the full 28 hours; many companies cap in the low twenties to leave room for the other job

Reporting is never perfect. That is exactly why a record that the company did its checking — the written declaration at hiring, periodic confirmations — becomes the seawall against the risk below.

Does employment insurance apply?

Daytime students are, in principle, not employment insurance insured (Employment Insurance Act, Article 6, item 4). Ministerial order defines cases that are insured — students on leave of absence, evening-course students and others — so check individually where they might apply.

Meanwhile, the foreign worker employment status notification is required even for student part-timers outside employment insurance (Form 3, by the end of the following month — see Hired a foreign worker? Notify Hello Work). And the expanded social insurance coverage for short-hours workers carries a "not a student" condition (see Hire for short hours, and what happens to social insurance?). "A student, so no paperwork" is wrong on both counts.

What happens if the hours are exceeded?

On the student's side, work in breach of the permission's conditions can affect renewal of the residence status (the individual outcomes are immigration territory). On the company's side sits the offence of promoting illegal work (Immigration Control Act, Article 73-2: up to three years' imprisonment or a fine of up to three million yen, or both). Paragraph 2 provides that not knowing is no defence (unless without negligence). "We didn't know about the other job" does not end the matter — which is precisely why the checking system and its records in the previous section carry weight.

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, builds the hiring-check forms for student part-timers, designs the other-employer reporting rules (contracts and service rules), designs shift caps, and files the employment status notifications. Consultation is free of charge. Fees are in the fee schedule; the whole flow of foreign employment is in Hire one foreign employee — how many counters do you need?.

Whom to consult

Applications for the activity permission and residence-status changes or renewals go to 四葉行政書士事務所 (a separate business from this office, engaged under a separate contract). Tax is for a tax accountant; matters already in dispute for an attorney. No referral fees change hands.

Frequently asked questions

Q. We only give 20 hours a week of shifts. Can there still be a problem?
A. Yes. The 28-hour limit applies to the person's total hours, so with another job the student can be over even though your shifts are modest. You need declarations at hiring and periodically to capture the other employer's hours.

Q. How many hours during the summer holiday?
A. During long holiday periods set by the institution's rules, up to 8 hours per day (Regulation, Article 19, paragraph 5, item 1). Whether a period falls under the school rules is the test — check the institution's academic calendar.

Q. Is the Hello Work notification needed for student part-timers too?
A. Yes. Where the student is not an employment insurance insured, file Form 3 by the end of the month following the hire or separation. Non-filing or false filing carries a fine of up to 300,000 yen (Act on Comprehensive Promotion of Labour Measures, Article 40, paragraph 1, item 2).

Q. How do we confirm the activity permission?
A. On the back of the residence card (the permission field), and where needed the designation slip. Employing a student without the permission is an illegal-work problem regardless of hours. Applying for the permission itself is gyoseishoshi territory (四葉行政書士事務所 — a separate business).

Sources for this article

• Regulation for Enforcement of the Immigration Control and Refugee Recognition Act (出入国管理及び難民認定法施行規則, Ministry of Justice Order No. 54 of 1981), Article 19, paragraph 5, item 1 (28 hours per week; 8 hours per day in long holidays; while enrolled; adult-entertainment exclusion) — current text confirmed on e-Gov on 14 August 2026
• Immigration Control and Refugee Recognition Act (出入国管理及び難民認定法, Cabinet Order No. 319 of 1951), Article 73-2 (promoting illegal work; paragraph 2 — ignorance no defence unless without negligence) — confirmed the same day
• Employment Insurance Act (雇用保険法, Act No. 116 of 1974), Article 6, item 4 (student exclusion; insured exceptions per ministerial order) — confirmed the same day
• 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 and Article 40, paragraph 1, item 2 — confirmed the same day
• The finer counting rules (week start, multi-employer aggregation) follow the Immigration Services Agency's guidance; check the latest guidance for individual cases

This article is general information and does not enter individual immigration judgments such as effects on residence status. 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).