What work can "Designated Activities No. 46" (graduates of Japanese universities) do? Scope of work, Japanese-language requirement, and the labour of employment

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
The "Designated Activities No. 46" status (graduates of Japanese universities) lets a foreign national who has graduated from a Japanese university or graduate school and has high Japanese ability (JLPT N1, or BJT 480 or more) work full-time in duties requiring smooth communication in Japanese. Work that is hard to allow under Engineer/Specialist in Humanities/International Services — customer service, store operation, on-site work — can be included if it requires Japanese communication and uses learning from university (not simple labour only). Employment is full-time, and pay must be equal to or above a Japanese national's. This article sets out, from a Shakai Hoken Roumushi's view, the scope of work, the language requirement, the care in employment contracts and notice of working conditions, and social/labour insurance, separating the eligibility judgment and the change-of-status application to a Gyoseishoshi (filing agent).
In short: The "Designated Activities No. 46" status (graduates of Japanese universities) lets a foreign national who has graduated from a Japanese university or graduate school and has high Japanese ability — JLPT N1 or a BJT Business Japanese Proficiency Test score of 480 or more — work full-time in duties requiring smooth communication in Japanese. Work that is hard to allow under Engineer/Specialist in Humanities/International Services (gijinkoku) — customer service, store operation, factory-floor work — can be included if it requires Japanese communication and uses knowledge and applied ability learned at university (simple labour only is not allowed). Employment is premised on full-time work, and pay must be equal to or above what a Japanese national in the same work receives. From a Shakai Hoken Roumushi's view, this article sets out the scope of work, the language requirement, the care in employment contracts and notice of working conditions, and social/labour-insurance enrolment, and separates the eligibility judgment and change-of-status application to a Gyoseishoshi (filing agent).
"We want to hire a graduate of a Japanese university in a role — including customer service — that is hard under gijinkoku," and "When hiring under Designated Activities No. 46, how do we handle notice of working conditions and social insurance?" — these are questions we often hear from HR and management. This page organises the labour design — employment contracts, notice of working conditions, social insurance — on the premise of full-time employment under No. 46. Judging whether the status applies, and the change-of-status application from "Student," is the domain of a filing-agent Gyoseishoshi (or attorney); this article focuses on the labour thinking.
How wide is the work you can do under Designated Activities No. 46?
Designated Activities No. 46 (graduates of Japanese universities) is a status based on the Immigration Services Agency's notice and guideline, and the work must satisfy all three elements below (Immigration Services Agency guideline; accessed 28 September 2026).
| Element | Content |
|---|---|
| Work using Japanese | Work requiring smooth communication in Japanese |
| Use of learning | Work using the broad knowledge and applied ability learned at a university or graduate school |
| Not simple labour | As a whole, not work engaging only in so-called simple labour |
Under this framework, work hard to allow under gijinkoku — customer service and store operation at restaurants and shops, hotel front desk, on-site handling combined with interpreting at a factory — can be done if it requires Japanese communication and uses learning. But a way of working that consists solely of simple labour — only washing dishes, only line work — is not allowed. The final judgment of which work applies is a question of eligibility for the status, confirmed with a filing-agent Gyoseishoshi (or attorney). For the working hours and social insurance of other Designated Activities such as a working holiday, see what are the working hours and social insurance for the "Designated Activities" status (working holiday, internship); for the timing of the switch from "Student" to work, see how do you align a new graduate's start date and change of status for former students.
How does it differ from Engineer/Humanities/International Services, and why can on-site work be included?
Gijinkoku and Designated Activities No. 46 differ in the breadth of allowed work and their basis. In labour, we design job content on this difference.
| Aspect | Engineer/Humanities/International Services | Designated Activities No. 46 |
|---|---|---|
| Basis | Appended Table I (2) of the Immigration Act | Ministry of Justice notice (Designated Activities for graduates of Japanese universities) |
| Education | University or specialist graduate, etc. (relevance to the work needed) | In principle graduation from a Japanese university or graduate school (expanded to certain advanced specialists by the 2024 reform) |
| Language requirement | No explicit unified standard | N1 or BJT 480 or more required |
| On-site work/customer service | In principle hard to allow | Can be included if it requires Japanese communication (simple labour only not allowed) |
The reason on-site work can be included is that No. 46 was created to let high-Japanese-ability graduates work across a wide range of duties centred on Japanese. Conversely, Japanese communication being the pillar of the work is a premise; simple labour only, without using Japanese, is not allowed. For hiring and status practice for Chinese and Taiwanese talent under gijinkoku, see what to watch in labour and status when hiring Chinese and Taiwanese talent under gijinkoku.
How do you meet the Japanese-language requirement (N1-equivalent, BJT, etc.)?
The Japanese-language requirement for No. 46 is met by one of the following (Immigration Services Agency guideline; accessed 28 September 2026).
- Passing JLPT N1
- Scoring 480 or more on the BJT Business Japanese Proficiency Test
- Certain cases, such as majoring in Japanese and graduating from a university or graduate school
At hiring, as a premise for the informal offer, you confirm the certificate/score and reflect it in the employment contract and internal job design. Because the language requirement is a question of status eligibility, the final judgment of whether it is met is confirmed with a filing-agent Gyoseishoshi (or attorney). On the labour side, you build a structure where, given the Japanese ability, work instructions and dissemination of work rules reliably reach the person. For how to divide consultation on foreign employment, see how do you divide consultation on foreign employment.
What care is needed in the employment contract and notice of working conditions for a foreign national?
No. 46 is premised on full-time direct employment; dispatch is in principle not contemplated. The labour points to grasp are as follows.
| Issue | Content |
|---|---|
| Notice of working conditions | Under Article 15 and Enforcement Ordinance Article 5, state wages, hours, place of work, the work to be engaged in, etc., in writing |
| Care for the native language | Under the MHLW "Guidelines on improving employment management of foreign workers," endeavour to state conditions in a way the person understands (native language, plain Japanese, etc.) |
| Level of pay | Equal to or above what a Japanese national in the same work receives (also a status requirement) |
| Scope of place/work | Reflecting the items added from April 2024, also state the scope of change of place of work and of the work |
| Notice of foreign employment status | Under Article 28(1) of the Labor Policy Comprehensive Promotion Act, notify hiring/separation to Hello Work |
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Pay equal to or above is both a status requirement and the core of working conditions. Being able to show objectively, via the wage ledger and wage regulations, whether it is equal to a Japanese national keeps the status application and the labour consistent. For proving equal pay and writing the notice of working conditions for a foreign national, see how do you prove equal pay for a foreign national and write it in the notice of working conditions; for native-language notice of working conditions, see how far is native-language notice of working conditions needed for a foreign national.
Social/labour-insurance enrolment, and whom do you send the status application to?
Under full-time employment on No. 46, social/labour-insurance enrolment is judged by the same thinking as for a Japanese national.
- Health insurance and employees' pension: As long as regularly employed at an applicable establishment, one becomes insured regardless of nationality or status (Health Insurance Act, Employees' Pension Insurance Act). Full-time employment is normally covered
- Employment insurance: Insured with 20 or more prescribed weekly hours and an employment prospect of 31 days or more (expanding to 10 or more weekly hours from October 2028). Full-time is normally covered
- Workers' accident insurance: Applies once even one worker is hired, regardless of nationality or status
On that basis, who decides divides. Separating the roles and entrusting each to its professional is safer.
| What is done | Whose domain |
|---|---|
| Employment contracts, work rules, wage regulations, notice of working conditions, social/labour-insurance enrolment, notice of foreign employment status | Shakai Hoken Roumushi (四葉社会保険労務士事務所) |
| Judging status eligibility; filing the change of status from "Student" and the extension of stay | Filing-agent Gyoseishoshi (四葉行政書士事務所) or attorney |
| Income tax on wages and year-end adjustment | Tax accountant |
| Labour disputes and dismissal disputes | Attorney |
四葉社会保険労務士事務所 and 四葉行政書士事務所 are independent business entities. Labour goes to the Shakai Hoken Roumushi and the status filing to the Gyoseishoshi, so you contract with each separately — a separate-engagement arrangement. No referral fees are exchanged. For foreign-employment labour, see labour management for foreign employment. Consultation is free. For fees, see the fee schedule; for FAQs, see the FAQ.
FAQ
Q. Under No. 46, can we have them do restaurant customer service or factory floor work?
A. If the work requires smooth communication in Japanese and uses the knowledge and applied ability learned at university, work including customer service and the floor can be done. But a way of working consisting solely of simple labour without using Japanese is not allowed. Which work applies is a question of status eligibility, confirmed with a filing-agent Gyoseishoshi (or attorney).
Q. How much Japanese ability is needed?
A. Passing JLPT N1, or a BJT Business Japanese Proficiency Test score of 480 or more, is needed. Certain cases, such as majoring in Japanese and graduating from a university or graduate school, are also allowed (Immigration Services Agency guideline; accessed 28 September 2026). The final judgment of whether it is met is confirmed with a filing-agent Gyoseishoshi (or attorney).
Q. Can we hire on a part-time or dispatch basis?
A. No. 46 is premised on full-time direct employment; dispatch is in principle not contemplated. Pay must also be equal to or above what a Japanese national in the same work receives. Whether the employment form fits the requirements is confirmed from both the working-conditions design and status eligibility.
Q. Can the status application and the labour be entrusted to the same person?
A. Because the governing laws differ, they are considered separately. Judging status eligibility and filing the change of status are for a filing-agent Gyoseishoshi (or attorney); employment contracts, notice of working conditions and social insurance are for a Shakai Hoken Roumushi. At Yotsuba, 四葉行政書士事務所 and 四葉社会保険労務士事務所 are independent business entities, dividing the work under separate contracts.
Sources
- The Ministry of Justice notice defining Designated Activities for graduates of Japanese universities (so-called No. 46) (Ministry of Justice Notice No. 37 of 2019). Specifics such as education, the language requirement, the scope of work and the level of pay were confirmed with the Immigration Services Agency "Guideline on the 'Designated Activities' for employment support of international students (graduates of Japanese universities, etc.)" (accessed 28 September 2026). The 2024 reform expanded the scope to certain graduates of authorised specialist-training-college programmes (advanced specialists), but the details of the scope are confirmed in the latest version of that guideline
- Labor Standards Act (Act No. 49 of 1947), Article 15 (notice of working conditions), Enforcement Ordinance Article 5 (items to state, including the scope of change of place of work and of work added from April 2024)
- MHLW "Guidelines on improving employment management of foreign workers" (endeavour to state conditions in a way the person understands, etc.; accessed 28 September 2026)
- Act on Comprehensively Advancing Labour Policies, and Stabilising the Employment of Workers and Enriching Their Working Lives (formerly the Employment Countermeasures Act), Article 28(1) (notice of foreign employment status)
- Health Insurance Act (Act No. 70 of 1922), Employees' Pension Insurance Act (Act No. 115 of 1954) (insured status for those regularly employed at an applicable establishment), Employment Insurance Act (Act No. 116 of 1974) (insured with 20 or more weekly hours and 31 days or more; expanding to 10 or more weekly hours from October 2028 by Act No. 26 of 2024), Workers' Accident Compensation Insurance Act (Act No. 50 of 1947) (applies regardless of nationality or status)
- The details of No. 46's notice number and effective date, and individual judgments on eligible education and work applicability, can change with reform, so this article avoids asserting them and treats them as points to confirm with the Immigration Services Agency's latest guideline and with a qualified filing agent (unverified)
This article does not decide whom to consult. Employment contracts, notice of working conditions, social/labour-insurance enrolment and the notice of foreign employment status are the work of a Shakai Hoken Roumushi. Judging status eligibility and filing the change of status are for a filing-agent Gyoseishoshi (or attorney); tax on wages for a tax accountant; labour disputes for an attorney. 四葉行政書士事務所 and 四葉社会保険労務士事務所 are independent business entities, contracted separately.
This article is general information. A judgment on individual circumstances is made by a qualified professional after a consultation. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).
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