Working hours and social insurance for the "Designated Activities" status (working holiday and internship)
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" residence status is one where whether a person can work differs from individual to individual. What they can actually do is confirmed by the "designation document" attached to the passport. Working holiday participants can work (some fields such as adult-entertainment businesses are not allowed), and there is no uniform hour cap like the students' "up to 28 hours a week." Workers' accident compensation insurance applies regardless of nationality or residence status; employment insurance and social insurance apply if their respective insured-person requirements are met.
In short: The "Designated Activities" residence status is one where whether a person can work differs from individual to individual. What they can actually do is confirmed by the "designation document" (shiteisho) attached to the passport. Working holiday participants can work, but some fields such as adult-entertainment businesses are not allowed. There is no uniform hour cap like the students' "up to 28 hours a week."
Working hours and the treatment of social and labor insurance are, once work begins, considered within the same framework as for Japanese workers. Workers' accident compensation insurance applies to workers regardless of nationality or residence status, and employment insurance, health insurance, and employees' pension insurance apply if their respective insured-person requirements are met. On the other hand, whether the person can work under "Designated Activities" at all, whether a permission to engage in activity other than that permitted is needed, and whether a change or renewal of residence status is required, are judgments on residence status under the Immigration Control Act and are the business of a Gyoseishoshi. 四葉行政書士事務所 is a separate, independent entity from our office and is contracted separately (we do not take on both under one engagement).
For business owners who employ working-holiday or Designated Activities foreign nationals for short-term or seasonal work, this article organizes, from the viewpoint of a Shakai Hoken Roumushi, how the possibility of working is decided, working hours, the application of workers' accident, employment, and social insurance, and procedures upon returning home.
What decides whether you can work under "Designated Activities"?
"Designated Activities" is a residence status set out in Appended Table 1-5 of the Immigration Control Act, under which the Minister of Justice specifically designates the activity for each individual foreigner. Many of the types are set by notification (Ministry of Justice Notification No. 131 of 1990 and others), and activities of entirely different nature—working holiday, paid internship, job hunting after graduation, domestic workers of highly skilled professionals, and so on—are included in the same "Designated Activities."
For that reason, you cannot say uniformly that "Designated Activities means you can/cannot work." What a specific person can do is written in the "designation document" attached to the passport. Some activities allow work, and some do not. Before hiring, be sure to check not only the residence card but also the content of the designation document.
| What to check | What to look at |
|---|---|
| Residence card | That the status is "Designated Activities"; the period of stay |
| Designation document (attached to passport) | The content of the designated activity; whether work is allowed; the scope |
| Permission to engage in other activity | May be required to work outside the activity in the designation document |
Whether the residence status applies, whether a permission to engage in other activity is needed, and the application for a change or renewal of residence status (including the application-agency service) are the business of a Gyoseishoshi. If there is any doubt about whether the person can work at all, check before hiring. The "notification of employment status of foreign nationals" is required for every residence status. For details, see when you hire a foreign national, a notification to Hello Work is required.
Is there a cap on working hours for a working holiday?
A working holiday is a system that allows young people from a partner country/region with which an agreement has been concluded to stay in Japan with a holiday as the main purpose and to work to supplement their travel funds. In that work is permitted, the treatment differs from students' part-time work.
- No uniform hour cap: unlike the students' permission to engage in other activity, a working holiday has no uniform cap of "up to 28 hours a week." The types of jobs and the way of working are relatively free.
- There are jobs you cannot do: some industries and work, such as work involving adult-entertainment businesses, are not allowed. Check the designation document and related laws.
- The Labor Standards Act applies the same as for Japanese workers: overtime pay is required for work over 8 hours a day or 40 hours a week, and rules on breaks, days off, minimum wage, and annual paid leave also apply as they are.
- A holiday remains the main purpose: the intent of the system is "a stay with a holiday as the main purpose."
For the 28-hour management of students' part-time work, see students' part-time work is up to 28 hours a week. How does a company manage it. A big difference is that a working holiday is not subject to this 28-hour cap. Working conditions must be disclosed in writing as an employer's obligation. See also disclosure of working conditions is also required for foreign workers. What changed from 2024.
Do workers' accident and employment insurance apply under Designated Activities too?
The application of labor and social insurance is judged not by the type of residence status but by "whether the person is a worker" and "whether they meet the insured-person requirements." The possibility of enrollment does not change with nationality or the presence or absence of a residence status.
| Insurance | How application is considered (the same under Designated Activities) |
|---|---|
| Workers' accident insurance | Compulsorily applies to any business that employs even one worker. Applies to a worker regardless of nationality or residence status |
| Employment insurance | An insured person if they meet 20 or more prescribed weekly hours (10 or more from October 2028) and expected employment of 31 days or more. Daytime students are excluded |
| Health insurance / employees' pension | Enroll if ordinarily employed at an applicable workplace and meeting the three-quarters rule, etc. (next section) |
- Workers' accident insurance may cover a person as a worker in substance, even if there was a problem with the permission to work under the residence status. Work-related injury or illness may be covered even after returning home. For the treatment of workers' accident after returning home, see what happens to compensation when a foreign worker has a work accident and returns home.
- Employment insurance makes a person an insured person under Designated Activities too if they meet the insured-person requirements. However, working-holiday participants often work short-term or across multiple jobs and may not meet "expected employment of 31 days or more," in which case they do not become insured persons. For the expansion to 10 weekly hours from October 2028, see employment insurance coverage expands to 10 or more weekly hours from October 2028.
How does enrollment in health insurance and employees' pension work?
Health insurance and employees' pension insurance also apply regardless of nationality or residence status: enroll if ordinarily employed at an applicable workplace and, for part-timers, meeting requirements such as the "three-quarters rule."
- Three-quarters rule: if prescribed weekly working hours and prescribed monthly working days are at least three-quarters of those of a regular worker, the person is in principle subject to enrollment. For the basics of the judgment, see what happens to social insurance when you hire someone for short hours.
- Often not applicable for short-term/short-hour work: working-holiday participants and interns often work short-term or short hours and may not meet the enrollment requirements.
- Avoiding double enrollment via social security agreements: to avoid "double enrollment" in the pension systems of both the home country and Japan, a person from a country with a social security agreement may, through certain procedures, be limited to one system. For details, see social security for people who come from abroad to work: double enrollment and social security agreements.
The final decision on whether to enroll is made individually by the pension office and the Japan Health Insurance Association (or a health insurance society). When in doubt about the judgment, gather the employment contract, work rules, and attendance records to check.
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What procedures apply upon returning home or at the end of the period of stay?
Designated Activities has a set period of stay, and some cannot be renewed or have a cap on the number of renewals. Toward returning home or the end of the period of stay, check the following on the labor side.
- Loss-of-qualification procedures: on resignation, submit the employment insurance loss-of-qualification notification and the health insurance and employees' pension loss-of-qualification notifications.
- Lump-sum withdrawal payment: a person who has an insured period of, in principle, six months or more under employees' pension or the National Pension and returns home without the right to receive a pension may be able to claim a lump-sum withdrawal payment within two years after loss of qualification (in principle after leaving Japan). For the flow, see when a foreign employee returns home, how is the pension settled.
- The relationship between the period of stay and employment: you cannot have someone work beyond the period of stay. A change or renewal of residence status is the business of a Gyoseishoshi. The labor side is responsible for managing the period of stay and the insurance procedures upon resignation and returning home.
四葉社会保険労務士事務所 can advise on sorting out the application of labor and social insurance, notifications of qualification acquisition and loss, maintaining employment contracts and work rules, and the payroll and attendance management system. Whether the residence status applies, the permission to engage in other activity, and the change application (application-agency service) can be connected to 四葉行政書士事務所 (a separate, independent entity from our office, contracted separately), but on the premise that the Shakai Hoken Roumushi work and the Gyoseishoshi work are contracted separately; we do not take on both under one engagement. Payroll taxation and tax treaties are the domain of a tax accountant. Consultation is free, and fees are summarized in the fee schedule.
Frequently asked questions
Q. Can everyone with "Designated Activities" work?
A. No. Designated Activities differs in content from person to person, and some activities allow work while some do not. What a person can actually do is written in the "designation document" attached to the passport. Before hiring, check both the residence card and the designation document. The judgment on whether work is possible at all is the business of a Gyoseishoshi.
Q. Is there a working-hours cap for a working holiday, like the 28 hours a week?
A. No. The 28-hour cap is a system for the students' permission to engage in other activity and does not apply to a working holiday. However, some industries such as those involving adult-entertainment businesses are not allowed, and the Labor Standards Act (8 hours a day / 40 hours a week, overtime pay, minimum wage, annual paid leave, etc.) applies the same as for Japanese workers.
Q. Even for a short-term working holiday, can workers' accident insurance be used?
A. Workers' accident insurance compulsorily applies to any business that employs even one worker and applies to a worker regardless of nationality or residence status. Therefore, even for a short-term working holiday, work-related injury or illness may be covered. For employment insurance and social insurance, whether a person enrolls depends on whether they meet the respective insured-person requirements (employment prospects, prescribed working hours, etc.).
Q. When returning home, is the pension I paid refunded?
A. A person who has an insured period of, in principle, six months or more under employees' pension or the National Pension and returns home without the right to receive a pension may be able to claim a lump-sum withdrawal payment within two years after loss of qualification (in principle after leaving Japan). Check the amount and the claim method in the Japan Pension Service guidance.
Sources
- Residence status "Designated Activities": Immigration Control and Refugee Recognition Act, Appended Table 1-5 (activities specifically designated by the Minister of Justice for each individual foreigner). The types are set by the Designated Activities notification (Ministry of Justice Notification No. 131 of 1990 and others) and include working holiday, paid internship, and others. The content of each individual's activity and whether work is allowed are confirmed by the "designation document" attached to the passport (Immigration Services Agency / Ministry of Justice, referenced 2026-09; the notification item numbers have been reorganized and some are vacant, so confirming by the designation document is the reliable way).
- Work under a working holiday: a system that allows work during a stay with a holiday as the main purpose. There is no uniform cap of 28 hours a week like the students' permission to engage in other activity, and some industries involving adult-entertainment businesses are not allowed (Immigration Services Agency guidance, referenced 2026-09; confirm the industries and scope by the designation document and related laws).
- Application of the Labor Standards Act: working hours, overtime pay, minimum wage, annual paid leave, etc. apply regardless of residence status (Labor Standards Act).
- Application of workers' accident insurance: compulsorily applies to a business that employs workers and applies to a worker regardless of nationality or residence status (Industrial Accident Compensation Insurance Act; Ministry of Health, Labour and Welfare, "To business owners who employ foreign nationals," referenced 2026-09).
- Employment insurance insured-person requirements: 20 or more prescribed weekly hours (10 or more from October 2028 (Reiwa 10) under Act No. 26 of 2024) and expected employment of 31 days or more. Daytime students are excluded in principle. Regardless of nationality or residence status (Employment Insurance Act / Ministry of Health, Labour and Welfare guidance).
- Application of health insurance and employees' pension: a person ordinarily employed at an applicable workplace is an insured person regardless of nationality or residence status. Part-timers enroll in principle if their prescribed working hours and days are at least three-quarters of those of a regular worker (Health Insurance Act, Employees' Pension Insurance Act; Japan Pension Service).
- Social security agreements: to prevent double enrollment, a person from an agreement partner country may be able to adjust the system to which they enroll through certain procedures (Japan Pension Service).
- Lump-sum withdrawal payment: if a person has an insured period of, in principle, six months or more under employees' pension or the National Pension and returns home without the right to receive a pension, they may be able to claim within two years after loss of qualification (in principle after leaving Japan) (Japan Pension Service).
- Notification of employment status of foreign nationals: required for all foreign workers regardless of residence status, except for diplomatic and official statuses (Labor Measures Comprehensive Promotion Act; Ministry of Health, Labour and Welfare).
- Business of a Shakai Hoken Roumushi: Article 2 of the Certified Social Insurance and Labor Consultant Act.
This article does not decide whom to consult. 四葉社会保険労務士事務所 can advise on sorting out the application of labor and social insurance, notifications of qualification acquisition and loss, maintaining employment contracts and work rules, and the payroll and attendance management system. The application and change of residence status (application-agency service) are the business of a Gyoseishoshi, payroll taxation and tax treaties are the business of a tax accountant, and labor disputes are the business of an attorney. The Shakai Hoken Roumushi work and the Gyoseishoshi work are contracted separately as separate, independent entities. Our office does not receive referral fees. The final decision on whether labor and social insurance apply to an individual foreign national is made by the pension office, the Labor Standards Inspection Office, and Hello Work. For fees when consulting 四葉社会保険労務士事務所, see the fee schedule; for frequently asked questions, see the FAQ.
This article is general information. Whether the system applies and individual enrollment decisions are made by a qualified professional after a consultation, in light of the latest primary sources (the Immigration Services Agency, the Ministry of Health, Labour and Welfare, the Japan Pension Service, etc.) and individual circumstances. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).
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