For applications filed from March 9, 2026, Japan's Immigration Services Agency will not approve an Engineer, Specialist in Humanities and International Services (技術・人文知識・国際業務) visa application for work in dispatch form (派遣形態) unless the client company is fixed at application. The period of stay is set according to the dispatch contract period. The immigration law firm Fragomen reads that regime as covering "dispatch arrangements, including Employer of Record arrangements"; the notice does not use that term.
Disclosure before going further: AirTA sells no employer-of-record service and is not a recruitment agency.
Can an Employer of Record Sponsor a Visa in Japan
The Immigration Services Agency has published a notice on work in dispatch form under the Engineer, Specialist in Humanities and International Services status of residence, and it governs applications filed from March 9, 2026. Fragomen, an immigration law firm, reads that regime as covering "dispatch arrangements, including Employer of Record arrangements". The notice does not use the term employer of record.
The application turns on two companies. The dispatching company employs the person and files the documents. The client company, where the work is performed, must be fixed at the time of application and signs a pledge of its own.
Japanese practitioner offices writing on the change describe it as a dispatch matter, and none of them uses the term employer of record. A search of the notice's full text returns no occurrence of the term in English or in Japanese.
The statutes behind the arrangement and the providers on the staffing registers are covered in what the statutes and the licence register show. Whether the arrangement is the right route is a different decision, worked through in hiring in Japan without an entity.
What the Notice Lists at Application
The notice lists what a visa application must contain, and the client company is one of the named parties.
For applications filed from March 9, 2026, the notice on work in dispatch form states that an application cannot be approved unless the client company is fixed at the time of application. The notice provides a narrow exception where the client cannot be decided until after post-hire training. It lists the individual dispatch contract (労働者派遣個別契約書) among the submission documents. It lists a pledge (誓約書) from the dispatching company and a separate pledge for client use.
Fragomen, whose reading connects the regime to employer-of-record arrangements, describes those pledges as covering document accuracy, understanding of the permitted scope of activities, strict adherence to the authorized activities, and full cooperation, "including by providing additional documentation upon request, participating in interviews and permitting on-site inspections".
The notice also states that the agency may confirm the applicant's duties and activities directly with the client company as well as with the dispatching company.
Transcribed from the Immigration Services Agency notice on work in dispatch form under the Engineer, Specialist in Humanities and International Services status of residence, document dated July 2026, read on August 17, 2026. The notice does not use the term employer of record; the reading that it covers employer-of-record arrangements is Fragomen's. The notice is published in Japanese, and the English wording is our paraphrase.
What Changes at Renewal and How Long the Visa Runs
The length of the visa follows the length of a commercial contract. The notice states that where a person works in dispatch form, the period of stay is determined according to the dispatch contract period.
Takanori Ishinagi, a certified immigration agent in Osaka, writes that under the new operation a short contract cycle with the client company, such as a three-month renewal, will in principle produce the shortest one-year period of stay, because repeated short-term contracts are evaluated as "lacking stability of residence". That is his office's reading of how the provision is applied in practice rather than text from the notice.
At renewal, the notice lists the dispatching and client management records and the work status report. These are records kept under the Worker Dispatch Act, and each company holds its own.
Each pledge form states that if the pledge is false or breached, applications from foreign nationals with that company as their employer, including the one being filed, may not be granted. Where the client pledge is deferred under the training exception and then not produced at renewal, the notice states that this counts as a negative factor in future examinations.
What Provider Pages Say About Sponsorship
Public stances on visa sponsorship differ across providers in this category, and one provider's own pages differ from each other. Some state that sponsorship is handled where the provider holds a Japanese entity, one states that it is not offered in Japan, and others do not address it at all.
Provider pages in this category published or updated after March 9, 2026 do not mention the notice. One was updated in July 2026, four months after the rule took effect. A Japan visa-sponsorship page written for employers was published on March 30, 2026, three weeks after the rule took effect, with a section on this arrangement and no reference to the notice.
What each provider's own Japan entity shows on the public registers is recorded in the EOR and payroll provider directory.
What to Put in Writing With Your Provider
Every requirement above is answerable with a document or a date. These are the documents the notice lists, so for a given employee they exist or they do not.
- Can we have a copy of the pledge filed for this employee, and a copy of the one filed for us as the client company?
- What does the client pledge commit us to, and who at our company signs it?
- What is the end date of the dispatch contract behind this visa, and what period of stay was granted against it?
- Which entity holds the management records and the work status report that a renewal calls for, and can we see ours?
This is a record of what public sources state as of August 17, 2026, and not legal advice.
The provider files the application and holds the dispatch contract term and the period of stay granted against it. None of this arises for a candidate already in Japan who holds their own work authorization and is hired directly, and finding that candidate is where Japan market entry hiring begins.