Three of the twelve providers in our EOR and payroll directory hold a Japanese worker dispatch licence, granted in 2018, 2021 and 2023 and checked against the government register on August 17, 2026. Several providers in the same market state that no licence is required in Japan, and the pages making that claim cite no statute.
Disclosure before going further: AirTA sells no employer-of-record service and is not a recruitment agency.
Where an Employer of Record Fits in Japanese Law
Japanese law contains no employer-of-record category. It recognises three structures for placing a worker under another company's direction, and which one applies turns on who directs the work rather than what the contract is called. No Japanese court has ruled on the model.
The three structures are worker supply (労働者供給), contracting (請負), and licensed worker dispatch (労働者派遣). The Employment Security Act defines worker supply in Article 4 as "having a worker work under the direction and orders of another person based upon a supply contract, and does not include anything that constitutes worker dispatch". Direction is the operative term, and dispatch is excluded from the definition by name.
Article 44 of the same act reads:
"It is prohibited for any person to provide the worker supply services or to have a worker who has been supplied by a person providing the worker supply services work under the directions or orders of the person to which the worker has been supplied, except in the cases provided for in the following Article."
Worker dispatch is licensed separately, under the Worker Dispatch Act and by the Ministry of Health, Labour and Welfare.
Practitioners describe the same distinction. The ICLG Corporate Immigration 2026 Japan chapter states that most work-type statuses allow employees to work at client sites if the visa sponsoring company pays the employee directly, and that "with a worker dispatching a service licence by the MHLW, they can also work under the supervision of the client".
A company hiring in Japan without an entity is using one of these three structures whether or not its contract names any of them.
What the Providers State and What the Lawyers Write
Provider pages name the Labor Contract Act as the governing law and stop there, without a ministry document, a court decision, or a register entry behind the assertion.
The practitioner literature answers with citations. The ICLG Corporate Immigration 2026 Japan chapter, contributed by RSM Shiodome Partners and Nakai Immigration Services, addresses it under a question naming the model directly:
Q4.14 Are Employers of Record (EORs) or Professional Employer Organisations (PEOs) permitted to act as the sponsoring employer in your jurisdiction?
"There are no provisions in the Immigration Control and Refugee Recognition Act regulating EOR and PEO, and neither is expressly permitted. In principle, sponsoring companies must give instructions to workers unless they have a dispatch business licence. As a visa sponsor, they are also responsible for the job content, etc. that they declare to the Immigration Bureau. If there is a discrepancy between the application and the actual activities, they may be subject to penalties for false application."
The two classes of source disagree. One names the acts, the licence, and the consequence of a mismatch between the application and the actual work. The other names none of them.
What the Licence Register Shows
The Ministry of Health, Labour and Welfare publishes both staffing registers, one for worker dispatch and one for fee-charging placement (有料職業紹介), and four of the twelve providers in our EOR and payroll directory appear on them, carrying six licences between them.
Both registers searched on August 17, 2026 across all 47 prefectures. The site's own data stamp on each entry reads August 1, 2026. Listing on this register has operator-initiated elements, so it records what an operator has filed rather than everything that exists.
Pebl's Japan entity is still registered under its former name, Velocity Global Japan GK, so a search on the current brand returns nothing useful.
Corporate registration and licence checks for the providers in this category are listed on the EOR and payroll provider directory.
Only One Agency Has Acted
No Japanese court decision naming an employer-of-record arrangement was found. No ministry has published guidance on the model, and no enforcement action was located. The public record contains neither an approval nor a prohibition.
The Immigration Services Agency has published a notice on work in dispatch form under the Engineer, Specialist in Humanities and International Services status. For applications filed from March 9, 2026, the client company must be fixed at the time of application, and the period of stay is set according to the dispatch contract period. The global immigration law firm Fragomen reads that regime as covering "dispatch arrangements, including Employer of Record arrangements"; the notice itself does not use the term.
That is the only dated document on this question. If you are weighing how long to stay on a provider's contract before hiring your first employee in Japan, this is a firmer source than a provider's own page.
This is a record of what public sources state as of August 17, 2026, and not legal advice.
How to Check an Employer of Record on the Register
The search takes about ten minutes and needs no Japanese beyond copy and paste.
- Open the MHLW staffing-licence register and pick one of the two. Worker dispatch and placement are separate searches.
- Search on the EOR provider's registered Japanese entity name rather than its brand name. The National Tax Agency corporate-number registry gives you the exact name.
- Enter that name in full-width characters. Half-width letters return nothing, which is the most common reason a search appears empty.
- Open the detail page for any hit. It shows the licensed entity, the licence number, the grant date in Japanese era format, and the date the register data was compiled.
Deel, Remote, Oyster and Multiplier each have a registered Japanese entity, confirmed by a single exact match in the National Tax Agency corporate-number registry on August 17, 2026.
Run against the exact registered names, a search of both registers returned no entry for Deel Japan KK, Remote Japan KK, Oyster HR Japan GK or Multiplier Technologies KK as of August 17, 2026. The same search run against GoGlobal and Globalization Partners Japan returned the licences in the table above, which is how you know the search works.
The rest of the answers come from the provider. Put these five questions in writing at renewal:
- Which structure does our arrangement use: licensed worker dispatch, contracting, or secondment (在籍型出向)?
- If dispatch, which entity employs our people and what is its licence number?
- Under the contract as written, who gives the employee day-to-day instructions?
- For any visa filed since March 9, 2026, which company was named as the client?
- Which entity appears as employer on the employment contract and on the social insurance enrolment?
Renewal is when those questions are cheapest to ask, because a provider negotiating a further year will put in writing what a provider mid-contract may not. Whichever way this question is settled, the structure your employer-of-record contract uses and the entity that employs your people are facts you can record now, dated, in your own file. There is still a role to fill, which is where Japan market entry hiring begins.