Reviewed by: Yuki Ando, Certified Immigration Legal Specialist (Gyoseishoshi)
This article is a translation of the original Japanese version.
With ongoing revisions to the system and its implementation guidelines, many on-site supervisors are uncertain—wondering, for example, “Which tasks can be legally delegated?” or “Could we unknowingly be engaging in unauthorized employment?”
This article provides a clear overview—based on official government resources—of the main and related duties permitted under the Specified Skilled Worker (Caregiving) visa, examples of activities that may be deemed unauthorized employment, and key practical points to be aware of.
If you’re looking to strengthen your understanding of the system and make informed decisions in the workplace, this guide will be a valuable resource.
Table of Contents
Scope of Work Permitted Under the Specified Skilled Worker (Caregiving) Visa
The Specified Skilled Worker (Caregiving) visa was established to accept foreign workers who can contribute immediately to the caregiving field.The Specified Skilled Worker system is divided into two categories: Type 1, for individuals with a certain level of knowledge and skills, and Type 2, for those with advanced expertise. However, in the caregiving sector, only Type 1 is applicable.
This is because individuals who obtain national certification as certified care workers (Kaigo Fukushishi) are eligible for a higher-level residency status known as the “Caregiver” visa.
In the following section, we will explain the primary duties that can be performed under the Specified Skilled Worker (Caregiving) visa.
Primary Duties
The primary duties permitted under the Specified Skilled Worker (Caregiving) visa include a range of personal care services tailored to the physical and mental condition of the care recipient, such as bathing, feeding, toileting, grooming, dressing, and mobility assistance.These tasks involve direct physical support to help individuals maintain their daily lives and play a central role in caregiving settings.
In addition, activities such as leading recreational programs and assisting with physical rehabilitation exercises are also recognized as part of these core caregiving duties.
This type of personal care is provided using specialized knowledge and techniques, with the goals of improving quality of life, promoting independence, and preventing the progression of physical or cognitive decline.
Related Duties
Examples of related duties under the Specified Skilled Worker (Caregiving) visa include tasks such as managing posted notices and handling the replenishment and inventory control of supplies.These duties are permitted when they are performed in conjunction with the main caregiving tasks, in the same manner as Japanese staff working at the facility.
However, being assigned exclusively to these related duties is not allowed under the system.
Therefore, such tasks must always be carried out in combination with core caregiving responsibilities.
What Proportion of Related Duties Is Permitted?
Under the Specified Skilled Worker (Caregiving) visa, individuals are not permitted to engage exclusively in related duties. However, there are no specific numerical limits defined in the official implementation guidelines regarding how much time may be spent on these duties.As a result, there is no clear figure for how related duties should be proportioned. Nevertheless, the standards used in the Technical Intern Training Program (Caregiving) can serve as a useful reference. In that system, duties are categorized as essential, related, and peripheral, with the share of related duties not exceeding half of the total, and peripheral duties limited to one-third.
If the same approach were applied to the Specified Skilled Worker (Caregiving) program, it would be reasonable to use one-third of the total workload as a benchmark for duties that fall outside the category of primary caregiving tasks.
\*Note: In the context of the Specified Skilled Worker visa, related duties are conceptually similar to peripheral duties under the Technical Intern Training Program. Therefore, using one-third as a guideline is considered appropriate.
Is It Permissible to Provide Living Assistance?
Living assistance refers to support services that do not involve direct physical contact with the care recipient. This includes tasks such as cleaning, laundry, taking out the trash, bed-making, shopping, and assisting with meal preparation.According to the operational guidelines for the Specified Skilled Worker (Caregiving) visa, these activities are not classified as personal care services. Instead, they are considered related duties and are not regarded as part of the main caregiving responsibilities.
Therefore, when performing living assistance, it must be carried out as a supplementary activity within the context of providing primary personal care. For example:
If a worker is assigned solely to living assistance on a routine basis—as in a housekeeping-only role—this would be deemed a violation of the permitted scope of duties, potentially constituting unauthorized employment.
Can Foreign Workers Engage in Transportation Duties if They Obtain a Driver’s License?
Even if a foreign worker under the Specified Skilled Worker (Caregiving) visa obtains a valid Japanese driver’s license, they are not permitted to serve exclusively as transportation staff.Since transportation duties are not considered part of personal caregiving, they cannot be treated as a primary job responsibility and are instead classified as a related duty.
Accordingly, such tasks may only be carried out on a supplementary basis, in the same manner and scope as Japanese caregiving staff—such as helping with pick-up or drop-off in between caregiving tasks.
Assigning foreign workers solely to transportation roles or having them perform only driving duties contradicts the intent of the system. In practice, transportation duties should be handled as needed, in conjunction with caregiving responsibilities, just as they would be for Japanese staff.
Workplaces Where Specified Skilled Worker (Caregiving) Visa Holders Can Be Employed
The workplaces where individuals holding a Specified Skilled Worker (Caregiving) visa may be employed are diverse and broadly defined.Examples include facilities covered under the Child Welfare Act, such as residential institutions for children with disabilities, as well as establishments governed by the Comprehensive Support for Persons with Disabilities Act, such as support centers for individuals with disabilities.
Additionally, employment is permitted at service providers under the Long-Term Care Insurance Act and the Elderly Welfare Act, including special nursing homes for the elderly, fee-based senior care facilities, and home-visit caregiving service offices.
Furthermore, under certain conditions, these workers may also be employed in medical institutions such as hospitals and clinics, allowing for a wide range of job settings tailored to various care needs.
Duties Not Permitted Under the Specified Skilled Worker (Caregiving) Visa
Even foreign nationals working under the Specified Skilled Worker (Caregiving) visa may be prohibited from engaging in certain tasks, depending on the nature of the work within a facility. Performing such tasks could result in a violation of immigration law and be classified as unauthorized employment.In this section, we will explain specific examples of duties that are not permitted.
Activities That Fall Under the Scope of Other Residency Statuses
The scope of work permitted under the Specified Skilled Worker (Caregiving) visa is strictly limited to caregiving duties. Even if the tasks are performed within a care facility, engaging in activities that fall under other residency statuses—such as “Business Manager” or “Engineer/Specialist in Humanities/International Services”—is not allowed.Specifically, roles such as management positions related to business operations, executive-level duties, clerical work, or sales-related responsibilities are outside the permitted scope. If foreign workers are assigned to such tasks, it may be deemed a case of unauthorized employment.
On the other hand, for residency categories that also fall within the caregiving field—such as the “Caregiver” visa, the “Technical Intern Training (Caregiving)” program, and the “EPA Certified Care Worker (Candidate)” status—the permissible scope of duties tends to overlap, and the work content is generally consistent across these statuses.
Medical Procedures
Foreign nationals working under the Specified Skilled Worker (Caregiving) visa are not legally permitted to perform medical procedures.This restriction is especially important in hospitals and clinics, where there are numerous tasks that cannot be carried out by unlicensed personnel—even under the supervision of doctors or nurses. As such, careful attention must be paid to role assignments in these settings.
If a worker engages in unauthorized medical procedures, it could result in violations not only of medical laws such as the Medical Practitioners Act but also of immigration regulations, potentially leading to serious legal consequences.
Summary
This article has provided a structured overview of the scope of work permitted under the Specified Skilled Worker (Caregiving) visa, including related duties, eligible workplaces, and examples of prohibited tasks. While personal care and related support activities are legally permitted, exceeding the authorized scope may lead to violations and carry the risk of unauthorized employment. Therefore, it is essential to regularly confirm task assignments and clarify each worker’s role.Receiving organizations and on-site supervisors should periodically review the duties being assigned and the scope of employment. In cases of uncertainty, it is crucial to consult with qualified professionals. Deepening institutional understanding of the system helps foster a safe and compliant work environment where foreign staff can continue working with peace of mind.
Supervisor’s Commentary
To prevent unauthorized employment, it is essential to have an accurate understanding of the scope of work permitted under each residency status.However, in practice, the boundaries are not always clearly defined. It is therefore necessary to make case-by-case decisions based on the intent of the system and the content of official guidelines.
Rather than leaving these decisions to the discretion of on-site staff, it is important to proactively organize the permissible duties in advance and establish a shared understanding among all relevant parties. This is the first step toward ensuring proper and compliant employment of foreign workers.
This article is a translation of the original Japanese version.