For applications for the "Engineer / Specialist in Humanities / International Services" visa (Categories 3 and 4) submitted on or after April 15, 2026, applicants will be required to submit new documents, such as a "Declaration Form by the Representative of the Affiliated Organization."

 Of particular note is the scope of "interpersonal duties" for which proof of Japanese N2 (CEFR B2) level proficiency is required.

 ・Will sales and interpretation become mandatory?
 ・Are IT engineers also included in this requirement?
 ・What points will be checked during renewal applications?

 We provide a thorough explanation of the key points of these system changes in Sections 1 through 8. Please use this article to check whether your company’s foreign employees meet the “language requirements.”

 CEFR B2 Supporting Documents and the Concept of “Interpersonal Business Activities Using Language Skills”

 For the “Engineer / Specialist in Humanities / International Services” status of residence, starting with applications submitted on or after April 15, 2026, a “Declaration Form by the Representative of the Affiliated Organization” is required as supplementary documentation for those falling under Category 3 or 4. Furthermore, if the individual engages in language-based interactive duties, they must also submit documentation proving they possess language proficiency equivalent to CEFR B2 in the language used for their work. The Immigration Services Agency has announced that, for Japanese language proficiency, it considers the following to be equivalent to B2: JLPT N2 or higher, a score of 400 or higher on the BJT Business Japanese Proficiency Test, having resided in Japan for 20 years or more as a medium- to long-term resident, or having completed a program at a Japanese university, college of technology, or specialized training college.

 However, this new requirement does not mean that JLPT N2 is uniformly required for all cases under the “Engineer / Specialist in Humanities / International Services” category. The Immigration Services Agency’s wording specifically requires proof of B2-equivalent proficiency in the language used for work only when “engaging in interpersonal duties that require language skills.”

 Therefore, the key question is whether the position involves interpersonal duties requiring Japanese or other language skills.

 At Tanishima Legal Group, we offer a “Foreign National Language Requirement Assessment Service” tailored to each individual foreign employee.

 Many companies are concerned that this change might result in their applications being suddenly denied during renewal. Please feel free to contact us.

 1. Review the Basics of the "Engineer / Specialist in Humanities / International Services" Category

 The Immigration Services Agency defines activities falling under the "Engineer / Specialist in Humanities / International Services" category as work requiring technical skills or knowledge in the fields of natural or human sciences, or work requiring thinking and sensibilities rooted in foreign cultures, performed under contract with public or private organizations in Japan. Examples include engineers in mechanical engineering, interpreters, designers, language teachers at private companies, and marketing professionals. In other words, this status of residence encompasses a mix of inherently language-intensive occupations and those that involve minimal interpersonal interaction and are primarily output-oriented.

 Therefore, it is difficult to make blanket statements such as “N2 is required because it is ‘Engineer / Specialist in Humanities / International Services’” or “It is not required because I am an engineer”; instead, it is necessary to examine the specific job duties on a case-by-case basis.

 2.  N2 is required not for “jobs that use Japanese,” but for “cases where language skills are used to engage in interpersonal work”

 The key point in this supplementary material is that The Immigration Services Agency is not simply looking at “whether Japanese is used,” but rather at cases where language skills are used to engage in interpersonal work. Furthermore, the language to be demonstrated is not limited to “Japanese,” but is defined as the language used in the course of business. Therefore, if the work primarily involves English sales to overseas customers or interpretation and negotiation in a foreign language, the requirement would be for B2-level documentation for that language.

 Conversely, simply attending meetings in Japanese, writing daily reports in Japanese, or engaging in brief chats in Japanese does not necessarily mean that B2-level documentation is immediately required. Situations that are prone to becoming problematic include the following:

 ・Making proposals and conducting negotiations with customers as a sales representative
 ・Using language skills directly in your work as an interpreter, translator, or language teacher
 ・Working in marketing, recruitment, HR, or customer support, where explanations, negotiations, and coordination are central to the job
 ・Handling internal and external coordination in Japanese, where the communication itself constitutes a major part of the job

 In these types of roles, it is easy to be evaluated as “engaging in interpersonal work using language skills,” and documents such as N2-level Japanese proficiency certificates or certificates demonstrating proficiency in other languages used for work are likely to be scrutinized. This aligns with the job categories cited by The Immigration Services Agency, such as interpreters, language teachers, and marketing professionals.

 3. Types of Work Where N2-Level Documentation Is Likely Unnecessary

 On the other hand, a different classification is more likely for the following types of work:

 ・In-house system development, design, and maintenance
 ・Work focused on deliverables such as drawings, code, specifications, and data analysis
 ・Jobs that involve primarily technical work without customer negotiations
 ・Tasks that involve limited communication in English or other languages, but where interpersonal explanations or negotiations are not the core of the job

 In such roles, since the core of the job lies in the creation of specialized deliverables or technical work itself—rather than “explanations,” “negotiations,” “customer service,” or “discussions”—there are situations where it cannot immediately be classified as “engaging in interpersonal tasks using language skills.”

 However, even if a position is nominally an engineer or designer, if the role involves frequent requirements definition, client negotiations, coordination with other departments, or participation in Japanese-language meetings, it may be viewed as having a high degree of interpersonal interaction. It is necessary to consider the actual job duties rather than the job title.

4. Does the existence of a Representative Declaration Form mean that the decision is based solely on nationality?

 This is another point that is often misunderstood. According to The Immigration Services Agency’s guidelines, the “Declaration Form by the Representative of the Affiliated Organization” is listed first as supplementary documentation for cases falling under Categories 3 or 4. Only then, if the individual engages in interpersonal duties using language skills, are language proficiency documents required to be submitted. In other words, based on the structure of the publicly available information, the necessity of B2-level documents is determined strictly by the nature of the job duties; it is not stated that this is automatically determined by nationality alone.

 Of course, during the screening process, the content of the Representative Declaration may be used to verify the specific language environment, the target audience, and the nature of the interpersonal duties to be performed. However, based on the publicly available materials alone, there is no indication that Japanese B2 proficiency is required simply because of a specific nationality. The safest approach is to focus on the actual job duties and the languages used, rather than nationality.

5. Points to Note for Renewal Applications

 These additional materials are not limited to new applications for Certificate of Eligibility (COE) applications. The Immigration Services Agency’s “Engineer / Specialist in Humanities / International Services” page lists the required documents for renewal applications by category, including a list of documents for Categories 3 and 4.

 Therefore, for those already residing in Japan under the “Engineer / Specialist in Humanities / International Services” status, it becomes even more important to clearly document job duties and languages used at the time of renewal. In particular, for the first renewal after changing jobs or in cases where job duties have become more people-oriented than before, it is essential to carefully verify the consistency of the employment contract, job description, company profile, and explanation of actual business operations. The Immigration Services Agency has also noted that applications with incomplete documentation may face significant delays in processing or result in unfavorable decisions.

6. Practical Points for Companies to Review

 The key point here is not to focus solely on whether the applicant passed or failed the Japanese Language Proficiency Test. Rather, the first thing to review is the company’s documentation and actual operations.

 First, verify the language used in employment contracts, notices of employment conditions, job descriptions, job postings, and organizational charts. For example, even if the company internally views the position as a “technical role with no customer interaction,” if the contract contains frequent references to “proposing to clients,” “negotiations,” “handling inquiries,” or “inter-departmental coordination,” the role may appear to involve a significant amount of interpersonal work.

 Next, discrepancies with actual on-site conditions are also important. Even if the position is nominally a back-office or technical role, if the actual work frequently involves sales support, explaining products to customers, handling phone and email inquiries, and regular participation in Japanese-language meetings, written descriptions alone may not be sufficient.

7. Which Companies Should Be Especially Cautious?

 Particular attention should be paid to companies where work tends to center on explanations and negotiations, such as those in sales, interpretation, translation, language education, marketing, recruitment, human resources, customer success, and customer support. This is because many of these roles closely match the examples cited by The Immigration Services Agency, and the relationship between language proficiency and job duties is often a point of concern.

Furthermore, even at IT companies and manufacturers, if engineers are directly coordinating requirements with clients in Japanese, or if they also handle project management and serve as the primary point of contact for clients, the role can effectively involve a high degree of interpersonal interaction. In such cases, it’s best not to rely solely on the job title for reassurance.

8. Reasons to Get Organized Early

 Waiting until just before the application to determine whether documents such as the N2 certificate are required can make the process difficult. This is because internal coordination takes time—not only to obtain the necessary documents but also to clarify job descriptions, organizational roles, and who is responsible for which tasks within the company.

 Therefore, it is advisable to confirm the following points as early as possible—not only if a renewal or change application is imminent, but especially for companies that plan to continue hiring foreign nationals under the “Engineer / Specialist in Humanities / International Services” category.

 ・Does the position involve interpersonal tasks that require language skills?
 ・What language is used for business purposes?
 ・Do the terms in the employment contract and job description accurately reflect the actual situation?
 ・Who is responsible for customer service and internal coordination?
 ・Is it likely that additional explanations will be required when applying for renewal?

 By reviewing these points early on, it becomes easier to determine whether support for obtaining an N2 certification is necessary, whether the issue can be addressed through a reorganization of duties, and what documents should be prepared.