Labor IssuesLast updated: 2026-10-296 min readPublic-source summary

MHLW Revokes a Company’s Worker Dispatch and Fee-Charging Job Placement Licences (Announced 28 October 2026): Fine Under Article 73-2 of the Immigration Control Act Made It Ineligible

This article compiles what Japanese government bodies have published, together with the statutory text. Links to the primary sources are included. For a specific matter, pleasecontact us.

Key Takeaways

  • ✓The Ministry of Health, Labour and Welfare (MHLW) announced that on 28 October 2026 it revoked the worker dispatch and fee-charging job placement licences of INC Co., Ltd. (Yokkaichi, Mie Prefecture)
  • ✓The ground was that the company had been fined for an offence under Article 73-2(1)(i) of the Immigration Control and Refugee Recognition Act, and the sentence became final on 4 February 2026
  • ✓That fine brought the company within the grounds of ineligibility for a licence in Article 6(i) of the Worker Dispatch Act and Article 32(i) of the Employment Security Act, and revocation was judged appropriate
  • ✓The revocations were made under Article 14(1)(i) of the Worker Dispatch Act and Article 32-9(1)(i) of the Employment Security Act
  • ✓Article 73-2(1)(i) of the Immigration Control Act punishes "a person who, in connection with business activities, has caused a foreign national to engage in illegal work" with imprisonment of up to three years, a fine of up to JPY 3 million, or both

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The Ministry of Health, Labour and Welfare (MHLW) announced that on 28 October 2026 it revoked the worker dispatch licence and the fee-charging job placement licence of INC Co., Ltd. (Yokkaichi, Mie Prefecture). A fine imposed on the company for an offence under Article 73-2(1)(i) of the Immigration Control and Refugee Recognition Act (the Immigration Control Act) had become final, bringing it within the grounds of ineligibility for a licence in the Worker Dispatch Act and the Employment Security Act.

This page summarises the MHLW press release and the full version of the press material (a PDF whose annex sets out the relevant provisions). The provisions have been checked against the current text on e-Gov, the Japanese government's statute database.

Overview

ItemDetails
Date announced28 October 2026
Announced byMinistry of Health, Labour and Welfare (contact: Demand and Supply Adjustment Division, Employment Security Bureau)
ActionRevocation of the worker dispatch business licence and the fee-charging job placement business licence
Date of action28 October 2026
CompanyINC Co., Ltd. (Yokkaichi, Mie Prefecture)
GroundFined for an offence under Article 73-2(1)(i) of the Immigration Control Act, with the sentence becoming final on 4 February 2026; this fell within the grounds of ineligibility in Article 6(i) of the Worker Dispatch Act and Article 32(i) of the Employment Security Act

1. The licences revoked

According to the press material, the two licences revoked were as follows.

BusinessDate licensedLicence number
Worker dispatch business1 March 2024派24-300833
Fee-charging job placement business1 March 202424-ユ-300429

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2. The action taken

The press material describes the action as follows.

  • Under Article 14(1)(i) of the Worker Dispatch Act and Article 32-9(1)(i) of the Employment Security Act, the licences for the worker dispatch business and the fee-charging job placement business are revoked with effect from 28 October 2026

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3. The grounds

According to the press material, the grounds were as follows.

  • The company was fined for committing an offence under Article 73-2(1)(i) of the Immigration Control Act, and the sentence became final on 4 February 2026
  • As a result, it fell within the grounds of ineligibility in Article 6(i) of the Worker Dispatch Act and Article 32(i) of the Employment Security Act, and revocation of the licences was judged appropriate

Relevant provisions

The relevant parts of the provisions, taken from the annex to the press material and the current text on e-Gov, are as follows. (The Worker Dispatch Act is formally the Act on Securing the Proper Operation of Worker Dispatching Undertakings and Protecting Dispatched Workers.)

ProvisionWhat it provides (summary of the wording)
Worker Dispatch Act, Art. 5(1)A person who intends to operate a worker dispatch business must obtain a licence from the Minister of Health, Labour and Welfare
Worker Dispatch Act, Art. 6(i)A person who has been sentenced to imprisonment or a heavier penalty, or who has been fined for one of the offences listed in that item (including an offence under Article 73-2(1) of the Immigration Control Act), and for whom five years have not passed since the sentence was served or ceased to be enforceable, cannot obtain a licence
Worker Dispatch Act, Art. 14(1)(i)The Minister may revoke the licence of a dispatching business operator that falls within any item of Article 6 (other than items (v) to (viii))
Employment Security Act, Art. 30(1)A person who intends to operate a fee-charging job placement business must obtain a licence from the Minister
Employment Security Act, Art. 32(i)The same ground of ineligibility as Article 6(i) of the Worker Dispatch Act (including a fine for an offence under Article 73-2(1) of the Immigration Control Act)
Employment Security Act, Art. 32-9(1)(i)The Minister may revoke the licence of a fee-charging job placement business operator that falls within any item of Article 32 (other than items (v) to (viii))

Article 73-2 of the Immigration Control Act provides as follows.

ProvisionWording
Para. 1, opening wordsA person who falls within any of the following items is punished by imprisonment of up to three years or a fine of up to JPY 3 million, or both
Para. 1, item (i)A person who, in connection with business activities, has caused a foreign national to engage in illegal work
Para. 1, item (ii)A person who has placed a foreign national under their control in order to cause them to engage in illegal work
Para. 1, item (iii)A person who, as a business, has acted as an intermediary in causing a foreign national to engage in illegal work or in the act in item (ii)
Para. 2A person who has done an act within any item of paragraph 1 cannot escape punishment on the ground that they did not know that the foreign national's activity was an activity of operating an income-generating business or receiving remuneration that did not fall within the activities permitted by their status of residence, that the foreign national did not have permission under Article 19(2), or that the foreign national was a person listed in certain items of Article 70(1). This does not apply where the person was not negligent

Sources

  • MHLW, "Revocation of licences for a worker dispatch business and a fee-charging job placement business" (28 October 2026, Japanese) https://www.mhlw.go.jp/stf/newpage_76850.html
  • MHLW, full version of the press material (PDF, Japanese) https://www.mhlw.go.jp/content/11654000/001761292.pdf
  • e-Gov, Immigration Control and Refugee Recognition Act (Japanese) https://laws.e-gov.go.jp/law/326CO0000000319
  • e-Gov, Worker Dispatch Act (Japanese) https://laws.e-gov.go.jp/law/360AC0000000088
  • e-Gov, Employment Security Act (Japanese) https://laws.e-gov.go.jp/law/322AC0000000141

This page is compiled from material published by government agencies. Please consult a lawyer where a decision is needed on a specific matter.

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