Legal Obligations During Job Change/Resignation: Requirements and Objective Submission Procedures for the “Notification Concerning the Contracting Organization”

This article is written by a Japanese local.

When foreign talent holding a work visa such as “Engineer/Specialist in Humanities/International Services (commonly known as Gijinkoku)” resigns or changes jobs, there is a legal requirement that is extremely important in practice but often overlooked. That is the “Notification Concerning the Contracting Organization (Shiozoku Kikan-to ni Kansuru Todokede).”

There is a never-ending stream of cases where individuals feel relieved after receiving a job offer from a new company or acquiring a Certificate of Authorized Employment, and subsequently neglect this notification. However, this is a strict “obligation” imposed on the foreign individual by the Immigration Control Act. This article thoroughly explains the legal timeline for the notification, the compliance penalties imposed when neglected, and the objective submission process.

1. Notification Timing and the Absolute “Within 14 Days” Requirement

The “Notification Concerning the Contracting Organization” is a legal procedure to report to the Immigration Services Agency when there is a change in the status of the contracting organization (employer) that forms the basis of your work visa. When the following events occur, you must submit the notification “within 14 days from the date the event occurred.”

• When you resign (Leave): Submit a notification of “Leaving the organization” within 14 days from the date of resignation (the end date of the employment contract).
• When you join a new company (Transfer): Submit a notification of “Transfer to a new organization” within 14 days from the date you joined the new company.

*If the resignation date and joining date are consecutive and there is no period of unemployment, it is legally permitted to submit a combined “Leave and Transfer” notification simultaneously in a single procedure.

2. Three Fatal Penalties for Neglecting the Notification Obligation

If you continue to neglect this under the self-judgment that “there is no direct reminder from Immigration, so it’s fine,” it will cause irreparable damage to your future career in Japan. Under the Immigration Control Act, there are objective risks of the following three penalties being imposed.

(1) Negative Impact on Next Visa Renewal and Permanent Residence Screening

The fact that you have not fulfilled your notification obligation under the Immigration Control Act serves as a direct cause for being deemed to have a “poor compliance record (conduct)” during your next period of stay renewal screening. This creates a risk that your period of stay will be shortened to “1 year,” or in the worst case, your renewal will be denied. Furthermore, when applying for “Permanent Residence” in the future, past violations of notification obligations act as a powerful negative factor that leads to an immediate denial.

(2) Application of Penalties (Fine of up to 200,000 JPY)

Under Article 71-2 of the Immigration Control Act, there is a clear penalty provision stating that if you fail to submit the notification concerning the contracting organization within 14 days without a justifiable reason, you may be punished with a fine of up to 200,000 JPY.

(3) Risk of Visa Revocation

If more than 3 months pass after resigning without joining a new company (and without submitting the notification), your current work visa becomes subject to “revocation” based on Article 22-4 of the Immigration Control Act.

3. Trouble Cases in Job Changes/Resignations and Risk Avoidance Measures

Case A: The Misconception That “The Company Will Handle the Procedure”

[Situation] Upon resigning, you asked the HR representative, “Are there any issues with my visa procedures?” and they replied, “The company will handle it,” so you did not submit any notification yourself.
[Legal Risk] The company also has a notification obligation to Immigration (Notification concerning the acceptance of mid to long-term residents), but that is strictly “the company’s obligation.” It is a completely separate procedure independent from the “notification obligation of the foreign individual.” Even if the company performs its procedure, your obligation is not waived. The responsibility for the violation lies with the foreign individual.
[Avoidance Measure] Separate this from the company’s procedures and ensure that you complete the notification under your own name within the deadline.

Case B: Discovery During Visa Renewal After Months of Neglect

[Situation] Unaware of the notification, you were pointed out by Immigration at the counter during your visa renewal application, 8 months after changing jobs, that the notification had not been submitted.
[Legal Risk] The renewal screening proceeds under the confirmed state of an obligation violation.
[Avoidance Measure] Even if the 14-day deadline has passed, instead of continuing to ignore it, you must minimize the deterioration of your impression by submitting the notification immediately upon realization, accompanied by a “Statement of Reason for Delay” reporting the objective facts.

4. Objective Submission Methods and Recommended Practical Process

The following three submission methods are specified, but in practice, “Online Submission” is highly recommended from the standpoint of information accuracy and immediacy.

• [Recommended] Online (Immigration Services Agency Electronic Notification System): Can be submitted 24 hours a day from a smartphone or PC. By simply registering your user information, it incurs no mailing costs, and the record of acceptance remains objectively on the system, making it the safest method.
• Mail: Mail the designated notification form and a copy of your residence card to the Tokyo Regional Immigration Services Bureau (Notification Reception Department). To prevent loss during mailing, be sure to use a trackable method such as “Registered Mail (Kani Kakitome)” or “Letter Pack.”
• In-Person: Submit it directly at the counter of your nearest regional Immigration Services Bureau (not recommended practically as it involves waiting times).

5. Practical Q&A on Notifications

• Q: Do I need to submit a notification if I just transfer from the Sales Department to the HR Department within the same company?
  A: No. The notification concerning the contracting organization is mandated only when there is a change in the “corporate entity (corporate number) with which you have an employment contract.” If it is a department transfer within the same corporation or a transfer from the head office to a branch, submission is not necessary. (However, if the job duties exceed the scope of your visa, a different procedure for change is required.)
• Q: Can the company’s HR department submit it online on behalf of the foreign employee?
  A: The Electronic Notification System has a function (proxy reporting) where staff of the contracting organization can submit notifications in batches on behalf of foreign individuals. It is legal for the company to support the submission using this, and it is an effective measure from the perspective of compliance management.

6. Conclusion: Preservation of Career Through Thorough Compliance

A job change is not complete the moment you join a new company and begin your duties. Only by completing the “Notification Concerning the Contracting Organization” mandated by the Immigration Control Act is a legal career transition established.

Even during a busy period of onboarding procedures and taking over new tasks, this statutory period of “14 days” is strictly applied. To eliminate fatal troubles in future visa renewals and permanent residence applications, ensure you execute the objective legal procedures: “Submit a notification of leaving immediately after resignation” and “Submit a notification of transfer immediately after joining.”