There is significant misinformation circulating about this proposed change.
The most important things for members of this sub are that this change may affect you if:
1) You apply to change status from something else (Instructor etc.) to an Engineer/Specialist SOR
AND
2) You are applying for that change of status to take a job at a Category 3 or 4 company (see below)
It does not affect people who are applying for a renewal of any visa category, and even with a change to the Engineer/Specialist SOR, not if you are applying based on employment at a Category 1 or 2 company (again, see below).
Here are the facts based on the latest update from the MOJ:
1. This is NOT a blanket N2 requirement.
The proposed requirement applies only where the job itself requires Japanese. If the role clearly does not require Japanese, this requirement does not apply. FULL STOP.
2. The standard is CEFR B2, not JLPT (UPDATED)
The requirement is based on CEFR B2-level proficiency, not JLPT specifically.
What’s new:
The MOJ guidance now clearly defines what counts as CEFR B2 or higher, removing ambiguity.
Accepted evidence includes:
Standardised tests:
- JLPT N2 or higher
- BJT (Business Japanese Test) 480+
Education-based equivalency (this is new and important):
- Graduation from a Japanese university
- Completion of education at a Japanese vocational school (専門学校)
- Completion of primary / secondary education (G1–G12) in Japanese
It recognises functional Japanese ability demonstrated through education, not just test scores
3. This applies only to new applications (UPDATED)
- Applies only to new applications
- A change of status from a different SOR to Engineer/Specialist will be viewed as a new application
- Renewals of existing Engineer/Specialist SOR will not be treated as a new application.
- International students (university, language school, vocational school) switching status are explicitly exempt
4. The actual target is misuse of the visa system
This policy is aimed at companies abusing the Engineer/Specialist/International Services visa by bringing workers in under a “skilled” visa, then assigning them to unskilled or non-qualifying work.
5. Crackdown on abusive employers (UPDATED)
The policy also closes a known loophole: companies that are banned from hiring under the Technical Intern Training or Specified Skilled Worker programs due to abuse (e.g. unpaid wages, assault, labour violations) will also be barred from hiring under this visa category during their suspension period.
Update based on MOJ guidance:
- This is now part of visa screening criteria, not just a guideline
- Applications from such companies will be rejected outright
- The restriction applies to the company itself, across visa categories
Suspended companies are now treated as fully ineligible employers, not just restricted in specific programs.
6. CEFR B2 enforcement applies specifically to Category 3 and 4 companies (NEW)
The clarified B2 standards are explicitly enforced for:
Category 3
- Small to mid-sized companies with limited transparency (not listed, limited public financials)
Category 4
- New or unstable companies with weak financials or a limited track record as this indicates a higher compliance risk
This tightening is not evenly applied across all employers. It is specifically aimed at lower-trust companies, where abuse and misuse are more common. Category 1 (Listed companies, government entities, etc.) and Category 2 (normal, compliant companies with standard tax reporting) retain more discretion and are not subject to this requirement.
TLDR (Updated)
- Not a blanket N2 requirement
- Only applies where the job actually requires Japanese
- CEFR B2 is now clearly defined with multiple accepted pathways: Tests (JLPT N2, BJT 480+, etc.) or Japanese education (university, vocational, or full schooling)
- Applies to new applications, not renewals
- Targets misuse of the visa system by employers
- Closes a loophole that allowed black companies to keep hiring under a different visa
- Suspended companies will now fail visa screening entirely
- Enforcement is focused on Category 3 and 4 (higher-risk employers)
- Category 1 and 2 (the bulk of employers) are not subject to this restriction.
by Orin_Scrivello_DDS