Safety & Health Training Obligations Under Japan's Ikuseishuro Program (Effective April 2027) — 5 Things Receiving Companies Must Prepare Now

TL;DR

• The Ikuseishuro (Training & Employment) program takes effect on April 1, 2027, succeeding the Technical Intern Training Program.
• Ikuseishuro workers are "workers" under the 労働安全衛生法 (Industrial Safety and Health Act) → on-hire training, special training, and supervisor training all apply in full.
• "We provided training in Japanese, but they didn't understand it" carries the risk of being treated as a breach of the duty of care for safety (安全配慮義務違反).
• The article below details the 5 things receiving companies must prepare immediately.

The amended Immigration Control Act, enacted in June 2024, formally established that the Ikuseishuro (Training & Employment) program will take effect on April 1, 2027, replacing the Technical Intern Training Program. One of the largest practical questions for receiving companies is: how does the scope of safety and health training obligations for foreign workers actually change?

A general overview of the program is easy to find online, but almost no article digs into the safety and health training obligations specifically. This article walks through the relationship with Japan's existing 労働安全衛生法 (Industrial Safety and Health Act, hereafter "ISHA") and narrows down five concrete actions that receiving companies should take before the law takes effect.

What is the Ikuseishuro program?

The Ikuseishuro program is a new framework for accepting foreign workers, designed to address the problems of the Technical Intern Training Program — the gap between its stated purpose ("international contribution") and its real-world function ("securing labor"), restrictions on job transfers, and human-rights concerns.

Key changes (compared with the Technical Intern Training Program)

It is easiest to understand as a system that openly recognizes the labor-securing function that the Technical Intern Training Program performed in practice.

Ikuseishuro workers are "workers"

This is the most important point that is most often overlooked in discussions of the Ikuseishuro program.

Ikuseishuro workers are protected as "workers" under the Labor Standards Act and the 労働安全衛生法 (Industrial Safety and Health Act).

This is the same as for technical interns. In other words, Article 59 of ISHA (safety and health training on hire), Article 60 (training of supervisors), and Article 61 (employment restrictions) all apply just as they do to any Japanese worker.

Safety and health training obligations imposed on receiving companies (ISHA-based)

Under the 労働安全衛生法, receiving companies (i.e., employers) of Ikuseishuro workers must provide the following training.

1. On-hire safety and health training (ISHA Article 59, paragraph 1)

Training given to every worker upon hiring. It is mandatory in nearly all industries, including construction, manufacturing, and logistics.

Following the expansion in April 2024 (Reiwa 6), training items that were previously limited to specific industries became mandatory across nearly all industries. This expanded scope naturally applies to Ikuseishuro workers as well.

Required content (Industrial Safety and Health Regulations, Article 35):

1. Hazards or harmfulness of machinery and raw materials, and how to handle them
2. Performance and handling of safety devices, harmful-substance suppression devices, and protective equipment
3. Work procedures
4. Inspections at the start of work
5. Causes and prevention of diseases that may arise from the work
6. Maintaining order, organization, and cleanliness
7. Emergency measures and evacuation in case of accidents
8. Other matters necessary for the safety or hygiene of the work

2. Safety and health training when work content changes (ISHA Article 59, paragraph 2)

When a worker's tasks change (department transfer, change of job type, etc.), the employer must provide the same training as for new hires.

3. Special training (ISHA Article 59, paragraph 3)

Required when assigning workers to dangerous or harmful tasks. The use of full-harness fall-arrest equipment, forklift operation, arc welding, low-voltage electrical work, and so on — 59 categories of work — are covered.

4. Supervisor training (ISHA Article 60)

Training for supervisors and others who directly instruct or supervise workers during their tasks. It applies to construction, parts of manufacturing, electricity, gas, automobile maintenance, and machine repair industries.

The real question: Can training be valid for workers who don't understand Japanese?

ISHA orders employers to "provide training," but it does not order them to "provide it in Japanese."

In fact, Japan's Ministry of Health, Labour and Welfare has issued a notice to the effect that "safety and health training for foreign workers must be conducted in a way they can understand," and this is consistent with the legal interpretation of the duty of care for safety (安全配慮義務).

In practical terms, then, a state of "training was conducted, but the worker didn't understand it" likely does not satisfy the training obligation under ISHA.

There have been past court cases in which companies that provided safety training in Japanese only were found to have breached their duty of care for safety after a foreign worker suffered a workplace accident.

Conclusion

Before the Ikuseishuro program takes effect, you need to put in place a system to deliver safety and health training in each foreign worker's native language — or in a language they sufficiently understand.

5 things receiving companies must prepare now

The program takes effect in April 2027, but preparation should start today. From frontline experience, starting one year in advance gives you breathing room; starting six months in advance is tight.

Step 1: Take stock of the countries and languages of incoming workers

Identify the countries you plan to receive Ikuseishuro workers from (or the nationalities of your current technical interns) and decide which languages you must support.

Step 2: Identify the language gaps in your existing safety training content

Take inventory of your in-house safety and health training materials (videos, text, tests) and check which languages they are available in. In most cases, the answer is "Japanese only."

Step 3: Choose how to localize

You have roughly three options.

1. Translate existing materials: Reliable, but creating subtitles, dubbing, and translating tests can cost anywhere from hundreds of thousands to several million yen.
2. Adopt a multilingual e-learning service: Cheaper than in-house production and offloads maintenance work.
3. Use the MHLW's multilingual manuals as a supplement: Free, but limited in industry-specific depth and how quickly they are updated.

Step 4: Set up a system to retain training records

Under ISHA, records of safety and health training must be retained for three years (Regulation Article 38). This applies to Ikuseishuro workers as well. Moving from paper management to e-learning, which leaves a digital log, is the realistic path.

Step 5: Align expectations with your supervising support organization

Under the new program, "supervising support organizations" replace the previous "supervising organizations" and will guide and oversee receiving companies. Because the supervising support organization will also check on the state of safety and health training, it is important to prepare documents that explain "this is how we run things".

Summary

Under the Ikuseishuro program (effective April 2027), foreign workers are protected workers under ISHA, and obligations such as on-hire training, special training, and supervisor training apply just as they do to any other worker.

But training must be conducted "in a way the worker can understand," and Japanese-only training carries the risk of being treated as a breach of the duty of care for safety.

In particular, multilingual preparation — including content production, translation, and test design — requires a preparation period of 6 to 12 months. It is worth starting today.

Key Takeaways

1. Ikuseishuro workers are "workers" under ISHA. On-hire training, special training, and supervisor training all apply.
2. Training must be conducted "in a language the worker understands." Japanese-only training carries breach-of-duty risk.
3. Start by taking stock of incoming countries and languages. Vietnamese, Chinese, Indonesian, and English are the highest priorities.
4. Training records must be retained for 3 years by law (Regulation Article 38). Moving to e-learning's digital records is the realistic answer.
5. The program takes effect in April 2027. Multilingual preparation takes 6–12 months — start now.

Primary references

• Overview of the Ikuseishuro Program (Ministry of Health, Labour and Welfare)
• JITCO (formerly Japan International Trainee & Skilled Worker Cooperation Organization): Ikuseishuro Program
• Industrial Safety and Health Act Article 59 (e-Gov Legal Search)
• Industrial Safety and Health Regulations Article 35 (same)