73.2% of Inspected Technical Intern Employers Found in Violation — ¥1.1M in Unpaid Overtime, Press-Machine Injury, 26 Prosecutions

Japan's Ministry of Health, Labour and Welfare (MHLW) published on September 15, 2026 the results of labor standards inspections and criminal referrals conducted by regional Labor Standards Inspection Offices nationwide during FY2025 at workplaces employing Technical Intern Trainees and Specified Skilled Workers (SSW). Of 13,148 workplaces employing technical interns that were inspected, 9,619 (73.2%) were found in violation of labor standards laws, and 26 serious or malicious cases were referred for criminal prosecution. In one case, a civil engineering firm was found, following an intern's complaint that overtime pay had not been paid, to owe roughly ¥1.1 million in unpaid overtime premiums.

Overall Inspection Results

The most common violations were: (1) safety standards for machinery (Industrial Safety and Health Act Articles 20-25, 2,994 cases, 22.8%); (2) failure to obtain physician opinions on health checkup results (Article 66-4, 2,066 cases, 15.7%); and (3) failure to pay overtime premiums (Labor Standards Act Article 37, 2,045 cases, 15.6%). These were followed by failure to clearly state working conditions (12.6%), sanitation standards (11.9%), annual paid leave (11.7%), working hours (10.7%), wage payment (9.3%), health checkups (8.8%), and work rules (8.5%).

Violation Rates by Industry

By industry, construction (civil engineering, building construction, etc.; 2,808 workplaces inspected) had the highest violation rate at 80.2% (2,252 workplaces), driven mainly by unpaid overtime (645 cases, 23.0%) and failure to obtain physician opinions on health checkups (644 cases, 22.9%). Agriculture/livestock followed at 75.4% (444 workplaces), textiles/apparel at 72.5% (366), food manufacturing at 71.8% (1,248), and machinery/metal manufacturing at 68.6% (2,416).

Concrete Inspection Cases

MHLW's published materials describe three representative cases.

Case 1 (civil engineering): A Labor Standards Inspection Office conducted an on-site investigation after a technical intern reported that overtime pay had not been paid. The investigation found that overtime premiums for hours worked beyond 40 hours per week had not been paid, resulting in a corrective recommendation. The office also issued a corrective recommendation because the company had made the intern bear treatment costs under health insurance for a work-related injury requiring outpatient care. The company subsequently paid roughly ¥1.1 million in unpaid overtime premiums and reimbursed the intern's share of treatment costs, including amounts billed through health insurance.

Case 2 (metal products manufacturing): At a factory, a technical intern was hooking a sling to a steel plate being lifted when the crane operator began operating the overhead crane, catching the intern's hand between the plate and the hook and causing injury. The Labor Standards Inspection Office's investigation found that signaling procedures for crane operation had not been established or used, resulting in a corrective recommendation. The company established crane signaling procedures requiring workers to call out to nearby colleagues when lifting loads, and posted illustrated notices near the worksite for the benefit of foreign workers.

Case 3 (metal products manufacturing): At another factory, a technical intern was injured when the hand holding a metal plate during a press-machine bending operation slipped and was caught in the machine. The investigation found that required safety measures — such as installing a safety device or using dedicated jigs to keep hands out of the danger zone — had not been implemented, resulting in a corrective recommendation. The company was also found not to have paid overtime premiums at the required rate of 50% or more for monthly overtime exceeding 60 hours, which was also subject to a corrective recommendation. The company changed its bending process to require dedicated jigs held with both hands, created and disseminated a work procedure manual, and paid roughly ¥10,000 in unpaid overtime premiums.

Complaints and Prosecutions

In FY2025, technical interns filed 108 complaints with Labor Standards Inspection Offices seeking correction of labor law violations (down slightly from 112 in FY2024), most commonly involving unpaid wages/overtime (93 cases), improper dismissal procedures (15), and pay below minimum wage (7). Of the 26 cases referred for prosecution as serious or malicious violations, 19 involved Industrial Safety and Health Act violations (including 11 safety-standard violations and 4 working-hours violations) and 7 involved Labor Standards Act/Minimum Wage Act violations.

Specified Skilled Workers

For workplaces employing SSW, 8,082 were inspected, of which 6,179 (76.5%) were found in violation. The pattern of violations was similar to the technical intern results: machinery safety standards (20.7%), failure to obtain physician opinions on health checkups (16.7%), and unpaid overtime (16.3%). 9 cases were referred for prosecution as serious or malicious violations.

Summary

• MHLW published FY2025 labor inspection and prosecution results for technical intern and SSW employers on September 15, 2026
• Technical interns: 13,148 workplaces inspected, 9,619 (73.2%) in violation, 26 prosecutions
• SSW: 8,082 workplaces inspected, 6,179 (76.5%) in violation, 9 prosecutions
• Construction had the highest violation rate at 80.2%, driven by unpaid overtime and health-checkup follow-up failures
• Published cases included roughly ¥1.1 million in unpaid overtime, a crane-signaling failure injury, and a press-machine injury

Practical takeaway: Many inspections are triggered by complaints from the technical interns or SSW workers themselves — of the 108 complaints filed in FY2025, 93 involved unpaid wages or overtime. Host organizations and SSW-accepting organizations are encouraged to review their overtime calculation methods (including the 50%+ premium required beyond 60 monthly overtime hours), whether machine-operation signaling procedures and safety devices are properly in place, and whether workplace injuries are being processed through workers' compensation insurance rather than health insurance. Supervising organizations and registered support organizations should make these specific points a focus of their periodic site visits. Consult Sakura Central Legal Office (MOJ-certified application agent) with any questions.