Can Foreign Workers with “Specified Skilled Worker” Status Be Entrusted with Sheet Metal Work and Painting? Combining These Duties with Vehicle Maintenance and the Separation of Categories in April 2027

“Can we hire foreign workers under the Specified Skilled Worker program by dividing roles into maintenance and body repair/painting? Or would it be better to have them handle both roles?” We received this inquiry from a business that handles sales, maintenance, and body repair all under one roof.

To put it simply, as of November 2026, under the Specified Skilled Worker program, maintenance and body repair/painting fall under the same job category: “Automotive Maintenance.” It is considered possible to hire workers with separate roles or to have them perform both tasks. However, starting in April 2027, the system is scheduled to be divided into two categories: “Automotive Maintenance” and “Body Repair,” so the approach will vary depending on the timing of hiring.

In this article, based on the provisions of the Operational Guidelines, we will outline the reasons for this and summarize the points you should confirm before hiring.

Can I trust them with bodywork and painting?

Body repair and painting are designated as the primary duties under the “Automotive Maintenance” Specific Skilled Worker category. This is clearly stated on page 4 of the Operational Guidelines (Revised February 15, Reiwa 6) as follows:

Workers must primarily engage in daily inspections and maintenance, periodic inspections and maintenance, specified maintenance, and tasks incidental to specified maintenance (such as maintenance of electronic control units and body repair and painting).

The key point here is that body repair and painting is specifically listed as part of the “primary duties,” rather than being categorized as “related tasks” such as car washing or cleaning.

Why Is Body Repair and Painting Considered Part of “Maintenance”?

The operational guidelines themselves do not specify a reason. One possible background factor is the April 2020 amendment to the Road Transport Vehicle Act. Under this amendment, “disassembly maintenance” was renamed “specified maintenance,” and the maintenance of electronically controlled devices—such as cameras and radar for automatic braking systems—was included within its scope.

When repairing a bumper or windshield damaged in an accident, it becomes necessary to adjust (aim) the sensors attached to those parts. The practical reality on the ground—where body repair and painting have become a single, integrated process—is likely the reason body repair and painting are classified as “work incidental to specified maintenance.”

Is it possible to hire staff with separate responsibilities or have them hold dual roles?

Both options are possible. Since there is currently only one job category under the “Automotive Maintenance” Specific Skilled Worker program, whether to assign separate personnel or have one person handle both roles is a matter of internal staffing rather than a matter of residency status.

However, please note the following three points:

1. Individuals responsible for bodywork and painting must also pass a maintenance skills test. Proof of skill is demonstrated by passing either the “Specific Skilled Worker Type 1 Evaluation Test in the Automotive Maintenance Field” or the “Automotive Mechanic Skills Certification Level 3,” or by completing the Type 2 Technical Intern Training Program in Automotive Maintenance. There is currently no exam specifically for bodywork and painting.

2. Workers cannot be assigned exclusively to related tasks. The Operational Guidelines state, “Engaging exclusively in related tasks is not permitted.” Even during peak seasons, workers cannot be assigned solely to related tasks such as car washing or transporting parts.

3. The requirements for the company are the same regardless of the worker’s role. The company must be a certified repair shop and must be a member of the Automotive Maintenance Sector Council prior to applying for the residence status.

What Will Change Starting in April 2027?

Under the operational guidelines for the automotive maintenance sector approved by the Cabinet on January 23, 2026, it was decided that business categories would be divided into the following two categories. Under transitional measures, operations will continue to follow the previous practices until March 31, 2027.

The Training-to-Employment System, which also begins in April 2027, is said to have the same job categories as the Specified Skilled Worker program.

Why Do We Separate Them?

According to explanatory materials from the Transport Bureau, this is described as “separating job categories to further secure personnel” in preparation for the start of on-the-job training. The materials explain that the system will be revised to allow candidates to choose not only vehicle inspection and maintenance but also job categories such as accident vehicle repair and bodywork.

This makes sense from the perspective of skills assessment as well. Under the current system, even those responsible for bodywork and painting have no choice but to demonstrate their skills through the general maintenance exam. Under the new system, the skills required for bodywork and painting will be assessed directly through the bodywork maintenance exam. Furthermore, the requirements for instructors in the on-the-job training program specify that, for the bodywork maintenance category, instructors must be certified as automotive bodywork and electronic control system technicians.

Things to Check When Hiring Now

If you proceed with hiring now, the requirements will vary depending on whether the employee’s entry into the country or start of employment falls before or after April 2027.

1. Start Date: When hiring from overseas, it takes several months from the job offer to entry into the country. If the start date is April 2027 or later, the application may fall under the new category.
2. Nature of the Work: Will the focus be on mechanical maintenance or on body repair and painting? If you are planning to focus on body repair and painting, the “Vehicle Body Repair” category will generally apply under the new system.
3. Exams the candidate has passed: Under the current categories, a vehicle maintenance exam (or completion of Technical Intern Training Program Type 2 in Automotive Maintenance) is required.

There are still some points that remain unclear. Based on the current operational policies and guidelines, it is not possible to determine whether individuals admitted under the current “Automotive Maintenance” category will be able to continue working primarily in body repair and painting after April 2027, or whether they will need to change their category when renewing their period of stay. If this applies to you, we recommend checking with the Automotive Maintenance Division of the Ministry of Land, Infrastructure, Transport and Tourism or your local Regional Transport Bureau.

Regarding Supporting Documents and Follow-up Reports

This article is based on the following materials published as of November 2026.

• Operational Guidelines for Accepting Foreign Nationals with Specified Skilled Worker Status in Specific Fields (Automotive Maintenance Field), Revised February 15, Reiwa 6
• Operational Guidelines for the “Specified Skilled Worker” and “Training-Based Employment” Programs in the Automotive Maintenance Sector (Approved by the Cabinet on January 23, Reiwa 8)
• Japan Immigration Services Agency: “Job Descriptions for Each Field Under the Specified Skilled Worker (Category 1) Program”
• Hokkaido Regional Transport Bureau: “Acceptance of Foreign Workers in the Automotive Maintenance Sector”

We will update this article with any information regarding revisions to the operational guidelines or procedures following the launch of the new system in April 2027.

Whether an individual application is accepted or rejected will be determined through a review based on the details of the application. If you need to confirm details regarding the start date or job responsibilities, please contact our office.

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• Requirements for Accepting Workers Under the “Automotive Maintenance” Specific Skilled Worker Program: Why Are the Companies’ Conditions So Strict?