Why Are Japanese Salaries Even Reviewed Under the Specific Skilled Worker Program for Construction? An Administrative Scrivener Explains How “Comparable Japanese Workers” Are Selected

Introduction

When you apply for a Specific Skilled Worker in Construction Acceptance Plan, the review covers not only the salaries of foreign workers but also the salaries of Japanese employees at your company. Companies are often asked to submit payroll records and employment histories, and many are surprised to find that “even the salaries of Japanese employees are being examined.”

In this article, I will explain—drawing on my practical experience—why Japanese salaries are subject to review and how to select appropriate Japanese comparators. For information on the minimum salary for foreign workers (1.1 times the minimum wage), please refer to a separate article titled “Why Must Salaries for Specific Skilled Workers in Construction Be at Least ‘1.1 Times the Minimum Wage’?”

*This article is intended for foreign workers with Category 1 Specific Skilled Worker status.

Why Are Even Japanese People’s Salaries Subject to Review?

According to a notice from the Ministry of Land, Infrastructure, Transport and Tourism (March 28, Reiwa 4), the following two factors regarding the salaries of Japanese nationals used for comparison will be reviewed:

・Is the foreign worker’s salary unfairly lower than that of the Japanese worker? This is to prevent foreign workers from being hired at lower wages than Japanese workers.
・Is the Japanese worker’s salary below one times the minimum wage? If it is, the employer will not be recognized as having “made efforts to recruit workers domestically by offering appropriate compensation and working conditions,” and the recruitment plan will not be approved.

Second, no matter how high we set wages for foreign workers, the system won’t be accepted if wages for Japanese workers remain low. This point clearly illustrates the underlying philosophy of this system.

The Specified Skilled Worker program is a system that permits the acceptance of foreign workers only in industries facing labor shortages despite efforts to recruit domestically. The construction industry is a prime example. Once construction sites are able to operate smoothly through the acceptance of foreign workers, the next step is to stabilize wages and working conditions and maintain employment.

Furthermore, these improvements in working conditions are not limited to foreign workers. The goal is to improve conditions for all employees—including the Japanese workers on-site—to increase retention rates and build strong companies. Through these cumulative efforts, the construction industry as a whole will be revitalized. Our firm believes that this is the underlying objective behind the requirement to review even the wages of Japanese workers.

Conversely, this also means that companies unable to improve working conditions for Japanese employees will not be able to utilize this system. Understanding that the Specified Skilled Worker program is not merely a system to fill labor shortages with foreign workers, but rather a system designed to support companies committed to improving working conditions, will help clarify the rationale behind the review process.

How to Select Japanese People for Comparison

Why Is “3 Years of Experience” the Standard?

The reason 3 to 5 years of experience is used as the standard is that foreign workers with “Specific Skilled Worker” status are treated as equivalent to “individuals with approximately 3 years of practical experience.” Those who have completed Technical Intern Training Program Category 2 have generally gained about 3 years of experience at actual construction sites. While the actual number of years of experience varies among those who pass the exam, they are individuals who have been assessed as having a skill level equivalent to that of Technical Intern Training Program Category 2 graduates.

The Ministry of Land, Infrastructure, Transport and Tourism (MLIT) guidelines also explain that for companies whose Hello Work job postings state “No experience required; monthly salary starting at 250,000 yen,” the salary for a Specified Skilled Foreign Worker who has passed the exam must be “250,000 yen plus the amount equivalent to three years of pay raises.” This example illustrates the approach of setting salaries based on the assumption that the worker has approximately three years of experience, regardless of their actual years of experience.

In practice, Japanese nationals with a cumulative total of 3 to 20 years of experience in the same job category and performing the same tasks are often used as a benchmark; in some cases, certain Regional Development Bureaus have even accepted those with less than 30 years of experience. On the other hand, Japanese nationals with less than 3 years of experience are generally not accepted as a benchmark by many Regional Development Bureaus. This is because even when compared to a foreign national, they cannot be considered “Japanese nationals with equivalent skills.”

Years of experience refers to “the total number of years at this company and other companies.”

When comparing Japanese candidates, the total years of experience include not only their time at your company but also the time spent in the same position at other companies. Even an employee in their second year at your company can be considered to have a total of 7 years of experience if they performed the same duties for 5 years at a previous employer. On the resume, list experience at your company and experience at other companies separately.

When Foreign Workers’ Salaries Are Lower Than Those of Japanese Workers

The standard is “equal to or higher than that of a Japanese national with equivalent skills.” The guidelines also state that salary differences based on differences in years of experience are permitted. On the other hand, salary differences based on Japanese language proficiency are not permitted.

So, are there cases where it is acceptable for a foreign national’s salary to be lower than that of a Japanese national? When our firm previously checked with the Regional Development Bureau, “Even if the salary is lower, it is acceptable as long as there is a valid reason. However, since this is rarely approved, it is safer to set the salary at a level equal to or higher than that of Japanese nationals.”

Our firm has never filed an application where a foreign national’s salary was lower than that of the Japanese national used as a comparison. Rather than explaining the reason for the difference and making repeated amendments, setting the salary at a level equal to or higher from the outset ultimately shortens the time required for approval.

If there are no Japanese people to compare with

If there are no Japanese skilled workers in the same occupation, demonstrate that the foreign worker’s salary is reasonable based on one of the following:

・Wage Regulations and Work Rules: These specify the salary amounts to be paid to employees with approximately 3 years (or approximately 5 years) of experience. As a general rule, only those filed with the Labor Standards Inspection Office are applicable.
・Statistical Data: We refer to wage levels for the relevant prefecture, the construction industry, and years of experience, as reported in the Ministry of Health, Labor and Welfare’s “Basic Survey on Wage Structure.”

However, based on our firm’s experience, the figures from the Basic Survey on Wage Structure tend to be on the high side. If you base your pay on these figures, foreign employees’ salaries may end up being higher than those of your Japanese employees, so we do not generally recommend this approach.

For companies that do not have Japanese employees with comparable experience, establishing a wage policy that sets salaries based on years of experience is one step in preparing to hire foreign workers. However, simply filing the policy is not sufficient; the policy must align with actual salaries, and the amounts specified must be reasonable.

Support from the Nasu Administrative Scrivener Office

Our firm provides comprehensive support for the preparation and submission of applications for the Specific Skilled Worker (Construction) Acceptance Plan, covering everything from selecting Japanese employees for comparison to preparing statements of compensation and resumes. Please feel free to consult with us even if you’re at the stage where you’re unsure who to use as a comparison or don’t have any Japanese employees to compare with.

Reference Materials (Verified in October 2026)

Ministry of Land, Infrastructure, Transport and Tourism, “Notice Regarding the Certification of Remuneration Amounts in Specific Skilled Worker Acceptance Plans for the Construction Sector” (March 28, Reiwa 4)

https://www.mlit.go.jp/tochi_fudousan_kensetsugyo/content/001473553.pdf

Ministry of Land, Infrastructure, Transport and Tourism: “Regarding Online Applications for the Construction-Specific Skills Worker Acceptance Plan [New]” (April 4, 2025)

https://www.mlit.go.jp/tochi_fudousan_kensetsugyo/content/001603430.pdf

Ministry of Health, Labor and Welfare, “Basic Survey on Wage Structure” (e-Stat)

https://www.e-stat.go.jp/stat-search/files?tclass=000001229518&cycle=0