[Blog]Key Policy Shift #4 for Employers — Data Integration and My Number Transform Workforce Compliance

2026-01-08

This article is the fourth installment in our five-part series examining immigration measures that represent a clear break from Japan’s traditional immigration policy framework. It is based on the Immigration Services Agency of Japan’s 2025 policy documents and related materials published at Immigration Services Agency: Immigration Policy Framework. In this installment, we focus on one of the most structural changes for employers: the expansion of data integration and the growing role of My Number in immigration and employment compliance.

Foreign Workforce Management Was Previously Fragmented

Until recently, information related to foreign employees was managed in separate administrative silos. Immigration status was handled by the Immigration Services Agency, social insurance by pension offices and health insurers, taxation by tax authorities, and residency information by local governments. Employers could comply by addressing each system independently. Cross-checking between immigration filings and tax or social insurance data was limited, and inconsistencies often went unnoticed unless triggered by audits or investigations.

Turning Point ① Integrated Use of Residence Cards and My Number

The 2025 policy framework clearly signals a shift toward unified identification and data management. Residence cards and My Number are positioned as core identifiers enabling comprehensive oversight of employment, taxation, and social security participation. For employers, this means immigration compliance can no longer be treated as an isolated administrative task. Workforce management, payroll, social insurance enrollment, and immigration status are becoming structurally interconnected.

Turning Point ② Immigration Data Will Be Matched with Other Government Records

The policy materials emphasize enhanced data sharing between national and local authorities. As a result, immigration filings will increasingly be compared against real employment data such as wages, working hours, social insurance enrollment, and tax payments. Situations that were previously difficult to detect—such as full-time visa holders without proper social insurance coverage—are far more likely to be identified under this integrated framework.

Turning Point ③ Minor Inconsistencies Become Compliance Risks

As data integration advances, discrepancies that were once considered minor—late notifications, inconsistent job descriptions, or mismatched working hours—can accumulate into significant compliance concerns. Even without malicious intent, persistent data inconsistencies may be interpreted as weaknesses in an employer’s management system. Employers must therefore maintain accurate, up-to-date, and internally consistent records for foreign employees at all times.

Turning Point ④ My Number as a Systemic Foundation, Not Surveillance

While My Number is sometimes perceived as a monitoring tool, the policy framework presents it as a foundational element of equal treatment. Foreign nationals are increasingly managed under the same administrative infrastructure as Japanese citizens. From an employer perspective, this means that foreign workforce compliance is expected to meet the same standards of accuracy, transparency, and accountability as domestic employment.

Operational Changes Employers Must Prepare For

This policy shift requires employers to rethink internal governance. Immigration compliance must be coordinated across HR, payroll, accounting, and legal functions. Companies relying on overseas headquarters or external vendors must ensure that Japan-based operations retain visibility and responsibility for compliance. Fragmented internal management structures pose growing risks in a data-integrated environment.

Why This Represents a Clear Policy Shift

Traditional immigration administration focused on discrete application events—submission, approval, and renewal. The 2025 framework moves toward continuous oversight enabled by data connectivity. Immigration compliance is no longer episodic but ongoing, with employment conditions monitored throughout the residence period. This structural change marks a decisive break from past practice.

Conclusion

Data integration and the expanded use of My Number are transforming foreign workforce management from a paperwork-based process into a continuous compliance system. While this increases exposure to risk for poorly managed employers, it also creates a fairer environment for companies that maintain robust, lawful employment practices. In the final article of this series, we will examine the broader philosophical shift behind these reforms and what kind of stance employers must adopt in Japan’s evolving immigration landscape.