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Work Permits · 2026-03-21

就労許可証 vs 就労ビザ:違いと重要性

The terms "work visa" and "work permit" are frequently used interchangeably in everyday conversation — but they are legally distinct documents in many countries. Mixing them up can lead to working illegally even while holding the right to be in the country, or vice versa. This guide clarifies the distinction and explains what it means for your specific situation.

The Simple Distinction

In most immigration systems:

  • A work visa is a document (usually a stamp or sticker in your passport) that authorizes you to enter a country for the purpose of work.
  • A work permit (also called a work authorization) is a document that authorizes you to actually perform work once inside the country.

In some countries, these are combined into one document. In others, they are separate — and you need both.

Country-by-Country Breakdown

United States

The US distinguishes sharply between the two:

  • Work visa (e.g., H-1B, L-1, O-1): Allows entry and work for a specific employer in a specific role
  • Employment Authorization Document (EAD): Work permit issued to certain categories — spouses of H-1B holders (H-4 EAD), asylum seekers, DACA recipients, adjustment-of-status applicants. An EAD allows work for any employer, unrestricted.

Canada

Canada uses "work permit" as the primary term for authorization to work. Most foreign workers need both a work permit (issued on entry or in advance) and in some cases an LMIA (Labour Market Impact Assessment) from the employer. Some permits are "open" (work for any employer) while others are "closed" (employer-specific).

United Kingdom

The UK issues a visa (via a vignette in the passport and a Biometric Residence Permit) that serves as both entry clearance and work authorization. No separate work permit exists. The right to work is built into the visa conditions.

European Union / Schengen Area

EU countries vary. Germany issues a residence permit (Aufenthaltstitel) that includes work authorization. France issues a combined visa de long sejour valant titre de sejour. Some EU countries require separate work authorization obtained by the employer before the visa is applied for.

Australia

Australia uses a single visa system. Work rights are encoded directly into the visa subclass. A subclass 482 (Temporary Skill Shortage) visa holder can work only for the nominated employer; a subclass 189 permanent resident can work freely. There is no separate work permit document.

UAE / Gulf States

The UAE requires both an entry visa (for entry) and a work permit/residency visa issued by the Ministry of Human Resources. These are combined during the standard employment visa process but technically remain two separate approvals. Your employer sponsors both.

Open vs Closed Work Permits

This distinction matters more than the "visa vs permit" terminology in many cases:

TypeDescriptionExamples
Closed/Employer-specificYou can only work for the named employer in the named roleH-1B (US), TSS 482 (Australia), Skilled Worker (UK)
Open/UnrestrictedYou can work for any employer, in any roleUS EAD, Canada open work permit, IEC working holiday
Sector-restrictedYou can work in a defined industry for any employer in that sectorSome EU Blue Card conditions, agricultural work permits

Can You Work Without Both?

This is where people get into trouble. Consider these scenarios:

  • You have a work visa but your employment ends: In employer-tied visa countries (H-1B, UK Skilled Worker), you typically have a 60-day grace period to find new sponsorship, change status, or depart. You cannot simply start working for a new employer.
  • You have an EAD but your underlying status lapses: Your work authorization may terminate even if the EAD card hasn't expired. Always track both documents.
  • You have a tourist visa and plan to work remotely for a foreign company: This is a legal gray area in most countries. Some countries have clarified this (digital nomad visas), but many have not. Tax residency can also be triggered.

Verification and Compliance

Employers in most countries are legally required to verify work authorization before hiring. In the US, this is done via Form I-9. In the UK, it's a Right to Work check. Hiring someone without proper authorization can result in fines of $5,000–$50,000 per violation and criminal charges in serious cases.

Bottom Line

Whether you call it a "work visa" or "work permit" depends largely on which country you're dealing with. What matters practically is: (1) the right to enter the country, and (2) the right to work — and whether those rights are employer-specific or open. Use our visa checker to identify exactly what documentation you need for your target country, or browse our visa guides by destination.