Introduction
By the end of 2026, Japan will implement a series of significant amendments to labor and occupational health and safety regulations, reflecting a growing emphasis on workplace safety. These changes, driven by forthcoming guidelines from the Ministry of Health, Labour and Welfare (MHLW), will require employers to adopt new compliance measures across a range of areas, including prevention of customer harassment, support for work-life balance, prevention of sexual harassment, gender pay gap transparency, and occupational health and safety for various worker categories. In this newsletter, we outline key legal developments and employer compliance obligations.
1. Amendment to the Comprehensive Promotion of Labor Policies Act
a. Measures Against Customer Harassment
Effective October 1, 2026 (tentative), employers will be required to take appropriate measures to prevent customer harassment in the workplace. For these purposes, “customer harassment” is defined as conduct by third parties, including customers, business partners, or facility users, that exceeds the bounds of socially acceptable behavior and adversely affects employees’ working environment. Employers will be required to implement measures in accordance with forthcoming MHLW guidelines, which may include establishing policies for the prevention of customer harassment and putting in place a designated contact point for affected employees to seek support or report incidents.
b. Balancing Work and Treatment
From April 1, 2026, employers will be required to make reasonable efforts to accommodate employees who are balancing medical treatment and work responsibilities. Such measures should align with MHLW guidelines, with a focus on creating a supportive work environment for employees managing ongoing health conditions.
2. Sexual Harassment Prevention for Job Seekers
Employers will be required to implement necessary measures to prevent sexual harassment against job seekers, including students, interns, and other applicants, across all stages of the recruitment process, including interviews, alumni networking (OB/OG) visits, internships, and similar recruitment activities. The required measures will include establishing internal policies and providing training to personnel engaged in recruitment activities, as specified in forthcoming MHLW guidelines. Noncompliance may lead to administrative guidance and public disclosure. The effective date has not been determined but will be specified as a date within 18 months from the promulgation of the amended act.
3. Gender Pay Gap and Female Management Ratio Disclosure
Effective April 1, 2026, employers with 101 or more employees will be required to publicly disclose information regarding gender pay gaps and the percentage of female managers. In addition, disclosure of measures to prevent sexual harassment of job seekers will become a prerequisite for special certification. Employers should take steps now to prepare for these enhanced transparency and disclosure obligations.
4. Amendments to the Industrial Safety and Health Act
a. Safety and Health Measures for Sole Proprietors
The relevant amendments will take effect in phases starting from April 1, 2026. Sole proprietors working alongside employees will be recognized both as protected parties and as parties subject to obligations under the Act. Employers engaging contractors will be required to extend occupational health and safety measures to cover both contractors and sole proprietors. Reporting requirements for occupational accidents will now also apply to incidents involving sole proprietors, and worksite operators managing hazardous worksites will be required to coordinate safety measures for all personnel, including contractors and sole proprietors.
b. Expansion of Stress Check Requirements
All employers, including those with fewer than 50 employees, which were previously exempt from statutory stress check requirements, will be required to conduct stress checks. Employers are encouraged to consult with external service providers regarding the implementation of these requirements. The effective date has not been determined but will be specified as a date within three years from the promulgation of the amended act.
c. Prevention of Occupational Accidents Among Senior Workers
Effective April 1, 2026, employers will be required to make efforts to implement workplace measures tailored to the needs of senior workers, including improving the physical work environment, adjusting job duties and responsibilities, and providing appropriate support and training. These measures should be implemented in accordance with MHLW guidelines to ensure workplace safety and suitability for senior workers.
Conclusion
The forthcoming amendments to Japan’s labor and occupational safety regulations will require employers to proactively review and revise workplace policies, reporting protocols, and health and safety measures. Adhering to new compliance obligations, particularly those detailed in forthcoming MHLW guidelines, will be essential to ensure safe and fair working environments. Employers should closely monitor regulatory developments and take steps to implement the required changes in advance of the effective dates.
December 10, 2025
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Author: Eriko Ogata