[1] The Industrial Safety and Health Act
The Industrial Safety and Health Act requires workplaces with 50 or more regular workers to appoint a health manager and submit reports. Before going into details, let’s check the definitions of terms.
The definition of “worker” under the Industrial Safety and Health Act is the same as the Labor Standards Act, i.e., “a person who is employed at a business or office and paid wages.” Under the Industrial Safety and Health Act, whether a worker is “regularly employed” is determined according to the normal situation of the company. While temporary hiring or vacancy are not taken into the account, part-timer workers must be included in the number of regular workers, unless they are working only temporarily.
Based on the above, companies with 50 or more regular employees have the requirements below. These are the items applied to all industries.
1. Appointment of health managers and reporting
2. Establishment of a health committee
3. Appointment of industrial physicians and reporting
4. Carrying out of stress check and reporting
5. Submitting of regular health check results
Regarding 1, health managers must be appointed by workplace unit. If a company has multiple workplaces with at least 50 workers, a health manager must be appointed for each of them. As for 4, the time of execution is yet to be determined, but all workplaces will become required to conduct stress check in the future, regardless of the number of workers.
[2] Social insurance
From October 2024, companies whose number of workers is more than 50 and up to 100 are required to enroll their part-timers working 20 hours or more in a week in the social insurance system (health insurance, employee pension). Under this rule, the number of workers mean those enrolled in the employee pension system.
The government plans to apply this rule to smaller enterprises in the future, covering companies with 36 or more workers from October 2027. Firms with 21 or more workers and 11 or more workers will also be included from October 2029 and October 2032, respectively. After October 2035, companies with up to 10 workers will become subject to this requirement.
[3] Employment of workers with disabilities
This is not a new requirement for companies with 50 or more employees but we include in this article as supplementary information. Currently, private companies’ mandatory employment rate of persons with disabilities is 2.5%. This rule is applied to firms with 40 or more regular employees, which means workers whose scheduled weekly work hours is 20 hours or more and have been (or are expected to be) employed for over one year. Workers whose scheduled weekly working hours is 30 hours or more are counted as one, while those working 20 hours or more and less than 30 hours are counted as 0.5.
The mandatory employment rate is due to be raised to 2.7% in September 2026. Companies with 37.5 or more regular employees will become required to meet this standard.
Businesses ramping up hiring are advised to check if or when these rules will be applied and make preparations as needed.
[Reference]
The Tokyo Labor Bureau, “Outlines of General Safety and Health Supervisor, Safety Officer, Health Supervisor, and industrial physicians”
https://jsite.mhlw.go.jp/tokyo-roudoukyoku/hourei_seido_tetsuzuki/anzen_eisei/a-kanri.html
The Labor Ministry, “Amendment to the National Pension Act has been enacted”
https://www.mhlw.go.jp/stf/seisakunitsuite/bunya/0000147284_00017.html
“Measures for the employment of persons with disabilities”
*The information is based on laws and regulations as of the date of the original article.
