The disclosure is a single ratio: women's average annual pay expressed as a percentage of men's. It must be shown three ways, for all workers, for regular employees and for non-regular employees, rounded to one decimal place. Employers publish it on their own website or on the Ministry of Health, Labour and Welfare's database of women's advancement data, and update it each year within about three months of the end of the fiscal year. They may add a written explanation of the causes, and the guidelines revised in 2026 encourage them to analyse the factors behind the gap.
The obligation began on 8 July 2022 for employers with 301 or more employees. The amended Act in force from 1 April 2026 extends it to employers with 101 or more. For newly covered employers the first disclosure covers the first fiscal year ending after that date, so a company with a March year end publishes by around the end of June 2027. Listed companies and other annual securities report filers also put the same figure in their yuho.
The national picture is improving slowly. The 2025 Basic Survey on Wage Structure, published in March 2026, put women's average monthly scheduled earnings at 76.6% of men's for full-time workers, the narrowest gap since comparable records began in 1976. The main drivers are well known: fewer women in senior grades, career-track structures, shorter average tenure and allowances tied to household head status.
What it means for a foreign employer
- Check whether your Japan entity is now covered. A subsidiary that crossed 100 employees may have its first disclosure due in 2027 and may not know it.
- Use the explanation box. A raw figure skewed by a mostly male sales force and a mostly female support function can look worse than your pay practice is. Say why.
- Look at allowances. Family and housing allowances paid to the main earner tend to widen the gap. Many companies are folding them into base pay.
- Candidates read the numbers. Senior women, in particular, compare employers on this figure. A narrow gap is a selling point for a gaishi recruiting from Japanese companies.
Sources
- Act on Promotion of Women's Participation and Advancement in the Workplace and its ordinance, disclosure in force 8 July 2022; amended by Act No. 63 of 2025, in force 1 April 2026.
- Ministry of Health, Labour and Welfare, Basic Survey on Wage Structure 2025, published 24 March 2026.
- JILPT forum briefing on the amended Act, February 2026.