The same term covers two separate plans under two laws, and most employers above the threshold need both.
Under the Act on Promotion of Women's Participation and Advancement in the Workplace, employers with 101 or more employees must analyse a set of basic data, including the share of women hired, the difference in average tenure between men and women, working hours and the share of women in management, then set a plan period, at least one numerical target and the measures to reach it. Employers with 301 or more must set targets in two categories, career opportunities for women and work-life balance. The threshold fell from 301 to 101 on 1 April 2022. From 1 April 2026 the guidelines also ask employers to consider women's health in their plans.
Under the Next-Generation Act, employers with 101 or more employees must plan how they will support employees raising children. For plans drawn up or changed from 1 April 2025, they must first check men's childcare leave uptake and full-time employees' overtime, then set numerical targets on both.
In each case the plan is published, communicated to employees and notified to the prefectural labour bureau. Employers with 100 or fewer employees are asked to make an effort, but are not obliged. A completed plan is the starting point for eruboshi and kurumin certification.
What it means for a foreign employer
- Crossing 100 employees triggers both plans. Growing subsidiaries often miss the moment. Build the threshold into your Japan headcount planning, along with the pay gap disclosure that now comes with it.
- Targets are public, so pick ones you can hit. The plan is visible to candidates and to the labour bureau. A realistic target that you meet is better than an ambitious one you abandon.
- The headcount counts people regularly employed. That includes fixed-term staff employed for more than a year or expected to be, not just seishain. Check with your payroll provider.
- It is cheap insurance. Failure to file draws labour bureau guidance and recommendations rather than fines, but it also rules out certification and procurement points.
Sources
- Act on Promotion of Women's Participation and Advancement in the Workplace, Article 8; as amended in 2019 (101-employee threshold from 1 April 2022) and by Act No. 63 of 2025.
- Act on Advancement of Measures to Support Raising Next-Generation Children, Article 12, as amended 2024 (numerical targets from 1 April 2025).
- Ministry of Health, Labour and Welfare, Kurumin certification guide (2025 revision).