Where the Equal Employment Opportunity Act bans discrimination, the Women's Advancement Act asks employers to show progress. It works through disclosure and planning rather than prohibition. An employer covered by it must first analyse its own position, at minimum the share of women among new hires, the gap in length of service between men and women, working hours and the share of women in management. It must then adopt a general employer action plan with at least one numerical target, notify the prefectural labour bureau, tell employees and publish the plan, and publish a set of data on women's careers.
Coverage has widened in stages. When the Act took effect in April 2016 the duties applied to employers with 301 or more regular workers. They were extended to those with 101 or more from April 2022. From July 2022, employers with 301 or more had to publish the gender pay gap, broken down for all workers, regular employees and non-regular employees. A 2025 amendment, in force from April 2026, extends the pay gap duty to employers with 101 or more and adds the female manager ratio to the mandatory disclosures. It also extends the Act, originally a ten-year measure due to expire in March 2026, to March 2036.
Employers that perform well can apply for eruboshi certification, which some use in recruitment and which counts in some public procurement scoring. The national picture is still modest: in the labour ministry's fiscal 2025 survey, women held 13.2% of section chief posts and 9.2% of department head posts.
What it means for a foreign employer
- Most Japan entities above 100 staff are now in scope. Headcount is per employing entity in Japan, not the global group. Check the number each April.
- Your pay gap will be public. The figure is a simple ratio of average pay, so a sales-heavy male workforce and a female support function produce a wide gap regardless of equal pay. Publish the explanation alongside it.
- Candidates read the data. Senior women considering a move check the published figures and the action plan. A credible plan helps recruitment.
- Targets need a pipeline. A female manager target cannot be met by promotion alone in a small entity. It usually needs external senior hires, which take time in this market.
Sources
- Act on Promotion of Women's Participation and Advancement in the Workplace (2015), as amended in 2019 and 2025 (in force April 2026).
- Ordinance under the Act, as amended July 2022 (gender pay gap disclosure).
- Ministry of Health, Labour and Welfare, Basic Survey on Equal Employment, fiscal 2025.