In Japan, many employment-law duties switch on at fixed headcounts. A company with a handful of staff must already give written terms, insure everyone and make sure people take five days of paid leave. At 10 people in a workplace it needs written work rules; at 50, an occupational physician, a health committee and annual stress checks; at 101 employees, action plans and disclosure under the women's advancement and next-generation laws; and above 300, wider public disclosure on gender pay, mid-career hiring and fathers' parental leave. Several of these thresholds are moving: the rules for part-timers' social insurance, stress checks and employment insurance are already legislated to change between 2026 and 2035.
Two things decide which rules apply. Whether the count is per company or per workplace: health and safety duties count the people at each workplace (事業場), so a company of 500 spread across offices of 30 may have no workplace at the 50 threshold. Disclosure and action-plan duties count the whole company. And who counts: most company-level duties count regularly employed workers (常時雇用する労働者), including fixed-term staff employed for a long period, not only permanent employees. Check the definition in each law before deciding a threshold does not apply.
At a glance
| Headcount | Counted per | What switches on |
|---|---|---|
| 1+ | Company / workplace | Written terms of employment, accident and employment insurance, health insurance and pension for corporations, five days of paid leave taken, a 36 agreement for any overtime, the annual older-workers report |
| 10+ | Workplace | Written work rules filed with the labour inspection office; a health promoter (10–49) |
| 37.5+ | Company | Disability employment quota (2.7% since 1 July 2026) |
| 50+ | Workplace | Occupational physician, health officer, monthly health committee, annual stress check, filing health check-up results |
| 51+ | Company | Part-timers working 20+ hours a week join health insurance and pension (threshold falling in stages to 2035) |
| 101+ | Company | Women's advancement action plan and disclosure (pay gap and women managers since April 2026); next-generation action plan; disability employment levy if the quota is missed |
| 301+ | Company | Wider women's advancement disclosure; mid-career hiring ratio; fathers' parental-leave uptake |
| 1,000+ | Workplace | Full-time occupational physician; a full-time health officer above 1,000 |
From the first employee
- Written terms. Every new hire receives written working conditions, including, since April 2024, the scope of possible changes to their place of work and duties (Labour Standards Act Enforcement Regulations).
- Insurance. Every business that employs anyone is covered by workers' accident insurance (労災保険) and employment insurance (雇用保険) for staff scheduled for 20 or more hours a week. From 1 October 2028 the employment insurance floor falls to 10 hours a week.
- Health insurance and pension. A corporation is a compulsory workplace for health insurance and the employees' pension from its first regular employee (Health Insurance Act).
- Paid leave. Anyone entitled to 10 or more days of annual leave must actually take at least five a year; the employer designates dates if they do not (Labour Standards Act).
- Overtime. Any work beyond statutory hours or on statutory rest days needs a labour-management agreement (36協定, the "36 agreement") concluded and filed for each workplace. There is no size floor.
- Older workers. Every employer files an annual report on its retirement age and continued employment to 65 and measures to 70 (高年齢者雇用状況等報告).
A small exception runs the other way: workplaces of fewer than 10 people in commerce, entertainment, health and hospitality may use a 44-hour statutory week instead of 40.
10 employees in a workplace: work rules
At 10 or more workers in a workplace, the employer must write work rules (就業規則), consult the majority union or an employee representative, and file them with the labour inspection office, and do the same for every change (Labour Standards Act, art. 89). Workplaces of 10 to 49 also appoint a health promoter (衛生推進者), or a safety-and-health promoter in industries that need a safety manager (Industrial Safety and Health Act regulations).
Work rules are where Japanese employment terms really live. A foreign company that issues only its global handbook, or only individual contracts, is missing the document labour inspectors and courts look at first.
37.5 employees: the disability employment quota
Employers must employ people with disabilities at the statutory rate: 2.7% since 1 July 2026 (2.5% until then), which means the duty to employ at least one person starts at 37.5 regular workers, counted across the company, with short-time workers counting as half (Cabinet Order). Employers with more than 100 workers that miss the quota pay a levy (障害者雇用納付金); smaller employers that exceed it can receive payments.
50 employees in a workplace: health and safety
At 50 or more workers in a workplace (Industrial Safety and Health Act Order):
- appoint an occupational physician (産業医);
- appoint health officers (衛生管理者): one up to 200 workers, rising to six above 3,000;
- hold a health committee (衛生委員会) every month, and in specified industries a safety committee and a safety manager;
- run the annual stress check with doctor interviews on request, and report the results (Industrial Safety and Health Act);
- file the results of periodic health check-ups with the labour inspection office.
From 1 April 2028, stress checks become mandatory at workplaces of every size, not only those with 50 or more.
51 employees: part-timers join social insurance
Employers with more than 50 people insured under health insurance and the employees' pension must also enrol part-timers who work 20 or more hours a week (students excepted). The ¥88,000 monthly-wage condition was abolished on 1 October 2026, so hours now decide. The company-size condition is being removed in stages (labour ministry):
| From | Employers covered |
|---|---|
| 1 October 2024 | More than 50 insured |
| 1 October 2027 | More than 35 insured |
| 1 October 2029 | More than 20 insured |
| 1 October 2032 | More than 10 insured |
| 1 October 2035 | All employers |
For a company with many part-time staff, this is the threshold with the largest cost.
101 employees: action plans and disclosure
At more than 100 regularly employed workers, counted across the company:
- Women's advancement action plan. Analyse women's hiring, tenure, hours and management share; set targets; file the plan; publish it and tell staff (女性活躍推進法, 101+ since April 2022).
- Women's advancement disclosure. Since 1 April 2026, employers with 101 to 300 workers must publish the gender pay gap and the share of women in management, plus at least one other item.
- Next-generation action plan on supporting staff with children, filed with the labour bureau (次世代育成支援対策推進法). Plans made or changed since April 2025 must review parental-leave uptake and set numerical targets.
- Disability levy if the employment quota is missed (see above).
301 employees: wider disclosure
At more than 300 regularly employed workers, the company must also publish:
- Under the women's advancement law, at least four items: the gender pay gap (since July 2022), the share of women managers (since April 2026), and others from the prescribed list.
- The ratio of mid-career hires among regular employees hired, for recent years, at least once a year (労働施策総合推進法).
- Fathers' parental-leave uptake, at least once a year (育児・介護休業法; extended from 1,001+ employers to 301+ on 1 April 2025).
Listed companies report most of these figures in their annual securities report as well. The site's company pages show them for every listed company.
Larger thresholds
- 1,000 workers in a workplace: a full-time occupational physician; above 1,000, a full-time health officer.
- Industry-specific managers: a general safety and health manager at 100 (forestry, mining, construction, transport, cleaning), 300 (manufacturing and some others) or 1,000 (other industries, including offices).
- Company health insurance society (健康保険組合): possible with 700 or more insured, or 3,000 for several employers jointly.
- Separations: notify Hello Work a month ahead if 30 or more workers will leave one workplace within a month, and separately if five or more older workers, as the law defines them, leave within a month for dismissal-type reasons.
The HR team that fits each size
The thresholds shape what HR has to do; the business shapes how it is organised. A sketch for a foreign company in Japan:
| Size in Japan | Typical set-up | What to get right |
|---|---|---|
| Under 50 | One HR generalist, or a country manager with an outsourced payroll and social-insurance provider (社労士) | Work rules at 10, the 36 agreement before anyone works overtime, written terms that match Japanese law, five days' leave tracked |
| 50 to 300 | An HR manager with one or two specialists; payroll still outsourced; the first HR business partner for the main business | Occupational physician and stress checks per workplace, the disability quota, part-timer social insurance, the 101 action plans and disclosure |
| 300 to 1,000 | HR business partners by business, specialists in reward and talent acquisition, an HR operations team | 301 disclosure, a defensible grading and pay structure, mid-career hiring at scale, data for the disclosures |
| 1,000 and more | The three-pillar structure: business partners, centres of expertise, shared services; people analytics; a CHRO or HR director on the leadership team | Full-time health staff, consistent figures across the annual securities report and global reporting, succession and talent reviews |
The Ulrich model guide explains the three-pillar structure; the chief people officer guide describes the top HR role.
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Questions
What does a company with 10 employees in Japan need?
Each workplace with 10 or more workers must write work rules, consult an employee representative, and file them with the labour inspection office, and appoint a health promoter. Duties from the first employee also apply: written terms, accident and employment insurance, five days of paid leave taken, and a 36 agreement for any overtime.
What are the obligations at 50 employees in Japan?
At 50 or more workers in a workplace: an occupational physician, a health officer, a monthly health committee, the annual stress check and filing health check-up results. Stress checks become mandatory for smaller workplaces too from 1 April 2028. Separately, employers with more than 50 insured must enrol part-timers working 20 or more hours a week in health insurance and pension.
What changes at 101 employees in Japan?
Employers with more than 100 regular workers must draw up and publish action plans under the women's advancement and next-generation laws, and since 1 April 2026 must publish the gender pay gap and the share of women managers. The disability employment levy also applies above 100 if the quota is missed.
What changes at 301 employees in Japan?
Employers with more than 300 regular workers publish at least four women's advancement items (including the pay gap and the share of women managers), the ratio of mid-career hires, and fathers' parental-leave uptake each year.
Are thresholds counted per company or per workplace?
It depends on the law. Work rules and the health and safety duties (occupational physician, health committee, stress checks) count workers at each workplace. Action plans, disclosure, the disability quota and part-timer social insurance count across the company.
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By Yan Sen Lu, Managing Director of Makana Partners and Editor of The Hardest Market.
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