What changes
The 2025 amendment to the Labour Policies Comprehensive Promotion Act (Act No. 63 of 2025, promulgated 11 June 2025) adds a new Article 33. It requires employers to take employment management measures against customer harassment, in the same way they must already act on power harassment and sexual harassment.
The law defines customer harassment by three elements, all of which must be present: conduct by customers, business partners, facility users or others connected to the business; that goes beyond socially acceptable bounds, given the nature of the employee's work; and that harms the employee's working environment. Conduct by phone or online counts. A legitimate complaint does not.
The ministry guideline issued in February 2026 sets out what employers must do: state a policy that the company will respond firmly and protect staff, and tell staff and managers; set up a consultation point; decide in advance how incidents are handled, including reporting crimes such as assault or threats to the police; support the affected employee; and take deterrence measures. Employers must not treat staff unfavourably for reporting, and should cooperate when another company investigates conduct by their own staff.
Who it applies to
Every employer, of any size. "Customers" includes business clients and prospective clients, so B2B companies are covered as much as retailers.
Action for employers
- Publish a customer harassment policy in Japanese. Add it to your existing harassment framework and work rules if you have not already.
- Write an incident procedure. Say who an employee escalates to, when a manager takes over, when to end a call or meeting, and when to call the police.
- Brief client-facing teams. Account managers need to know they will be backed against a difficult client, however large the account.
- Expect requests from your own clients. If one of your staff is accused of harassing a client's employee, the law asks you to cooperate with their investigation.
Sources
- Labour Policies Comprehensive Promotion Act, Article 33, as amended by Act No. 63 of 2025, promulgated 11 June 2025, in force 1 October 2026.
- Ministry of Health, Labour and Welfare, guideline on employment management measures against customer harassment, February 2026.
- Ministry of Health, Labour and Welfare and prefectural labour bureaus, pamphlet on harassment measures employers must take (2026 edition).