What changes
The 2025 amendment to the Equal Employment Opportunity Act, made by the same Act No. 63 of 2025 that introduced the customer harassment duty, adds a new Article 13. Employers must take employment management measures so that sexual conduct by their employees does not obstruct the job-seeking activities of applicants and similar people. It came into force on 1 October 2026.
"Job seekers" covers applicants, people taking part in recruitment activities such as internships and information sessions, and students on practical training. "Job-seeking activities" includes interviews, information sessions, internships and visits to employees, including alumni visits, wherever they take place and whether online or in person. The ministry's examples include sexual questions in an interview and repeated private dinner invitations during an internship.
The required measures follow the existing sexual harassment guideline, with additions: clear rules for staff on meeting candidates (time and place, how many staff attend, which messaging tools to use), shared with candidates on the careers site or in materials; a consultation point that job seekers can use, ideally not staffed only by the recruiting team; prompt investigation; and no unfavourable treatment of staff who help with an investigation. Candidates with an offer that forms a contract are covered by the general sexual harassment rules.
Who it applies to
Every employer that recruits. Interviewers, hiring managers, intern supervisors and any employee who meets students are in scope, not only HR.
Action for employers
- Set rules for candidate meetings. Office premises and office hours, two people where possible, company channels only, no alcohol.
- Publish a contact for candidates. Put a harassment consultation contact on the careers page and in internship materials.
- Train interviewers, including regional ones. Personal and sexual questions are now a compliance breach, not only poor practice.
- Cover alumni visits. Tell staff who are contacted by students how such meetings must be run.
Sources
- Equal Employment Opportunity Act, Article 13, 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 measures against sexual harassment in job-seeking activities.
- Ministry of Health, Labour and Welfare and prefectural labour bureaus, pamphlet on harassment measures employers must take (2026 edition).