What changes
A ministerial ordinance and two guideline notices promulgated on 28 April 2026 took effect on 1 October 2026.
First, the written statement of terms on hiring must now say that the worker can ask the employer to explain the content of, and reasons for, any difference in treatment compared with regular employees. For part-time and fixed-term workers this is added to the existing list of items (pay rises, bonuses, retirement allowances, and who to consult). For dispatched workers, the agency must include it both when it hires the worker, including on renewal, and when it dispatches them.
Second, the equal-pay guidelines, which say when a difference in treatment is unreasonable, were revised in light of recent court rulings. Retirement allowances get their own section, and the guidelines now also address no-accident allowances, family allowances, housing allowances, summer and winter holidays and long-service awards, with more detail on bonuses and paid sick leave. A parallel revision to the employment management guideline encourages pay improvements based on fair evaluation.
The underlying statutes have not changed. The right to an explanation has existed since 2020; what is new is that workers must be told about it in writing.
Who it applies to
Any employer with part-time or fixed-term staff, including re-employed retirees and contract specialists. For dispatch, the agency carries the statement duty; the client should expect agencies to ask for more information on its own staff's pay.
Action for employers
- Update your hiring and renewal templates. Terms issued from 1 October 2026 without the new statement are non-compliant. The ministry has published revised model forms.
- Audit allowances against the new list. Family, housing and retirement allowances paid only to regular staff need a written rationale tied to their purpose.
- Prepare explanations before anyone asks. Expect more requests once the right is printed on every contract.
- Ask your staffing agencies how they are complying. Their pay data requests and fees may change.
Sources
- Ordinance of the Ministry of Health, Labour and Welfare No. 87 of 2026, promulgated 28 April 2026, amending the enforcement regulations of the Part-Time and Fixed-Term Employment Act and the Worker Dispatch Act.
- Ministry of Health, Labour and Welfare Notices No. 202 and No. 203 of 2026 (employment management guideline and Equal Pay for Equal Work Guidelines).
- Osaka Labour Bureau, notice on the 1 October 2026 changes for dispatched workers.