Industrial Safety and Health Act: stress checks become mandatory at workplaces under 50

From 1 April 2028, every workplace with fewer than 50 workers must offer staff an annual stress check, ending the effort-only rule for small sites. The amendment was promulgated on 14 May 2025 and a cabinet order of 10 June 2026 fixed the start date.

Status
Coming up
Effective
1 April 2028
Decided
14 May 2025
Type
Statute amendment
Applies to
Every workplace with fewer than 50 workers; larger workplaces have been covered since December 2015

What changes

The 2025 amendment to the Industrial Safety and Health Act (Act No. 33 of 2025, promulgated 14 May 2025) removes the 50-worker threshold for the annual stress check. Since December 2015, only workplaces with 50 or more workers have had to offer one; smaller sites were asked to make an effort. A cabinet order promulgated on 10 June 2026 set the start date for small workplaces at 1 April 2028.

The rules are otherwise the same. A doctor, public health nurse or other qualified person runs the questionnaire, results go to the employee, and the employer may not see them without consent. An employee assessed as high-stress can ask to see a doctor, and the employer must arrange it and act on the doctor's opinion. To lighten the load, workplaces under 50 will not have to report results to the Labour Standards Inspection Office, but they must keep records. The labour ministry has published an implementation manual for small workplaces and recommends using an outside provider, since few have an in-house doctor and confidentiality is hard to keep in a small team.

Who it applies to

Any workplace with fewer than 50 workers, counted per site, not per company. That covers many foreign subsidiaries in Japan, and the regional branch offices of larger ones.

Action for employers

Sources

General information for employers, not legal advice. Dates and thresholds are checked against the sources listed and dated above; confirm anything you act on with a Japanese employment lawyer or a licensed labour and social security attorney.