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
- List every site and its headcount. A 120-person Tokyo office and a 20-person Osaka branch have different duties until April 2028. After that, both need a stress check.
- Choose a provider during 2027. Health check clinics and employee assistance providers offer packages. Confirm that they can handle the doctor interviews and keep individual results away from local managers.
- Write the rules down. Set out who runs the check, how results are stored, and how a high-stress employee asks for an interview, and tell staff before the first round.
- Keep regional HR out of individual results. Group-level summaries are the useful output for management. Individual results need the employee's consent.
Sources
- Industrial Safety and Health Act, Article 66-10, as amended by the Act partially amending the Industrial Safety and Health Act and the Working Environment Measurement Act (Act No. 33 of 2025), promulgated 14 May 2025.
- Cabinet Order No. 195 of 2026 setting the effective dates of parts of the amending Act, promulgated 10 June 2026.
- Japan Industrial Safety and Health Association, Q&A on stress checks at workplaces with fewer than 50 workers.
- Ministry of Health, Labour and Welfare, implementation manual for the stress check programme at small workplaces.