Whistleblower Protection Act: criminal penalties for retaliation

From 1 December 2026, dismissing or disciplining someone because they made a protected report becomes a crime: up to six months' detention or a 300,000 yen fine for the individual, and up to 30 million yen for the company. Dismissal or discipline within a year of a report is presumed to be retaliation.

Status
Coming up
Effective
1 December 2026
Decided
11 June 2025
Type
Statute amendment
Applies to
All employers; the internal reporting system duty applies above 300 employees

What changes

The 2025 amendment to the Whistleblower Protection Act (Act No. 62 of 2025, promulgated 11 June 2025) turns retaliation from a civil wrong into a criminal offence. Dismissing or disciplining an employee because they made a protected report can now be punished with up to six months' detention or a fine of up to 300,000 yen for the person responsible, and a fine of up to 30 million yen for the company.

It also shifts the burden of proof. If an employer dismisses or disciplines someone within one year of their report, the law presumes the action was retaliation, and the employer has to show otherwise.

Who it applies to

Every employer in Japan, foreign subsidiaries and branches included. Employers with more than 300 employees have had to run an internal reporting system and designate the staff who handle reports since June 2022; that duty continues.

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.