What changes
The 2025 amendment to the Women's Advancement Act (part of Act No. 63 of 2025, promulgated 11 June 2025, in force 1 April 2026) makes two figures mandatory for mid-sized employers. Until now only employers with 301 or more employees had to publish the gender pay gap, and the female manager ratio was optional.
The minimum disclosure is now:
- 301 or more employees: the pay gap, the female manager ratio, at least one item on career opportunities for women and at least one on work-life balance (four items or more).
- 101 to 300 employees: the pay gap, the female manager ratio and at least one other item (three items or more).
The pay gap is shown for all workers, regular employees and non-regular employees. A manager means section-manager level or above, excluding directors. The first disclosure covers the first fiscal year ending after 1 April 2026 and is due within about three months of the next year starting. The amendment also extends the Act, which was due to expire on 31 March 2026, to 31 March 2036, and states that women's advancement should take account of women's health.
Who it applies to
Every employing entity in Japan with 101 or more regular employees, counted per entity, not per global group. Foreign subsidiaries and branches are covered on the same basis.
Action for employers
- Check your headcount now. An entity that has crossed 100 employees is in scope, whether or not it has ever filed an action plan.
- Run the numbers before the deadline. For a March year end, the year to March 2027 is the first period; publish by around the end of June 2027.
- Map titles to the legal definition of manager. Disclosure follows the role, not the business card, so audit how gaishi manager titles fit before you calculate.
- Use the explanation field. Publish on the ministry's women's advancement database and explain the causes behind a wide gap rather than leaving a bare figure.
Sources
- Act on Promotion of Women's Participation and Advancement in the Workplace, as amended by Act No. 63 of 2025 (promulgated 11 June 2025, in force 1 April 2026); ordinance and guidelines amended 23 December 2025.
- Ministry of Health, Labour and Welfare, leaflet on the amended Women's Advancement Act (revised 18 February 2026).
- Cabinet Office Gender Equality Bureau, briefing on the amendment of the Women's Advancement Act (January 2026).