What changes
The Financial Services Agency amended the Cabinet Office Order on Disclosure of Corporate Affairs on 20 February 2026. Three items are added to the employee section of the annual securities report:
- HR strategy linked to business strategy, described on a consolidated basis.
- The policy for deciding employee pay, in light of that strategy. This covers the filing company only; a holding company whose main business is managing subsidiaries also covers its largest subsidiary by headcount.
- The year-on-year change in average annual salary of the filing company's employees, as a percentage, alongside the existing average salary, age and length of service.
The date shown above is not a single start date. The rules apply to reports for fiscal years ending on or after 31 March 2026, so a March year-end company first included them in the report filed around June 2026, and a December year-end company will do so in the report for the year to December 2026. The existing human capital items, including the female manager ratio, male childcare leave uptake and gender pay gap, continue.
Who it applies to
Listed companies and other annual securities report filers. A Japan subsidiary of a foreign group is usually not a filer, but its listed Japanese competitors, customers and joint-venture partners are.
Action for employers
- Benchmark pay against the new figure. Each filer's average salary change is now public; pull it for the Japanese companies you compete with for talent.
- Expect candidates to ask. Staff at listed companies will see their employer's pay policy and salary growth in print, and will compare.
- Brief listed affiliates. If your group has a listed Japanese entity, check that HR and finance agree on the pay policy wording before the next filing.
Sources
- Financial Instruments and Exchange Act, Article 24.
- Cabinet Office Order amending the Cabinet Office Order on Disclosure of Corporate Affairs, promulgated 20 February 2026; Financial Services Agency announcement and public comment results, 20 February 2026.
- Deloitte Japan, commentary on the February 2026 amendments.