Health and Safety in Japan: 9 Duties for a Tokyo Office
Japan is one of the more structured occupational health jurisdictions in the world, and foreign parents opening in Tokyo consistently underestimate it for the same reason: the obligations are about health rather than safety, and an office with no obvious hazards feels like it should have very little to do.
It has a great deal to do. Japan requires a medical examination for every regularly employed worker from the first hire, a psychological assessment programme that is currently expanding to cover every workplace in the country, and a set of appointments that switch on sharply at 50 employees.
Two significant changes also landed recently, which is why material written even a couple of years ago is now incomplete.
Nine duties, under the Industrial Safety and Health Act of 1972.
1. The duty of care is broad and judicially developed
Beyond the Act itself sits a general obligation known as anzen hairyo gimu, the employer's duty of care for the safety and health of employees.
It requires reasonable measures to prevent injury, illness and psychological harm, and it covers environmental and psychological factors rather than physical hazards alone. Poor ergonomics, noise, temperature and work stress all fall within it.
Importantly, it is reported as extending to dispatched workers, meaning agency staff placed with you even though you are not their direct employer. A group relying on the agency relationship to transfer responsibility has misread the position.
2. Annual health checks, from your first hire
The obligation that surprises British employers most.
Under Article 66 of the Act, every employer must arrange an annual medical examination for all regularly employed workers, regardless of company size, industry or the worker's nationality. A predetermined examination is also required when a worker is taken on as a regular employee.
Two points that matter. The employer bears the cost, and it cannot be passed to employees. And workers on night shifts or in specified categories of work require examinations twice yearly rather than annually. JETRO's guidance on safety and hygiene summarises the position for foreign investors.
So a five-person representative office in Tokyo has a health surveillance obligation that a comparable British office does not.
3. Fifty employees changes everything
Need Expert H&S Guidance?
Our qualified consultants can help you implement the right health & safety measures for your business.
The threshold where the architecture appears.
At 50 or more regularly employed workers, an employer must appoint an industrial physician from among medical doctors, appoint a certified safety and health manager, and establish a health committee or safety and health committee.
Below 50, those appointments are not required, though forming a committee is encouraged.
This is a genuine cliff rather than a gradual increase, and it is worth planning for before you cross it. Recruiting an industrial physician is not something to start on the day you make your fiftieth hire.
4. The industrial physician's recommendations carry weight
A provision that distinguishes Japan from jurisdictions where occupational health advice is advisory in practice as well as name.
Where an industrial physician considers it necessary for a worker's health, they may issue recommendations to the employer regarding healthcare and related duties, and the employer must respect them. Having received a recommendation, the employer must report its substance and other prescribed particulars to the health committee.
So the advice does not simply arrive and sit. It goes to a committee, which creates a record of what was recommended and what the employer did.
5. The stress check programme
The most distinctive element of the Japanese system, introduced by a 2015 amendment.
The stress check is an annual assessment of workers' psychological burden using a standardised questionnaire, typically of 57 items. It has applied to workplaces with 50 or more employees, with results handled confidentially and follow-up available where indicated.
For an organisation used to treating psychological wellbeing as a voluntary programme, this is a statutory annual process with a medical practitioner involved.
6. Stress checks are being extended to every workplace
The change that makes older guidance out of date.
A revised Act promulgated on 14 May 2025 extends the mandatory stress check from workplaces with 50 or more employees to all workplaces regardless of size. Previously, for smaller employers, it was an effort obligation only.
The enforcement date is to be designated by Cabinet Order within three years of promulgation, with implementation expected by around 2028. Smaller workplaces are expected to be exempt from reporting to the Labour Standards Office while still being required to conduct the checks, and the ministry published an implementation manual for small workplaces in February 2026.
Since the check requires a medical practitioner and smaller workplaces need not appoint an industrial physician, outsourcing is the practical route. Confirm the current commencement position, because the date had not been fixed at the time of writing.
7. Contractors and sole proprietors are now inside the Act
The second recent change, and it took effect this year.
Amendments taking effect in phases from 1 April 2026 recognise sole proprietors working alongside employees both as protected parties and as parties with obligations. Employers engaging contractors are required to extend occupational health and safety measures to cover contractors and sole proprietors. Accident reporting requirements now also apply to incidents involving sole proprietors, and operators managing hazardous worksites must coordinate safety measures for all personnel present.
The background is a 2021 Supreme Court decision holding that the Act's protective purpose extends beyond a formal employment relationship to people working at the same site without a labour contract.
For a group using contractors in Japan, this closes the gap that a service agreement used to leave open.
8. Long hours trigger a medical consultation
The obligation that connects working time to health, and it is specific.
Workers performing more than 80 hours of overtime in a month who show signs of accumulated fatigue must be offered a medical consultation with a physician.
That is a concrete trigger a group can build into its systems, and it requires somebody to be watching hours with health in mind rather than only payroll.
9. Prevention, reporting and recent additions
The ordinary machinery, plus two current developments.
Employers must carry out risk assessments, provide protective equipment, conduct regular inspections and ensure adequate training, and must educate a worker on safety and hygiene for their work when they are newly employed. Where a medical examination identifies abnormalities, the employer must obtain a physician's opinion and take appropriate measures, including adjusting duties or working hours.
Two recent additions reported alongside these: specific heat stress prevention measures where high-temperature risks exist, applying from mid-2025, and a broader move toward digital reporting.
What a Tokyo entity needs
| Duty | Threshold | Common gap |
|---|---|---|
| Duty of care | Always; includes dispatched workers | Assumed transferred to the agency |
| Health examinations | From the first regular hire | Not arranged at all |
| Cost of examinations | Employer bears it | Passed to employees |
| Industrial physician | 50 employees | Started too late |
| Safety and health manager, committee | 50 employees | Not planned for |
| Physician recommendations | Must be respected, reported to committee | Treated as advisory |
| Stress check | 50 employees now, all workplaces by around 2028 | Not run |
| Contractors and sole proprietors | From April 2026 | Service agreement assumed sufficient |
| Overtime consultation | Over 80 hours in a month with fatigue | Hours watched only for pay |
Rows two and seven are where a foreign parent is most likely to be in breach without knowing it, and row four is the one to plan a year ahead of.
Japan in the Asia-Pacific picture
Japan sits at the structured end of a region this series has mapped across several jurisdictions.
Thailand requires a formal safety management system and prescribed officer appointments. Indonesia's SMK3 obligation is audited by a licensed body and graded. Malaysia has extended duties to reach a much wider range of workplaces. Japan requires medical examinations from the first employee, appointments at fifty, and a psychological assessment programme moving toward universal coverage.
Not one of those frameworks is satisfied by another's documents, and Japan's health-led approach is the least like the British model of any of them. The ILO publishes the international standards these national systems align to.
Holding each entity's appointments, examination cycles and assessments in one register is where health and safety consultants and software are worth more together than either alone, and periodic health and safety audits establish whether an entity is meeting its own national requirements rather than the group's.
Where Arinite fits
Arinite coordinates locally qualified practitioners in Japan, so the examinations, appointments and stress check obligations are handled by people entitled to do so, while your group keeps one point of contact across every country. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years.
Our health and safety consultants work extensively with finance and banking, IT and software and professional services organisations, which describes most foreign-owned headcount in Tokyo.
Our global health and safety consultants handle the regional jurisdictions that usually accompany a Japanese entity, and our international health and safety consultants can establish what is outstanding locally.
If your Tokyo entity has employees and nobody has arranged an annual health examination, a free gap analysis is the right place to start.
Related Articles
Written by
Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
