A checklist for employers
October 1, 2026 is the effective date for five separate regulatory changes, arriving from three different ministries under three different statutes, for reasons that have nothing to do with each other. That’s not unusual — Japan clusters a lot of administrative effective dates at the start of the second half of the fiscal year — but it means an employer checking only for the change they already heard about is likely to miss the other four. Below is the full list, what each one actually requires, and where to read the primary source.
| # | What changes | Governing law | Applies to |
|---|---|---|---|
| 1 | Customer harassment prevention becomes mandatory | Act on Comprehensive Promotion of Labor Measures, Art. 33 | Every employer |
| 2 | Dispatched workers must be told, unprompted, that they can ask about pay gaps | Worker Dispatch Act, Art. 31-2 + equal-pay guideline | Dispatching agencies and host companies |
| 3 | Regional minimum wages rise | Minimum Wage Act | Every employer, staggered by prefecture |
| 4 | The ¥88,000/month wage floor for part-time worker social insurance enrollment disappears | Pension system reform act of 2025 | Employers with part-time staff |
| 5 | Employer-provided housing gets revalued for social insurance premium purposes | MHLW notification on in-kind benefit valuation | Employers providing housing as compensation |
1. Customer harassment prevention becomes mandatory
Employers now have a specific legal duty to protect workers from harassment by customers and business counterparties — not just from coworkers or managers. The duty requires a stated policy, a working consultation channel, and a response plan, enforced the same way Japan’s existing harassment laws are: advice, then a formal recommendation, then public disclosure of persistent non-compliance.
職場において行われる顧客、取引の相手方、施設の利用者その他の当該事業主の行う事業に関係を有する者の言動であって、その雇用する労働者が従事する業務の性質その他の事情に照らして社会通念上許容される範囲を超えたもの
— 労働施策の総合的な推進並びに労働者の雇用の安定及び職業生活の充実等に関する法律 第33条第1項
Conduct by a customer, business counterparty, facility user, or other person connected to the employer’s business, occurring in the workplace, which exceeds the bounds of what is socially permissible.
We covered this in full detail, including the compensation pathway for an affected worker, in Japan’s New Customer Harassment Law.
2. Dispatched workers must be told, unprompted, that they can ask about pay gaps
Japan has required equal pay for dispatched workers since 2020. What changes October 1 is enforcement: a revised guideline sharpens which allowances and bonuses count as unreasonable disparities, and a new disclosure duty means a dispatched worker no longer has to know to ask about a pay gap with a comparable host-company employee — the agency now has to raise the right to ask in the paperwork given at hiring and at every new placement.
We covered the full mechanics, including the host company’s own cooperation duty, in Japan’s Dispatch Worker Pay Reform.
3. Regional minimum wages rise
Japan’s 47 prefectural minimum wages are revised annually, with new rates phased in on a staggered schedule that typically opens October 1 and runs through the following spring, prefecture by prefecture. For fiscal 2026, the central council’s target is a national weighted-average increase of roughly ¥55, moving the average from ¥1,121 to approximately ¥1,176 per hour; Tokyo’s rate is set to reach approximately ¥1,226. These are targets set by the national council as of this writing — each prefecture’s local council still finalizes its own figure and effective date, so the exact rate and date for a given location should be confirmed against that prefecture’s own announcement rather than assumed to be October 1 uniformly.
This is the one item on this list with no exceptions and no phase-in optionality: every hourly rate paid in Japan has to clear the new floor from the local effective date, full stop.
4. The ¥88,000/month wage floor for part-time worker social insurance enrollment disappears
Since 2016, a part-time worker at a covered employer has generally been required to enroll in employees’ health insurance and welfare pension insurance once they cross several thresholds together — including working 20+ hours a week and earning at least ¥88,000 a month. Scheduled for October 1, 2026, the wage threshold is removed entirely, under the pension reform legislation passed in 2025:
社会経済の変化を踏まえた年金制度の機能強化のための国民年金法等の一部を改正する等の法律
— 令和7年6月20日法律第74号
Act Partially Amending the National Pension Act and Related Acts for Strengthening the Function of the Pension System in Light of Changes in the Socio-Economic Environment — Act No. 74 of 2025, promulgated June 20, 2025.
Once this takes effect, the weekly-hours test (20+ hours) becomes the primary gate for enrollment, rather than one of several thresholds a worker could sit just under. For any employer with part-time staff scheduled near that hours line, this is worth a payroll review before the date, not after.
5. Employer-provided housing gets revalued for social insurance premium purposes
Where an employer provides housing as part of compensation, that housing has a notional cash value that factors into the employee’s social insurance premium calculation. From October 1, 2026, the calculation method itself changes: instead of valuing housing per tatami mat of living space, it’s valued per square meter of total floor area. This is a narrower, more technical change than the other four, but it directly affects any employer — including one placing an assigned or seconded employee — providing company housing as part of a compensation package, since the premium base shifts along with it.
Why this matters as a batch, not just individually
Four different offices — the Immigration and Labor Standards side of MHLW, the pension bureau, the regional minimum wage councils, and the worker dispatch policy division — all landed changes on the same calendar date, for entirely unrelated reasons. An employer that tracks one of these because a vendor or a client mentioned it, and misses the other four because nobody happened to mention them, is exactly the gap this kind of checklist exists to close. This is also, not incidentally, most of what an EOR or staffing partner is actually being paid to track on a client’s behalf — not the headline change, but the four adjacent ones nobody thought to ask about.
This article draws on the Act on Comprehensive Promotion of Labor Measures, the Worker Dispatch Act, the Minimum Wage Act, the 2025 pension reform act, and Ministry of Health, Labour and Welfare notifications on in-kind benefit valuation. It is provided for general informational purposes, is not legal advice, and is not directed at any specific company or arrangement. Companies should confirm current requirements, including prefecture-specific minimum wage rates and effective dates, with qualified Japanese employment counsel.
Sources
- MHLW — Customer Harassment Countermeasures Company Manual (PDF)
- MHLW — Equal Pay for Dispatched Workers overview
- MHLW — Minimum wage system overview
- Japan Pension Service — expanded application of employees’ health and pension insurance to short-time workers
- MHLW — notification on in-kind benefit valuation