--- title: "10, 50, 101: Japan's Headcount Lines for Employers" description: Japanese labor duties switch on at 10, 37.5, 50, 100, 101 and 301 people, some per site, some per company. A levy line at 80 was proposed in October 2026. image: https://nobusato.jp/hubfs/covers-2026-11/japan-headcount-legal-thresholds-cover-en-2026-10-m.png --- [Nobu Sato](https://nobusato.jp/en?hsLang=en) [Profile](https://nobusato.jp/en/profile?hsLang=en) [Method](https://nobusato.jp/en/blog/method?hsLang=en) [Articles](https://nobusato.jp/en/blog?hsLang=en) [Glossary](https://nobusato.jp/en/blog/glossary?hsLang=en) [Contact](https://nobusato.jp/en/contact?hsLang=en) [日本語](https://nobusato.jp/ja/blog/japan-headcount-legal-thresholds)[English](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds)[中文](https://nobusato.jp/zh/blog/japan-headcount-legal-thresholds) Japan by the Numbers In this article 1. [Who counts, and where?](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s1) 2. [10 people: written work rules](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s2) 3. [37.5 and 50: disability employment and health and safety](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s3) 4. [Is the 80-person line decided?](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s4) 5. [100 and 101: the levy, action plans and pay gap disclosure](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s5) 6. [301: more items to publish](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s6) 1. [Home](https://nobusato.jp/en?hsLang=en) 2. [Articles](https://nobusato.jp/en/blog?hsLang=en) 3. [Japan by the Numbers](https://nobusato.jp/en/blog/tag/japan-by-the-numbers) # 10, 50, 101: Japan's Headcount Lines for Employers Per site or per company decides it [Nobu Sato](https://nobusato.jp/en/profile?hsLang=en)8 min read Contents6 1. [Who counts, and where?](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s1) 2. [10 people: written work rules](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s2) 3. [37.5 and 50: disability employment and health and safety](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s3) 4. [Is the 80-person line decided?](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s4) 5. [100 and 101: the levy, action plans and pay gap disclosure](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s5) 6. [301: more items to publish](https://nobusato.jp/en/blog/japan-headcount-legal-thresholds#s6) Japanese labor law switches on obligations by headcount, and a growing Japan entity often crosses them without noticing. The lines sit at 10, 37.5, 50, 100, 101 and 301 people. On 21 October 2026 the labor ministry proposed adding another one around 80. Here is the list as of November 2026, smallest first, with the one detail that trips foreign companies most: who gets counted, and where. ## Who counts, and where? Some lines are counted per workplace, others across the whole company. That single difference decides whether you have crossed a line. Work rules under the Labor Standards Act, and health and safety staffing under the Industrial Safety and Health Act, are counted per establishment (jigyojo), meaning a site such as an office or plant. Forty people in Tokyo and fifteen in Osaka make 55 in the company, but no site has reached 50. Fifty in Tokyo alone, and the Tokyo office has the duties. Disability employment, the Next Generation Act on supporting employees with children, and the Women's Advancement Act are counted across the company. Splitting sites changes nothing. Who counts also varies. For the 10-person work rules line, labor bureaus say part-time and fixed-term workers count alongside regular staff. For disability employment, short-time workers generally count as 0.5 of a person, which is how Japan ends up with a line at 37.5. ## 10 people: written work rules A site that regularly employs 10 or more workers must write work rules (shugyo kisoku) and file them with the local Labor Standards Inspection Office, under Article 89 of the Labor Standards Act. The filing needs a written opinion from a union representing the majority of workers, or from an elected majority representative. The rules must be made available to staff at all times, by posting, handing out copies, or a terminal they can check. Every change goes through the same steps. Sites with 10 to 49 workers must also appoint a health promoter, or in some industries a safety and health promoter. The common shortcut is to translate the global employee handbook. Any clause that conflicts with Japanese law then sits in a document you filed with the government. I wrote about why the first rules matter in [Set the rules in the first ninety days, or don't bother](https://nobusato.jp/en/blog/set-the-rules-in-the-first-ninety-days?hsLang=en). ## 37.5 and 50: disability employment and health and safety Japan's statutory disability employment rate for private companies rose from 2.5% to 2.7% on 1 July 2026. The obligation now starts at 37.5 employees, down from 40. At 37.5 people, 2.7% is just over one person, so one hire is required. Covered companies report their status as of 1 June each year to Hello Work, the public employment office, by 15 July. The 50-person line is per site, and it brings a set of duties. Appoint an occupational health manager (one for 50 to 200 workers). Appoint an industrial physician. Both appointments are due within 14 days of the site reaching the threshold and must be reported to the inspection office. Set up a health committee that meets at least monthly. Run an annual stress check and report the results. Report the results of periodic health checkups. The stress check line is moving. An amendment to the Industrial Safety and Health Act promulgated in May 2025 makes stress checks mandatory for sites under 50 from 1 April 2028. Until then they are a best-effort duty for smaller sites. Fifty is also where organizations tend to need a second layer of management, which I covered in [5, 15, 50, 150: when to redraw the org chart](https://nobusato.jp/en/blog/dunbar-numbers-redraw-the-org-chart?hsLang=en). The legal setup and the reorganization arrive in the same quarter, and the legal setup is usually the one that slips. Between 37.5 and 301 people there are six lines, and the one at 80 is still only a proposal Main headcount thresholds in Japanese labor law. Some count per site, others per company. Ministry of Health, Labour and Welfare and prefectural labor bureau materials; Labour Policy Council disability employment subcommittee papers, 21 October 2026. As of November 2026 Proposal under discussion (not decided)Current obligation 1. 10Write and file work rulesPer site. Part-time and fixed-term staff count. Sites of 10 to 49 appoint a health promoter 2. 37.5Employ at least one person with a disabilityPer company. Statutory rate 2.7% from July 2026. Annual report as of 1 June 3. 50Health manager, industrial physician, health committeePer site. Report stress check and checkup results. Stress checks required below 50 from April 2028 4. 80Proposed extension of the disability levyWould cover 80 to under 100. Lead time "for example about five years," starting with employers that have no disabled employees 5. 100+Disability employment levyPer company, over 100. 50,000 yen a month for each missing hire 6. 101Action plans; gender pay gap disclosurePer company. Next Generation Act and Women's Advancement Act. Pay gap and female manager ratio disclosure from April 2026 7. 301More disclosurePer company. Four or more items under the Women's Advancement Act; male parental leave rate (over 300, from April 2025) Your hiring plan already tells you the month you cross each line. Missing it usually means nobody checked how to count. Figure 1. Japanese labor law requires filed work rules at 10 workers per site, disability employment at 37.5 per company (rate 2.7%), an industrial physician, health manager and health committee at 50 per site, a levy of 50,000 yen a month per missing disabled hire above 100 per company, and action plans plus gender pay gap disclosure at 101; in October 2026 the ministry proposed extending the levy to companies in the 80s. ## Is the 80-person line decided? No. On 21 October 2026, at the 144th meeting of the Labour Policy Council's disability employment subcommittee, the ministry raised it as a point for discussion. The paper asks whether employers with 80 to under 100 workers should be considered for the levy, because above 80 the required number of disabled employees reaches two, similar to companies just over 100. It also floats a long lead time, "for example about five years," and starting with employers that employ no disabled workers at all. The ministry's table counts 7,825 companies with 80 to 90 workers and 6,272 with 90 to 100, about 14,000 in total. Companies have pushed back, according to press reports. Whether this becomes a bill, and when, is unknown as of November 2026. For scale: a company of 101 needs two disabled employees at 2.7%. With none, the levy at 50,000 yen per person per month comes to 1.2 million yen a year. Not a large sum for most foreign subsidiaries. It recurs every year, though, and a company that stays below the rate can receive guidance, then a recommendation, and if it still doesn't improve, have its name published. ## 100 and 101: the levy, action plans and pay gap disclosure Companies with more than 100 regular workers that miss the disability rate pay the levy. The 80-person proposal would lower this line. At 101, two laws apply. The Next Generation Act requires companies with 101 or more regular employees to draw up a general employer action plan and file it with the prefectural labor bureau; smaller companies are asked to try. The act now runs until 31 March 2035. The Women's Advancement Act has the same 101 threshold for its own action plan. The bigger change is disclosure. Under an amendment promulgated in June 2025, from 1 April 2026 companies with 101 or more employees must publish their gender pay gap and their ratio of women in management. The pay gap had been required only at 301 and above, since July 2022. Pin down your definitions before you publish; the female manager ratio in particular moves a lot depending on who counts as a manager, as I showed in [One Company, Four Female Manager Ratios](https://nobusato.jp/en/blog/same-company-different-numbers?hsLang=en). ## 301: more items to publish From 301 employees, Women's Advancement Act disclosure rises to at least four items, against three for companies of 101 to 300. Separately, since 1 April 2025, companies with more than 300 regular employees must publish their male parental leave rate once a year. One tempting idea is to hold the Tokyo office at 49. For per-site lines, how you divide sites does change the answer. For company-wide lines it doesn't. And a Japan entity set up to grow the business should not stop hiring to dodge a filing. The better move is to put the lines in the plan. Your hiring plan shows the month Tokyo reaches 50 and the month the company reaches 101. Sign the industrial physician and draft the action plan a few months before, instead of after an inspector asks. What inspectors find when they do visit is in [Japan's Labor Inspectors Find Violations at 70% of Visits](https://nobusato.jp/en/blog/japan-labor-inspection-violation-rate?hsLang=en). This article is general information, not legal advice. How headcount is counted and which duties apply depend on industry, employment type and how sites are defined. Check specific cases with a licensed labor and social security attorney (sharoushi), a lawyer, or the local labor standards inspection office, labor bureau or Hello Work. The extension of the levy to employers with 80 or more workers was a proposal put to a government council in October 2026 and has not been decided. Information is as of November 2026. Sources (as of November 2026) - [Hokkaido Labour Bureau, work rules: preparation, filing and notice (Labor Standards Act Articles 89 and 90)](https://jsite.mhlw.go.jp/hokkaido-roudoukyoku/hourei_seido_tetsuzuki/roudoukijun_keiyaku02/kantokuka_hourei_02/_119904.html) - [Kyoto Labour Bureau, outline of safety and health management systems](https://jsite.mhlw.go.jp/kyoto-roudoukyoku/content/contents/001537413.pdf) - [MHLW, appointing an industrial physician at sites with 50 or more workers](https://www.mhlw.go.jp/file/06-Seisakujouhou-11300000-Roudoukijunkyokuanzeneiseibu/0000168242.pdf) - [MHLW, for employers with 50 or more workers (stress check reporting)](https://www.mhlw.go.jp/stf/newpage_70557.html) - [Tokyo Labour Bureau, periodic health checkup report guide](https://jsite.mhlw.go.jp/tokyo-roudoukyoku/var/rev0/0141/0240/teikikenshin_houkokusyo_kisairei.pdf) - [Yamanashi Labour Bureau, stress checks mandatory for sites under 50 from 1 April 2028](https://jsite.mhlw.go.jp/yamanashi-roudoukyoku/hourei_seido_tetsuzuki/anzen_eisei/hourei_seido/stresscheck_R100401.html) - [MHLW, disability employment rate and levy system for employers](https://www.mhlw.go.jp/stf/seisakunitsuite/bunya/koyou_roudou/koyou/jigyounushi/page10.html) - [SME Support Japan, J-Net21, disability employment rate increase (16 September 2026)](https://j-net21.smrj.go.jp/solution/law/20260916.html) - [MHLW, 144th Labour Policy Council disability employment subcommittee (21 October 2026)](https://www.mhlw.go.jp/stf/newpage_76825.html) - [Same meeting, Material 1 on the levy system and support for SMEs](https://www.mhlw.go.jp/content/11704000/001761020.pdf) - [MHLW, Act on Advancement of Measures to Support Raising Next-Generation Children](https://www.mhlw.go.jp/stf/newpage_11367.html) - [MHLW, Women's Advancement Act page](https://www.mhlw.go.jp/stf/seisakunitsuite/bunya/0000091025.html) - [MHLW, leaflet on the amended Women's Advancement Act (effective 1 April 2026)](https://www.mhlw.go.jp/content/001668255.pdf) - [MHLW, male parental leave rate disclosure for companies over 300 from April 2025](https://www.mhlw.go.jp/content/11909000/001029776.pdf) --- Author [Nobu Sato](https://nobusato.jp/en/profile?hsLang=en) Launching in Japan, starting with people and systems. 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