What a Japan entity must do each year

What do foreign-owned companies in Japan miss most often?

Sixteen obligations, each with a clear legal basis and real consequences, that are missed systematically in offices of a few dozen people. Read this section first: it tells you within a minute whether to worry.

• Sending employee data to the overseas parent

  Under Article 28 of Japan's Personal Information Protection Act, transferring personal data to a third party outside Japan requires the person's consent as a rule, together with advance information about the destination's data protection regime. Outsourcing abroad is not an exemption. Japanese-authored checklists almost never include this, because Japanese-owned companies have no overseas parent. For a foreign subsidiary it is the highest-consequence item on this page.

• The annual industrial waste manifest report

  The report on manifests issued, due 30 June to the prefecture, covering the year to 31 March. Nobody sends a reminder. Issuing a single paper manifest in the year creates the duty, even for one pallet of old monitors. It is not required if you are fully on electronic manifests, which the JWNET system reports for you.

• Notice of commencement of use

  Filed with the fire station seven days before you move in, under the municipal fire prevention ordinance. It is required even when you take empty space and carry out no works at all. Tenants assume the landlord handles everything to do with fire; this one is the occupant's own filing. Works such as moving partitions require a separate notice, seven days before they start.

• The fire manager threshold is the whole building

  Not your own headcount. A fire prevention manager is required where the whole building holds 50 or more people for offices and other non-specified use, or 30 or more where the building includes a restaurant or a clinic. A sixty-person tenant in a four-hundred-person building is in scope, and every tenant appoints its own manager for its own area.

• Fire drills are not twice a year for an office

  Twice a year applies to specified-use premises. An office follows the number set in its own fire plan. What is real in Tokyo: notify the fire station before each drill, and keep the record of it for three years.

• A rest room where people can lie down

  Article 21 of the Office Hygiene Standards Ordinance requires a rest room or rest area where workers can lie down, provided separately for men and women, at 50 or more employees or 30 or more women. Leased Tokyo offices almost never have one. A shared room with screening that people can use at any time is accepted in practice; a sofa in the pantry is not.

• Air environment measurement is also your duty

  Where a central air conditioning system serves the room, carbon monoxide, carbon dioxide, temperature and humidity must be measured every two months and the records kept three years. This is the employer's duty under the Office Hygiene Standards Ordinance, running in parallel with the owner's duty under building hygiene law rather than replacing it. In practice you discharge it by collecting the landlord's measurements for your own floors, and almost nobody collects them.

• The health check report has no fixed date

  The periodic health check results report is due without delay after the check, not on a calendar date. The stress check report runs once within each twelve months, counted from your own last report rather than from a fiscal-year deadline. Both are widely mis-stated as fixed dates, which is exactly what produces late filings.

• Night work carries a six-monthly health check

  Article 45 of the Industrial Safety and Health Ordinance requires a health check every six months for anyone regularly engaged in designated work, which includes night work. A shift covering a US or European parent lands squarely in this, and those companies usually run only the annual check.

• The 51-person insurance test is company-wide

  It counts pension-scheme enrolees across all sites under one corporate number, not per site and not total headcount. Above 51, part-time staff working 20 hours a week and earning 88,000 yen a month must be enrolled in health insurance and pension. At sixty employees you are almost certainly over the line.

• The twice-yearly tax schedule needs fewer than ten

  Withholding tax and resident tax may be remitted twice a year only by employers paying fewer than ten people. Companies that set this up at eight employees and never filed the notice that they no longer qualify are accumulating penalty exposure on every month they pay late.

• Depreciable assets go to the metropolitan tax office

  In the 23 wards of Tokyo the depreciable asset return is filed with the metropolitan tax office, not the ward office. Guides written for the rest of Japan say municipality, which sends the form to the wrong place. Fit-out the tenant installed, including partitions, cabling and signage, is a depreciable asset the tenant files.

• Minor accident reports are quarterly

  Accidents causing one to three lost days are reported at the end of April, July, October and January. Most companies only know the four-or-more-days version, which is due without delay, so office falls and commuting slips go unreported. Both forms are filed electronically as the rule since January 2025.

• Safety induction is now all eight items

  The exemption for office industries was removed in April 2024. Staff in office work previously skipped the first four of the eight induction items and no longer can. That includes the hazards of the copier and the shredder. A great deal of guidance still online says office work is partly exempt; it is out of date.

• A move requires the payroll office relocation notice

  Due within one month, and filed with the tax office for the address you are leaving rather than the one you are moving to. It is forgotten at every relocation. A move also triggers the business office tax notification within a month and registration of the head office move within two weeks.

• Breach reporting is not only about 1,000 people

  Sensitive personal data, which includes health check results, stress check results and disability status, triggers the reporting duty at a single record, with no numeric floor. One mis-sent HR email with a health list attached qualifies. The thousand-person figure is one of four independent triggers, not the test.

Which obligations are yours, and which are the landlord's?

Statutory inspections of the building are largely the owner's duty; the tenant carries its own leased area. This is where overseas HQ and the Japan office most often talk past each other. Draw the line in the lease, or you end up with items each side assumes the other is handling.

Which obligations switch on at which headcount?

These are not annual tasks. Each one begins when you cross a line, so this is the first thing to check when you set up an entity or add people. Note which count each rung uses, because four different counts are in play.

Why does February decide your social insurance cost?

Because the standard remuneration filing submitted in July looks only at pay in April, May and June, and it sets the contribution base for the twelve months from September. By July the figure is already fixed. The decision that moves it is the scheduling decision taken in February, and it is the only dependency in the year that crosses months.

One caveat worth stating plainly: this works only as a genuine scheduling decision. Arranging pay on paper to reduce contributions is a different thing, and not something to do.

Month by month

Dates are statutory deadlines; a weekend or public holiday pushes them to the next business day. Rates and amounts are deliberately left out, because a figure written into a reference never gets updated the following year. Teal marks the people track, green the office and facility track.

What else runs outside the monthly calendar?

Three groups of obligations do not belong to any month: those on their own cycle, those triggered by an event such as a hire or an accident, and those arising once when the entity or the office is new. Putting them in the calendar would turn every line into a conditional, so they sit here.

What does not apply to a company of a few dozen people?

Overseas HQ asks about several of these, and at this size they simply do not apply. The point is to be able to say so with a threshold rather than a guess.

• Action plan under the women's advancement law — 101 or more. Best-effort below that
• Publishing the gender pay gap — 101 or more, from April 2026
• Action plan under the next-generation support law — above 101
• Publishing parental leave uptake — above 300, from April 2025
• Publishing the mid-career hiring ratio — 301 or more
• Disability employment levy — above 100 regular employees
• General safety and health supervisor — 1,000 or more for office-type industries
• Safety manager and safety committee — industry-limited. An ordinary office needs only the hygiene committee
• Employee-based business office tax — above 100 employees
• Energy saving law periodic report — 1,500 kilolitres oil equivalent a year company-wide
• Tokyo greenhouse gas reduction obligation — 1,500 kilolitres, or 3,000 combined for the reporting scheme
• Premises inspection reporting — specified-use premises only. A pure office building is out
• Disaster prevention manager and inspection — 11 floors and 10,000 square metres and similar
• Building hygiene law registration and manager — 3,000 square metres or more, and the owner's duty
• Large-volume waste generator plan — 1,000 tonnes of industrial waste a year
• Fluorocarbon leakage reporting — 1,000 tonnes of CO2 equivalent a year

How many ways is headcount counted in Japanese law?

Four. The same company produces a different number under each, so each has to be counted separately. A sixty-person company split across two offices can trigger nothing under the site count and two obligations under the company-wide count.