At a glance

• Companies with over 300 employees must appoint a designated whistleblower response officer. Failure to comply may result in corrective orders, inspections, and fines.
• The revised law extends protections to freelancers under current or recently expired contracts, ensuring they are not disadvantaged for whistleblowing.
• To reinforce a safe reporting environment, the amendment prohibits unjustified attempts to identify whistleblowers and voids agreements that obstruct lawful reporting.
• New criminal penalties target retaliation in the form of dismissal or disciplinary actions. Individuals may face imprisonment or fines of JPY300,000, and companies can be fined up to JPY30 million. A presumption of retaliation applies to adverse actions such as dismissal or disciplinary actions within one year of a report.

Background to the changes

Japan has taken a significant step toward strengthening protections for whistleblowers with the passage of the 2025 Amendment to the Whistleblower Protection Act. Enacted and promulgated in June 2025, the revised law is expected to come into force before the start of 2027.
The amendment aims to address long-standing concerns about the effectiveness of whistleblower protections in both the public and private sectors. It introduces new enforcement mechanisms, expands the scope of protected individuals, and seeks to remove barriers that discourage whistleblowing.

Specific features of the new law

One of the most notable changes is the...

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