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Thursday, July 2, 2026

Japan Employment Law Alert: Expansion of the Scope of Mandatory Disclosure of Gender Pay Gap and Other Information (Affecting Companies with 101 or More Regularly Employed Workers) - JD Supra

日本語: Japan Employment Law Alert: 男女間賃金差異等の公表義務対象の拡大(常時雇用従業員数101人以上の企業に影響)

The Act on the Promotion of Women’s Active Engagement in Professional Life (the “Act”) requires companies with 101 or more regularly employed workers1 (“Workers”) to disclose at least one item selected from 14 prescribed items relating to the promotion of women’s participation (such as the ratio of female workers to all workers, and the gender gap in average years of continuous service). Effective April 2026, an amendment to the Act (the “Amendment”) added the following required disclosure items:2

  • Companies with 101 to 300 Workers: The previously required items, plus (i) gender pay gap and (ii) ratio of women in managerial positions.
  • Companies with 301 or more Workers: The previously required items (which, for such companies, already include the gender pay gap), plus ratio of women in managerial positions.

In Japan, the gender pay gap remains large by international standards, with one contributing factor being the low ratio of women in managerial positions. The Amendment aims to address this situation by extending the term of the Act (originally a sunset law set to expire on March 31, 2025) by ten years and by expanding the scope of the disclosure obligation as described above. In light of the background motivating the Amendment, the Ministry of Health, Labour and Welfare (“MHLW”) is expected to place more emphasis on ensuring compliance with the disclosure obligations going forward.

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