Japanese: Japan Employment Law Alert: 顧客等によるハラスメント（カスハラ）及び求職者等へのセクハラ対策の義務化‐対社外のハラスメント対応も義務に

1. Introduction

Until now, companies have been required to take measures — such as establishing internal reporting channels — against harassment occurring “within the workplace” (power harassment, sexual harassment, harassment relating to pregnancy and childbirth, and harassment relating to childcare and family care; collectively, “Internal Harassment”). With effect from October 1, 2026, however, amendments to the relevant statutes^{1 (the “Amendments”) will require companies to also take measures against harassment arising “in dealings with parties outside the company” — namely, harassment by customers and other counterparties (commonly referred to as “customer harassment,” or kasu-hara) and sexual harassment towards jobseekers etc. and similar persons (collectively, “External Harassment”).}

The Amendments were prompted in part by a 2023 survey conducted by the Ministry of Health, Labour and Welfare (the “MHLW”), which revealed the following²

• With respect to customer harassment, although the proportion of employees who had suffered customer harassment in recent years exceeded the proportion who had suffered sexual harassment, relatively few companies had taken steps to address it; and
• With respect to sexual harassment towards jobseekers etc.³ , the proportion of jobseekers etc. who experienced sexual harassment during their job search exceeded the proportion of employees who...

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