Nagashima Ohno & Tsunematsu | View firm profile
Introduction
On June 4, 2025, Japan amended the Whistleblower Protection Act, further enhancing protections for whistleblowers while strengthening sanctions for violations and expanding administrative enforcement powers. This is the first amendment in five years since the 2020 revision. Notably, the amendment introduces a clause providing that any dismissal or disciplinary action taken within one year following a whistleblowing report shall be presumed to have been taken in response to that report. This change is likely to create significant tension for corporate responses to whistleblowing in Japan and is expected to materially increase the burden on companies in handling such reports.
The effective date will be set by Cabinet Order within 18 months from the date of amendment; while this date is not yet fixed, the amendments will take effect no later than sometime in 2026. Compliance and whistleblowing teams in each company should familiarize themselves with the amendments and assess, before the effective date, whether their internal frameworks and practices conform to the revised requirements.
This article provides a brief overview of the amendments and practical notes considering them.
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[Author]
Tsubasa Watanabe, Partner