Customer Harassment and Sexual Harassment towards Applicants

In June 2025, some laws were amended in order to place additional obligations on employers for the purpose of protecting people from workplace harassment, and these amendments are scheduled to take effect in 2026. An overview of these coming changes is outlined below.

Customer Harassment

In 2023 the Ministry of Health, Labour and Welfare (“MHLW”) conducted a survey on and found that the overall trend in the number of cases in which customers were harassing workers had been increasing. In order to maintain a safe working environment and protect workers from this type of harassment, lawmakers have newly introduced obligations on employers to protect workers.

Definition

According to the amended Act on Comprehensively Advancing Labor Measures, and Stabilizing the Employment of Workers, and Enriching Workers' Vocational Lives (the “Labor Measures Comprehensive Advancing Act”), customer harassment is defined as conduct that meets all three of the following criteria:

Verbal abuse or shouting, unreasonable demands (e.g. forced apologies or excessive compensation demands), physical intimidation (e.g. grabbing clothing), and repeated or prolonged harassment (e.g. long phone calls or stalking) may fall under customer harassment.

Obligations for Employers

Under the amended Labor Measures Comprehensive Advancing Act, employers are obligated to implement necessary measures regarding employment management to prevent customer harassment. Employers are also required not to retaliate against employees for reporting customer harassment.

Guidelines on the specific obligations that employers will be required to take have not yet been released by the MHLW. However, based on past guidelines for power harassment, sexual harassment, and maternity harassment, the following obligations will likely be required with respect to handling customer harassment:

In addition, employers will be required to “make an effort” to:

Sexual Harassment Toward Job Seekers Etc.

Currently, there is no law that specifically protects interns and people seeking employment but who have not yet been hired. However, as part of the same 2023 MHLW survey, the survey found that nearly one-third of all interns or other job seekers have experienced sexual harassment in the workplace or as part of the job seeking process. Accordingly, the amended Act on Equal Opportunity and Treatment between Men and Women in Employment (the “Equal Employment Opportunity Act”) will be extending legal protections to include the following regulations.

Obligations for Employers:

Under the amended Equal Employment Opportunity Act, employers are obligated to implement necessary measures regarding employment management to prevent sexual harassment toward interns and job seekers. Again, the MHLW has not yet released detailed guidelines with respect to these newly included groups; however, the following measures are likely to be include in order to protect interns and job seekers from sexual harassment committed by the employees of a company:

In addition, employers will be required to “make an effort” to take necessary measures, such as conducting training, to ensure that employees exercise appropriate care in their interactions with interns and job seekers.