New 2026 Japanese labour laws require Nintendo to strengthen customer harassment protections

Nintendo will need to overhaul customer-facing policies and safety practices after Japan phases a package of labour and occupational safety amendments through 2025-2026 that impose new legal duties on employers. One provision set to take effect in 2026 will require employers to implement measures to protect employees against harassment from customers, creating a legal obligation to adopt clear internal policies and support systems for affected employees.

The package also broadens occupational safety and health responsibilities. Sole proprietors and contractors working alongside employees will be brought into the statutory safety framework: "Sole proprietors will be recognised both as protected individuals and as parties subject to certain obligations under the legislation." Occupational accident reporting will be expanded to cover incidents involving sole proprietors, and operators of hazardous worksites will be expected to coordinate safety measures for all personnel on site. Phased implementation for these OSH changes begins in April 2026, and employers should prepare to revise contractor management and on-site coordination practices.

Worker-focused changes extend beyond on-site safety. Stress check obligations will be broadened to reach smaller workplaces, with the effective date to be specified within three years from promulgation. Employers will also face new senior-worker duties from April 1, 2026, requiring efforts to improve the physical work environment, adjust job duties and provide appropriate training in line with Ministry of Health, Labour and Welfare guidance.

Sexual-harassment prevention obligations will expand beyond current employees to cover job seekers, students, interns and other applicants. Employers will be required to take proactive steps across recruitment stages, including interviews and internships, by establishing internal policies and training personnel involved in recruitment. The effective date for that extension will be set within 18 months of promulgation, and noncompliance may trigger administrative guidance and public disclosure.

The reforms intersect with other statutory changes that carry concrete reporting and penalty rules. The statutory quota for employing persons with disabilities will rise from 2.5% to 2.7% effective July 1, 2026, "effectively expanding the hiring obligation to employers who employ 37.5 or more employees (previously 40 or more employees)." Employers subject to the quota must file a Disability Employment Status Report by July 15 each year; failure to file could lead to a criminal fine of up to JPY 300,000. Employers with more than 100 employees who fail to meet the quota will remain subject to a disability employment levy of JPY 50,000 per month for each person short, and payment of the levy will not exempt the employer from meeting the statutory quota.

For Nintendo employees, contractors and HR teams, the changes mean clearer channels for reporting customer harassment, expanded access to support, and heightened employer responsibility for contractors who work on site. Human resources and operations should update harassment policies, extend training to recruitment and frontline supervisors, audit contractor arrangements, and ensure systems can meet new reporting deadlines.

The Ministry of Health, Labour and Welfare will issue guidance on many of these measures; employers should track promulgation dates and the ministry’s guidance and begin policy and systems work now to meet staged compliance deadlines.