Japan’s New Recruitment Harassment Rules: What Employers Need to Know

A significant change to Japan’s recruitment rules took effect on 1 October 2026.

Employers are now required to take specific measures to prevent sexual harassment of job seekers and others participating in recruitment-related activities.

The change, introduced through amendments to Japan’s Equal Employment Opportunity Act, extends employers’ harassment prevention responsibilities beyond existing employees and into the recruitment process itself.

For companies hiring in Japan, this means it is time to review not only workplace policies, but also how interviews, candidate communications, internships and other recruitment activities are managed.

What Changed on 1 October 2026?

From 1 October 2026, measures to prevent sexual harassment of job seekers became a legal obligation for employers in Japan.

Under the new requirements, employers must take necessary measures to prevent sexual conduct by their employees from interfering with job seekers’ recruitment and career-selection activities.

This is important because recruitment does not always happen within a formal interview room.

Candidate interactions can take place during internships, recruitment events, informal meetings, online communications and other activities connected with the hiring process. Japan’s Ministry of Health, Labour and Welfare (MHLW) makes clear that covered activities can also take place through social media or outside the employer’s usual workplace.

Who Is Covered?

The requirements extend beyond candidates attending traditional job interviews.

According to MHLW guidance, “job seekers and others” can include:

• Applicants participating in recruitment interviews

• Participants in company recruitment or information sessions

• Interns

• People undertaking certain educational or nursing practical training

• Individuals participating in OB/OG visits with company employees

Recruitment and career-selection activities conducted online, including through social media, can also be covered.

This means employers need to consider the entire candidate journey, rather than treating the formal interview as the only part of recruitment requiring appropriate safeguards.

Why Was the Change Introduced?

The new requirements respond to concerns about harassment occurring before employment even begins.

According to the Ministry of Health, Labour and Welfare’s FY2023 Survey on Workplace Harassment, among 737 men and women who graduated between FY2020 and FY2022 and had participated in job-hunting activities, 31.9% reported experiencing sexual harassment during job hunting, excluding internships.

Among those who reported experiencing sexual harassment, the most commonly reported behaviour was persistent invitations to meals or dates (33.2%), followed by sexual jokes or teasing (28.9%), questions about sexual matters (26.0%) and unnecessary physical contact (25.1%).

The survey also found that 40.0% of those affected said the experience reduced their motivation towards job hunting.

These findings highlight why harassment prevention is increasingly being treated as part of the recruitment process itself, rather than only as a workplace issue after employment begins.

What Do Employers Need to Do?

The new requirements go beyond simply stating that harassment is prohibited. Employers are expected to establish practical measures covering how recruitment activities are conducted and how concerns are handled.

1. Establish Clear Recruitment and Conduct Rules

Employers should clearly state that sexual harassment of job seekers is prohibited and communicate how inappropriate conduct will be addressed.

Companies are also expected to establish rules around recruitment activities themselves.

MHLW specifically identifies areas such as meeting times and locations, how meetings are conducted and the types of social media or communication channels used for candidate interactions.

These expectations should be clearly communicated to employees involved in recruitment and, where appropriate, to candidates.

2. Make Reporting Channels Accessible to Candidates

Companies must establish a consultation or reporting channel for job seekers and make candidates aware of how they can access it.

This deserves particular attention because many existing workplace reporting systems are designed only for current employees.

Employers should consider whether someone who has not yet joined the company can easily find and use the appropriate channel if they need to raise a concern.

3. Have a Process for Responding to Complaints

When a concern is raised, employers need a process for responding promptly and establishing the facts.

Where harassment is confirmed, appropriate measures should be taken in relation to both the affected person and the individual responsible. Employers should also take steps to prevent similar incidents from happening again.

Privacy must also be protected when handling consultations and complaints.

4. Prepare Everyone Involved in Hiring

Recruitment compliance is not only the responsibility of HR or the recruitment team.

Hiring managers, department heads, interview panel members, future colleagues and other employees may all interact directly with candidates.

Anyone involved in recruitment should understand the organisation’s expectations regarding candidate interactions, meeting arrangements, communication channels and reporting procedures.

Recruitment Does Not Always Happen in the Interview Room

One of the most important practical implications of the new rules is the broad range of situations employers should consider.

For example, a candidate may:

• Meet a hiring manager over coffee or dinner

• Communicate directly with an employee through social media or another online channel

• Spend several weeks with a company as an intern

• Attend a recruitment or networking event

• Meet existing employees through an OB/OG visit

These activities are not prohibited.

However, MHLW guidance confirms that recruitment-related activities can take place outside the normal workplace, including at restaurants, and can also occur online or through social media.

Employers should therefore consider whether appropriate boundaries and procedures are in place wherever recruitment-related interactions take place.

A business dinner may still be part of a recruitment process, for example, but companies should consider who attends, where and when the meeting takes place, how employees are expected to behave and what options are available to the candidate if a concern arises.

A Recruitment Compliance Checklist for Employers in Japan

With the new requirements already in effect, employers recruiting in Japan should consider reviewing the following:

Recruitment policies
Does your anti-harassment policy clearly extend to job seekers and recruitment-related activities?

Interview procedures
Are there clear expectations around where, when and how candidate meetings should take place?

Candidate communications
Have you established appropriate channels for recruiters, hiring managers and other employees to communicate with candidates?

Hiring manager awareness
Do employees participating in interviews or other recruitment activities understand their responsibilities?

Internships and recruitment events
Are employees interacting with interns, students and potential candidates subject to the same standards?

Candidate reporting channels
Can someone who is not yet an employee easily raise a concern?

Complaint handling
Is there a clear process for investigating and responding to a complaint from a candidate?

Privacy
Are appropriate safeguards in place to protect the privacy of everyone involved?

What Employers Should Take Away

Japan’s new requirements send a clear message: recruitment compliance begins before an employment contract is signed.

For employers, this means looking beyond the formal interview and considering every stage at which employees interact with potential candidates.

Interview procedures, internships, informal meetings, digital communications and reporting mechanisms should all form part of that review.

Companies recruiting in Japan should take the opportunity to examine their existing recruitment processes, ensure employees involved in hiring understand the requirements and make sure candidates know where they can turn if a concern arises.

A well-structured recruitment process is not only about finding the right candidate. It is also about creating a professional, respectful and compliant candidate experience from the very first interaction.

Official Sources:

Japan Ministry of Health, Labour and Welfare (MHLW), Measures to Prevent Workplace Harassment
https://www.mhlw.go.jp/stf/seisakunitsuite/bunya/koyou_roudou/koyoukintou/seisaku06/

Japan Ministry of Health, Labour and Welfare (MHLW), New Rules on Measures Against Sexual Harassment of Job Seekers, 1 September 2026
https://www.mhlw.go.jp/web_magazine/series/20260901.html

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Need Support with Recruitment in Japan?

Hiring successfully in Japan requires more than finding the right talent. Understanding the local market, recruitment practices and employment environment is equally important.

Link Compliance Recruitment Solutions supports businesses hiring in Japan with local recruitment expertise and market knowledge, helping companies identify and secure the talent they need.

Speak to our team to learn more about recruitment support in Japan.

kl@linkcompliance.com (Japan Enquiries) | info@linkcompliance.com (General Enquiries)

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