On February 27, 2023, the Ministry of Health, Labor and Welfare in Japan announced a new tool to create a list of bulk notification workplaces, stating that it is now possible to submit a collective notification of the agreement on the annual variable working hours system. This announcement has important implications for businesses operating in Japan, as it affects how they must report their agreements regarding working hours and holidays. MHLW now allows bulk notification workplaces of variable working hours and this will greatly simply, and reduce the burden on multiple-location businesses of such reporting.

Verse Corporation publishes articles on timely issues in Japanese Social Welfare and Labour Law. Japanese payroll, source deductions, and all labor law work & pay rules regarding compensation, social insurance, absenteeism & sick leave, etc. require strict adherence. Labor/employment law can be complex, even for Japanese companies, and must be handled mostly in Japanese. As with all social welfare and labor law matters in Japan, please seek out professional Sharoushi (Certified Labour Law and Social Insurance Attorney.)

Bulk Notification Stipulations

According to the new regulations, the head office can be notified collectively only if the contents of the agreement are the same. Additionally, the notification must be made by electronic application, and the contents of certain items must be the same across all workplaces. These items include the following: 

• the target period and specific period, working hours and regular holidays on each day and week during the target period, the average number of working hours per week during the target period, the validity period of the agreement, the number of working hours on the day with the longest working hours for those under 18 years old, the number of working hours in the week with the longest working hours for those under the age of 18, the total number of working days during the target period, the longest consecutive weeks in a week with more than 48 working hours, the longest consecutive working days during the target period, the number of weeks in which the working hours exceed 48 hours during the target period, the longest consecutive working days during a specific period, the user’s job title and name, and the contents of the old agreement.

It is important to note that the calendar attached to the notification will only meet the requirements if the calendar of the head office and the branch office have the same content. If there are multiple types of calendars at the head office, the handling is as follows: 

• the branch office does not use all of the calendars at the head office, but the calendars it uses are the same as the head office, it meets the requirements and can be filed at the head office at once. If the branch office uses all the calendars of the head office, and also uses calendars that are not used at the head office, it cannot submit a lump-sum notification to the head office.

Regarding Different Contents By Workplace.

When there are items with different contents for each workplace, businesses must download the bulk notification workplace list creation tool (Excel file) from the application page of the Ministry of Health, Labor and Welfare HP or e-Gov, fill in the contents and attach it.

To facilitate the implementation of these changes, the e-Gov electronic application provides guidance. 

• For some procedures, the same procedure name is displayed twice on the procedure search results list screen from after the change of procedure information to March 3, “under maintenance” is displayed on one side, and “enter application form” is displayed on the other side, so businesses should apply from the “enter application form” option. Double display such as the above is not necessarily displayed on the same search screen page, but may be displayed on another page, so businesses should enter the procedure name in detail for procedures with a large number of search results. Since the procedure registered in the procedure bookmark before the change cannot be used, businesses will not be able to apply from the bookmark. Additionally, since the application data is temporarily saved before the change will not be available, businesses must create the application data from the beginning and apply.

Summary 

In conclusion, the announcement by the Ministry of Health, Labor and Welfare in Japan on February 27, 2023, regarding the submission of a collective notification of the agreement on the annual variable working hours system will have a significant impact on businesses operating in Japan. Businesses must ensure that they comply with the new regulations, including the requirements for electronic application and the contents of the notification, to avoid penalties and other legal repercussions.

The MHLW summarizes the new system as follows*

For overtime and holiday labor agreement notification, employment rule notification, and agreement notification on the one-year variable working hours system, it is possible to make a collective notification at the head office, but if you want to make a collective notification at the head office, please write the necessary information in the bulk notification office list creation tool, and the tool You need to attach and apply. The tool is posted below, so please download it as appropriate.

The MHLW provides additional support information here. This is in Japanese 

Details of the system and the digital tool are found here. This is in Japanese. 

The MHLW now allows bulk notification workplaces of variable working hours and, as mentioned, is expected to simply, and reduce the burden on multiple-location businesses of such reporting.