Increased employer obligations in regard to gender gap reporting in early 2026

At a glance

• Companies with over 100 employees are impacted by new reporting requirements which will take effect on 1 April 2026.
• Disclosure requirements include the employer's gender pay gap, the employer's ratio of female managers, and several itemized statistics divided into two categories known as 'Category A' and 'Category B'.
• The new obligations are based on employee numbers, requiring:
  • companies of more than 300 employees (301 or more) to add their ratio of female managers to their existing disclosure obligations; and
  • companies of more than 100 employees (101 or more) to add their ratio of female managers and their gender pay gap to their existing disclosure obligations.
• The changes do not affect companies of 100 or less employees, which still have some non-binding disclosure obligations. 

Background to the changes 

In 2015, the Japanese government enacted the Act on the Promotion of Women's Participation and Advancement in the Workplace. This was not the first time gender pay laws were developed in Japan, as gender based equal pay and anti-discrimination legislation has existed since the 20th century. However, the 2015 Act was the first framework to encourage female employment and career development, and introduce obligations based on the number of employees an employer had. 

This act has undergone many amendments since 2015, starting with requirements on employers to outline goals and initiatives for women's participation, to more specific requirements in 2022 to report on the gender pay gap and other statistics. In 2024, the World Economic Forum released the Global Gender Gap Index, placing Japan 118th of 146 economies, and lowest of the G7 nations, which showed that further changes were needed for the act to have its desired effect.  

This resulted in the 2025 update, which builds on the approach introduced in 2022 by continuing to use a category-based framework for reporting gender pay and other gender-related employment data.

What are the obligations and what has changed? 

Under the existing law (prior to the recent changes), companies with 301 or more employees are required to disclose their gender pay gap, along with at least one item from Category A and one item from Category B. From 1 April 2026 when the changes take effect, such employers will be required to maintain these disclosure requirements, and add their ratio of female managers to this list of disclosures. 

Companies with between 101 and 300 employees, under the existing law (prior to the changes) must disclose at least one item from category A and category B. From 1 April 2026, such employers will be required to maintain these disclosure requirements, and add their gender pay gap and their ratio of female managers to this list of disclosures. 

The items in Categories A and B are:

While some of the items in these categories may appear similar, each is distinct with its own specific set of requirements under Japanese legislation (for example managerial positions vs management positions). 

For any questions about these changes, please reach out to our team in Tokyo.