Beyond the Introduction — What Advisors Should Check Before Recommending a Stress Check Service with an Implementer for Japan's 2028 Mandate
- From April 1, 2028, the Stress Check becomes mandatory for workplaces with fewer than 50 workers in Japan (MHLW)
- Sharoushi and tax accountant qualifications alone do not make someone an implementer. The realistic role is to introduce a service that includes an implementer and support introductions and coordination within each advisor’s professional and contractual scope
- The "implementer" and the "physician who conducts interviews" are different roles. Confirm who does what before contracting
- Small-group analysis follows MHLW's rule and its exceptions, counted by the number of valid responses, not headcount. Do not assume small clients can freely analyze by department
- Individual Stress Check results are not provided to the employer without the employee's consent (Article 66-10); the guidelines also prohibit disadvantageous treatment based on them
Introduction — clients call the advisor they already know
According to the Ministry of Health, Labour and Welfare (MHLW), under the amended Industrial Safety and Health Act promulgated in May 2025, the Stress Check becomes mandatory for workplaces with fewer than 50 workers from April 1, 2028 (Reiwa 10). Until now, it was only a best-effort duty for these workplaces (MHLW: Stress Check program).
Small workplaces running it for the first time are likely to ask their regular sharoushi or tax accountant: "Who should we ask?" and "Where do we start?"
This article sets out how advisors can handle role distinctions, small-group analysis, and pre-contract checks when recommending a Stress Check service with an implementer.
1. Distinguish advisor qualifications from the "implementer"
Stress Check implementers are limited to physicians, public health nurses, and dentists, nurses, mental health social workers, or certified public psychologists who have completed the prescribed training (MHLW Stress Check Q&A, in Japanese). Sharoushi or tax accountant qualifications alone are not enough.
The advisor's role can therefore be framed as:
Introduce a service in which a qualified professional takes the implementer role, and support introductions and coordination within each advisor’s professional and contractual scope. Specialist labor-management judgments are referred to a sharoushi or other responsible professional.
The advisor who knows the client well, and the provider who handles implementation, operation, and analysis. Clearly separating these roles is what gives clients confidence.
2. Even "with an implementer," confirm who does what in the contract
A Stress Check service "with an implementer" is one in which a qualified professional takes on the implementer role within the service, reducing the client's burden of finding and contracting an implementer separately.
However, the annual Stress Check cycle involves people with different roles:
| Role | Main party | What to confirm |
|---|---|---|
| Deciding to implement, setting up the system, internal communication | The employer (client) | Implementation arrangements and internal rules, explained to employees. Use the health committee where applicable; at small workplaces without a committee requirement, hear workers’ views before finalizing the arrangements |
| Implementer | Physician, public health nurse, or trained qualified professional | Who takes the implementer role in the service, and with what qualification |
| Physician interview for high-stress employees | Physician | Who arranges the physician and how (e.g. whether there is an occupational physician) |
| Introductions and coordination | Sharoushi / tax accountant (within each advisor’s professional and contractual scope) | How far the firm acts as the point of contact; specialist labor-management judgments go to a sharoushi or other responsible professional |
In particular, the implementer role and the physician interview are separate. "With an implementer" does not necessarily mean a physician for interviews is included. When comparing services, confirm the following so your explanation to the client stays consistent:
- Who the implementer is (qualification and scope)
- How far the provider explains group-analysis results (and which analysis the plan includes)
- How the physician for interviews is arranged
- Who takes over and answers specialist questions from employees or the client
- The price, and what the price covers
3. Groups under 10 — separate the legal rule from the product's handling
For advisors with many small clients, the headcount condition for group analysis is a common question. Here, the legal / administrative interpretation and the product specification must be explained separately.
MHLW Q&A
Aggregating and analyzing small groups can identify individuals. For groups under 10, the ways results can be aggregated and analyzed without workers' consent are therefore limited. The MHLW Q&A — including its question on "methods that allow aggregation and analysis without workers' consent even for groups under 10" — states the following (Stress Check Q&A Q15-1, Q15-3, Q15-4; in Japanese):
- Even if every department has 10 or fewer people, group analysis combining several departments is possible
- Group analysis below 10 people is possible with methods that do not risk identifying individuals, such as calculating the average of total scores
- The "job stress assessment chart" may be used, but targeting extremely small groups is inappropriate because it leads to identifying individuals
In other words, "analysis below 10" is limited to cases such as using methods that do not risk identifying individuals. It is not simply a matter of lowering the number, or of recording it in a health committee.
The headcount condition is checked against the number of valid responses actually collected, not the number of people on the payroll (MHLW Stress Check implementation manual, p.84, in Japanese). MHLW's July 2026 leaflet (in Japanese) gives examples of analysis methods that prevent identification in small groups. An amendment that codifies "methods that do not identify individuals" takes effect on April 1, 2027, and MHLW states it is not intended to change existing practice (MHLW notice of June 30, 2026, in Japanese). This is a separate date from the April 1, 2028 expansion to small workplaces.
How COCKPITOS handles it
The headcount condition is based on the number of valid responses, not department headcount. For small groups, the analysis method and display scope that do not identify individuals are confirmed with the implementer. Details of how COCKPITOS displays results and handles groups of 5–9 will be provided separately based on confirmed product specifications.
The pricing page (in Japanese) describes operating conditions for small-group analysis. Before contracting, confirm the specific method, recipients and display scope with the implementer.
When explaining this to a client, rather than "you can analyze by department even if you are small," it is more accurate to say: "Groups with fewer than 10 valid responses are, as a rule, easy to identify individuals in, so methods such as combining departments or looking at averages will be decided in consultation with the implementer."
4. From first conversation to adoption
This can be handled as an extension of regular advisory work:
- Check the client's situation: number of workers, past implementation, and whether there is an occupational physician.
- Inform early: first agree on the implementation arrangements and internal rules, and explain them to employees. Use the health committee where applicable; at small workplaces without a committee requirement, hear workers’ views before finalizing the arrangements (MHLW start guide for small workplaces, p.2, in Japanese). Then move on to the check itself, result notification, and guidance toward physician interviews. The more lead time, the calmer the client.
- Introduce a service: use the checks in Section 2 to introduce a service with an implementer. The advisor does not need to be the implementer.
- Agree the division of roles after adoption: decide up front that the firm is the first point of contact and specialist questions go to the provider.
5. After implementation — turning group trends into workplace conversations
If results are simply returned, the Stress Check tends to become "an annual procedure." Using group-analysis results as a starting point for what to discuss in the workplace gives it more meaning for the client.
COCKPITOS is an HR platform that, in addition to the Stress Check, offers an external consultation service, 1on1s, skill maps, training management, and pulse surveys (anonymous responses, aggregated by department). Stress Check results are not automatically fed into these other functions.
⚠️ One boundary must hold: individual Stress Check results are not provided to the employer without the employee's consent (Article 66-10 of the Industrial Safety and Health Act), and the guidelines call for not using them in ways that disadvantage the employee, such as performance evaluation. For the organizational improvements discussed here, use group trends that do not identify individuals. Individual health support follows the separate consent and physician-interview procedures provided by the system.
6. The partner's role
COCKPITOS offers a partner program for professional firms, including sharoushi and tax accountants, and HR consultants (Partner program (Japanese)). The current division of roles is:
| The firm | COCKPITOS |
|---|---|
| Introducing clients and the first meeting | Proposals and onboarding setup |
| Helping with account setup | System operation and maintenance |
| Explaining how to get started | Analysis and reporting of results |
| Receiving first-line inquiries | Handling specialist inquiries |
COCKPITOS's CEO, Shinsuke Ichiki, is a certified labor and social security attorney and a mental health social worker, and has experience serving as a Stress Check implementer. The advisor who knows the client well, and us, handling implementation, operation, and analysis — we want to clarify each role and support clients beyond simply returning results.
For referral terms, please contact us. Pricing (excluding tax) is published on the pricing page. Companies with 50 or more employees use the six-service bundle (no single-service sales); companies with fewer than 50 employees can choose one-off Stress Check, single modules (1on1, pulse survey, skill map), or the bundle. The external counseling desk and training management are included only in the bundle. The one-off Stress Check includes a basic company-wide group report. Department-level drill-down and year-to-year organizational analysis are included in the bundle. Confirm the available analysis and privacy conditions for the plan before contracting.
Summary
- From April 1, 2028, the Stress Check becomes mandatory for workplaces with fewer than 50 workers (MHLW)
- Advisor qualifications alone do not make someone an implementer. Introduce a service with an implementer and support introductions and coordination within each advisor’s professional and contractual scope
- The implementer and the physician who conducts interviews are separate roles. Confirm who does what before contracting
- Small-group analysis is limited to methods that do not risk identifying individuals, counted by valid responses rather than headcount. Confirm the method, recipients and display scope with the implementer before contracting
- Individual results are not passed to the employer without consent and are not used for disadvantageous treatment (Article 66-10 and guidelines)
Related Articles
- Japan Stress Check 2028: Compliance Timeline for Companies Under 50 Employees
- How to Choose an Employee Wellbeing (Stress Check) Provider in Japan
- Why Japan's Stress Check Can Feel Like Empty Compliance — and How to Fix It
Discuss introducing a client → Contact us (please write “Partner inquiry” in your message)
COCKPITOS is an HR platform offering a Stress Check with an implementer, plus an external consultation service, 1on1s, skill maps, training management, and pulse surveys. See also: Partner program (Japanese).