The Industrial Physician (Sangyo-i) Requirement in Japan — Explained for Foreign-Owned Companies
Key points - A workplace with 50+ workers must appoint an industrial physician (sangyo-i) - The industrial physician and the stress check implementer are related but distinct roles - A physician industrial doctor can be the implementer, but the implementer need not be your appointed sangyo-i - Under-50 workplaces generally need not appoint one, but stress checks still apply (all workplaces from April 2028) - Individual stress check results stay confidential (Art. 66-10) regardless of physician involvement
⚠️ Obligations vary with workplace size and conditions and may change. Confirm with official sources such as Japan's Ministry of Health, Labour and Welfare.
1. What is an industrial physician?
An industrial physician (sangyo-i) is a physician who supports health management in the workplace — advising on working conditions, conducting health-related interviews, and contributing to the health and safety committee. Under the Industrial Safety and Health Act, a workplace with 50 or more workers must appoint one.
Foreign-owned companies expanding in Japan often hit this requirement at the 50-worker threshold, alongside other obligations like the health and safety committee. See how the 50-employee threshold triggers multiple obligations.
2. Industrial physician vs. stress check implementer
This is the most common confusion. The two roles are related but not identical.
| Role | Who | Trigger |
|---|---|---|
| Industrial physician (sangyo-i) | A physician | Workplace with 50+ workers |
| Stress check implementer | Physician, public health nurse, or trained nurse / mental health social worker / certified public psychologist | Required to run the stress check |
An industrial physician (being a physician) can serve as the stress check implementer, but the implementer does not have to be your appointed industrial physician. Don't assume they're automatically the same person. The implementer rules are covered in common misconceptions about Japan's stress check law.
3. What smaller subsidiaries should do
If your workplace has fewer than 50 workers, appointing an industrial physician is generally not required — but health management still matters, and public industrial health support resources exist. For the stress check itself (mandatory for all workplaces from April 2028), a practical route is to use a service that arranges a qualified implementer, rather than building the capability in-house.
4. The physician does not hand you individual results
Even where an industrial physician is involved, individual stress check results remain confidential under Article 66-10 and are not provided to the employer without consent. The physician's role in stress checks relates to implementation and interview guidance — not delivering individual results to management. The employer's window is group analysis of 10 or more people.
5. Keeping it manageable
For a foreign-owned company, the cleanest approach is to use a stress check service that arranges the qualified implementer and handles results per Article 66-10, and to connect retention efforts (pulse surveys, 1on1s) separately at the appropriate level — see the integrated retention platform approach.
Summary
A workplace in Japan with 50 or more workers must appoint an industrial physician, while the stress check implementer is a related but distinct role that can be — but need not be — the same physician. Smaller subsidiaries generally need not appoint a sangyo-i but must still address stress checks (all workplaces from April 2028). Throughout, individual stress check results stay confidential under Article 66-10. Confirm specifics with official sources.