Japan Stress Check 2028: Compliance Timeline for Companies Under 50 Employees
Key points - From April 2028, stress checks become mandatory for all workplaces, including under-50 - Under 50 is currently an effort obligation → full requirement in April 2028 (2025 amendment) - Small teams underestimate lead time for arranging a qualified implementer - Prepare: confirm applicability → arrange implementer → choose method → set confidential handling (Art. 66-10) → plan group analysis (10+) - Use stress check data only at the group level for retention; never join individual results
⚠️ This is a planning overview. Confirm exact obligations and timing with official sources such as Japan's Ministry of Health, Labour and Welfare.
1. What changes in April 2028
Stress checks have been mandatory for workplaces with 50 or more workers since December 2015. Under the 2025 amendment, the obligation expands to all workplaces — including those with fewer than 50 employees — from April 2028. For under-50 workplaces, it is currently an effort obligation; in April 2028 it becomes a full requirement.
For foreign-owned small companies, the obligation applies to the workplace in Japan regardless of parent nationality. Background is in the stress check law guide for foreign companies and common misconceptions.
2. A practical compliance timeline
Treat this as a small project with a few months of runway, not a single task.
| When | Step |
|---|---|
| ~6 months before | Confirm worker count and applicability; assign an internal owner |
| ~4–5 months before | Arrange a qualified implementer (physician, public health nurse, etc.) |
| ~3 months before | Decide survey method (web/paper); set up confidential handling of individual results (Art. 66-10) |
| ~2 months before | Prepare employee communication; plan group analysis (only for 10+) |
| ~1 month before | Dry run; confirm interview-guidance path for high-stress requests |
| April 2028 onward | Conduct annually |
(Exact lead times vary — adjust to your situation.)
3. The two things small teams underestimate
- Arranging the implementer. You cannot run it yourself; HR and the employer cannot be the implementer, and a sharoshi cannot either. Securing a qualified implementer takes time — see the industrial physician requirement explained.
- Confidential result handling. Individual results are protected under Article 66-10. Set up the flow (results to the employee; only group analysis of 10+ to the employer) before launch.
4. Don't misuse the data for retention
It is tempting to use stress check data to manage retention, but individual results cannot be used for evaluation or turnover prediction. Use only group analysis (10+) to read trends, and pair it with pulse surveys and 1on1s for retention — never joining individual stress check data. See the integrated retention platform approach.
5. The simplest path for small companies
For a small foreign-owned company, the most practical route is a service that arranges the qualified implementer and handles results per Article 66-10. COCKPITOS supports stress checks including implementer arrangement, so a small team can meet the 2028 obligation without building in-house health capability.
Summary
From April 2028, stress checks are mandatory for all workplaces in Japan, including those under 50 employees. Small foreign-owned companies should treat compliance as a short project: confirm applicability, arrange a qualified implementer early, set up confidential handling under Article 66-10, and plan group analysis. Start before the deadline, and use the data only at the group level for retention.