Who Does What in a Japan Stress Check: Roles & Structure
"Who actually runs the stress check?" and "How is the implementer different from our HR administrator?" are the two questions foreign-owned companies in Japan ask most often once they realize the stress check is not a survey their HR team can simply send out.
Japan's stress check program does not just regulate whether you run the check — it regulates who is allowed to do each part of it. The roles are defined in law, and each role has both duties it must perform and actions it is forbidden from taking. Getting the structure wrong is one of the most common ways an otherwise well-intentioned employer ends up in breach.
This is a structure-and-roles deep dive. If you want the broader end-to-end overview — questionnaires, timeline, multilingual materials, provider selection — start with the complete employer's guide to Japan's stress check. This article zooms in on one thing: the internal org chart, and who does what.
⚠️ Obligations vary with workplace size and conditions and can change. Confirm the specifics for your operation with official sources such as Japan's Ministry of Health, Labour and Welfare (MHLW).
1. The four roles, at a glance
Japan's stress check (governed by Article 66-10 of the Industrial Safety and Health Act) distributes responsibility across four roles. Two of them are people who act on the results, one is a support role, and one is a governance body.
| Role | Who fills it | Qualification | Core responsibility |
|---|---|---|---|
| Implementer (jisshisha / 実施者) | Physician, public health nurse, or trained nurse / mental health social worker / certified public psychologist | Licensed (see §2) | Selects questionnaire, judges results, designates high-stress employees, notifies individuals |
| Administrative staff (jisshi-jimu-jujisha / 実施事務担当者) | HR or general affairs staff | None required | Notices, employee lists, reminders, storage — but never individual results |
| Employer (jigyosha / 事業者) | The company (its representative) | — | Decides to implement, bears the cost, drives workplace improvement |
| Health committee (eisei-iinkai / 衛生委員会) | Required at 50+ employees | — | Deliberates and approves the implementation policy |
The single most important idea in this table is not what each role does — it is the wall between the implementer and everyone else. Only the implementer touches individual results. That wall is the entire reason the roles are separated in the first place.
2. The implementer (jisshisha): the licensed core
The implementer is the professional who is legally responsible for the stress check itself. Concretely, the implementer:
- Selects the questionnaire to be used
- Sets the criteria for designating high-stress employees
- Evaluates and judges each individual's result
- Notifies each employee of their own result
- Conducts or arranges physician interviews for high-stress employees
- Produces the group analysis and provides it to the employer
Who is qualified to be the implementer
Under the Ordinance on Industrial Safety and Health, the implementer must hold one of the following:
| Qualification | Note |
|---|---|
| Physician (including an industrial physician) | The most common route |
| Public health nurse (保健師) | An occupational health specialty |
| Mental health social worker (精神保健福祉士) | Mental health / welfare specialty; prescribed training required |
| Nurse / assistant nurse (看護師・准看護師) | Prescribed training required |
| Dentist (歯科医師) | Prescribed training required |
| Certified public psychologist (公認心理師) | Prescribed training required |
A frequent point of confusion for foreign companies: a certified social insurance and labor advisor (社会保険労務士, "sharoshi") is not a qualified implementer, regardless of any training. A sharoshi can advise on the surrounding labor-management operations and help you make use of the group analysis — but they cannot serve as the implementer. (One professional can, of course, hold both a qualifying implementer license and a sharoshi qualification.)
The independence rule
The implementer must function independently from the people who make personnel decisions. An HR director, a general manager, or an executive with authority over hiring, evaluation, or placement cannot serve as the implementer — even if they happen to hold a qualifying license — because their access to individual stress results would compromise the protection the law is built to provide.
An in-house industrial physician serving as implementer is fine. An in-house HR staff member doubling as implementer is, as a rule, not acceptable.
3. The administrative staff (jisshi-jimu-jujisha): support without sight
The administrative staff role is where most HR teams actually sit. It requires no license, and it is what lets a small HR function operate the stress check day to day. But it is defined as much by its prohibitions as by its duties.
What administrative staff may do
- Announce the stress check and distribute access to the questionnaire
- Manage the employee roster and system registration
- Send reminders to employees who have not yet responded
- Coordinate logistics with the implementer
- Store the group analysis and submit it to the health committee
What administrative staff may not do
- View or obtain any individual's stress check result
- Judge who is or is not high-stress
- Conduct physician interviews
If administrative staff access individual results — even with the sincere intent of "just compiling the numbers" — that is a breach of the confidentiality the stress check regime is built on, and a personal-information problem. This is not only a policy rule; it should be enforced in the system itself. The administrative-staff account must be configured so that individual results are technically invisible to it. A structure that relies on staff "choosing not to look" is not a structure.
4. The health committee (eisei-iinkai): governance, not access
The health committee (or safety and health committee) is the deliberative body for the stress check. It is where the how of implementation is decided — not where results are viewed.
As a decision body
Certain matters must pass through the committee, including:
- Timing and frequency of implementation
- Which questionnaire is used
- Selection of the implementer (or of the external provider)
- Criteria for designating high-stress employees
- How physician interviews are offered and the deadline to request one
- How group analysis is conducted and how its results are used
As a reporting forum
After implementation, the group analysis is reported back to the committee, and workplace-improvement measures are deliberated there. This closes the loop: the committee that set the policy also reviews the outcome. For how to actually structure that recurring agenda, see putting stress check group analysis on the health committee agenda.
If there is no committee
A health committee is mandatory at workplaces with 50 or more employees — the same threshold that triggers several other obligations (see the 50-employee compliance milestone). Below 50, there is no committee obligation, but once the stress check applies to you (all workplaces from April 2028), you are still expected to provide a route for hearing employee input on how it is run.
Note that the committee, like the employer, never receives individual results — its window is group analysis covering 10 or more people.
5. Two structural patterns
The org chart depends on one decision: is your implementer inside the company, or contracted?
Pattern A — In-house industrial physician as implementer
Health committee
│ (deliberates & approves the implementation policy)
▼
Employer (the company)
│ (decides to implement · bears cost)
▼
Implementer = in-house industrial physician ──▶ result notices · interviews
▲
Administrative staff (HR) ──▶ roster · notices · reminders
▲
Employees (respondents)
If your industrial physician takes the implementer role, confirm it explicitly in advance — an appointed sangyo-i is not automatically your stress check implementer (this is a common false assumption; see the industrial physician requirement). A part-time contract physician who visits monthly may also charge separately for the added implementer work.
Pattern B — External provider supplies the implementer
Health committee
│ (deliberates & approves the implementation policy)
▼
Employer (the company)
│ (outsourcing contract)
▼
External provider (implementer on staff) ──▶ result notices · interviews
▲
Administrative staff (HR) ──▶ roster · notices · reminders
▲
Employees (respondents)
For most foreign-owned subsidiaries — especially those under 50 employees with no resident industrial physician — Pattern B is the practical route. When you outsource, the contract must state who the named implementer is, and you should verify their qualification. "A specialist will handle it" is not a named implementer.
6. Common structural mistakes
| Mistake | Why it breaks |
|---|---|
| Contracting a system but never naming an implementer | A vendor can run the logistics, but a stress check with no qualified implementer is a direct breach of Article 66-10 |
| HR staff seeing individual results | Even "for aggregation," accessing individual results without consent is prohibited — and usually a sign the account permissions are wrong |
| Skipping health committee deliberation | "We decided internally" is a procedural breach and a classic finding in a labor inspection; keep the minutes (retention: 3 years) |
| A named implementer who never actually functions | The physician is written into the regulations, but no result notices or interview outreach ever come from them — a paper implementer is not an implementer |
The thread running through all four is the same: a role that exists on paper but not in operation, or a wall between roles that exists in policy but not in the system.
7. Structural due diligence when choosing a provider
If you outsource, evaluate the provider on the structure they give you, not just the questionnaire they send:
| Check | Good sign | Warning sign |
|---|---|---|
| Named implementer | "Implementer: [name], public health nurse, license no. ×××" | "Our specialists respond" (who, exactly?) |
| Interview handling | Physician / nurse on their side conducts or arranges interviews | "We refer you elsewhere" (interviews left entirely to you) |
| Access control | System where no one but the implementer can see individual results | "Our staff manage it" (permissions unclear) |
| Post-implementation support | Group analysis report plus workplace-improvement input | Report delivery only |
A provider who cannot name the implementer, or who cannot explain how individual results are walled off from everyone else, is handing you the compliance risk — not taking it off your plate.
Summary
| Role | Who | Can do | Cannot do |
|---|---|---|---|
| Implementer | Physician / public health nurse etc. (licensed) | Judge results, designate high-stress, run interviews | Be someone with personnel authority |
| Administrative staff | HR / general affairs (no license) | Roster, notices, reminders | View or obtain individual results |
| Health committee | Required at 50+ | Deliberate & approve the policy | Receive individual results |
| Employer | The company | Decide, fund, drive improvement | See individual results without consent |
Getting the structure right is not about who has the fanciest title. It is about being precise on who is qualified to do each part and who is forbidden from seeing what — because that precision is exactly what prevents both a compliance breach and a leak of employee data.
How COCKPITOS fits in. COCKPITOS is a Japanese HR platform built for companies that must run the stress check alongside broader retention work. Our representative holds a mental health social worker (精神保健福祉士) license — a qualifying stress check implementer under Japanese law — combined with certified social insurance and labor advisor (社会保険労務士) expertise, so the implementer function, administrative operation, group analysis, and interview coordination can be handled as one outsourced structure with the access walls enforced in the system itself. To talk it through, visit our contact page.