Japan's Stress Check Manual for Small Workplaces (Under 50 Employees) — MHLW February 2026 Guide Explained
Overview
On February 25, 2026, Japan's Ministry of Health, Labour and Welfare (MHLW) published the "Stress Check Implementation Manual for Small Workplaces" (小規模事業場ストレスチェック制度実施マニュアル). This guide was designed specifically to help workplaces with fewer than 50 employees prepare for the upcoming mandatory stress check requirement, which takes effect around 2028.
This article breaks down the key points of the MHLW manual and explains what employers need to do — and when.
Background: Why Is This Becoming Mandatory?
The Legal Change
Japan's Industrial Safety and Health Act was amended on May 14, 2025, extending mandatory stress check requirements to all workplaces, including those with fewer than 50 employees.
Previously: - 50+ employees: Mandatory stress check since December 2015 - Under 50 employees: "Best-effort" obligation only (努力義務)
After the amendment: - Under 50 employees: Mandatory, with enforcement expected by 2028 (within 3 years of promulgation)
Why Small Workplaces?
Approximately 97% of all Japanese workplaces have fewer than 50 employees — the vast majority. Yet most have had no formal mental health screening mechanism. With mental health-related workers' compensation claims continuing to rise, the government moved to close this gap.
Implementation Timeline
| Date | Event |
|---|---|
| May 14, 2025 | Amended Industrial Safety and Health Act promulgated |
| February 25, 2026 | MHLW publishes Small Workplace Stress Check Manual |
| FY2026 (2026–2027) | Awareness campaign and preparation support period |
| ~2028 | Mandatory enforcement begins |
What the Manual Covers: A 3-Stage Framework
The MHLW manual is structured around three stages: Preparation → Implementation → Follow-up. Each stage defines the responsibilities of employers, stress check administrators, and employees.
Stage 1: Preparation
The employer must:
-
Declare a mental health policy — Management publishes a written commitment to employee mental health, explicitly promising that stress check results will not be used for performance evaluations or disciplinary action.
-
Collect employee input — Before establishing procedures, consult with employees (or their representatives) on implementation methods and privacy protections. In small workplaces, a direct team meeting can serve this purpose.
-
Create and communicate internal rules — Document and share the following:
- Who administers the stress check (internal staff or external provider)
- How personal data will be handled and secured
- How employees are protected from adverse treatment
- The process for high-stress employees to request a medical interview
Stage 2: Implementation
- Select a qualified stress check administrator (実施者 — must hold a certified mental health license such as 精神保健福祉士)
- Choose a survey questionnaire (the standard 57-item MHLW questionnaire is recommended)
- Notify employees and conduct the survey
- Deliver individual results directly to each employee (NOT to the employer)
Important: Employees cannot be required to take the stress check. Participation is voluntary, and refusing to take it cannot be grounds for adverse treatment.
Stage 3: Follow-up
- Employees who score as "high-stress" are encouraged (not required) to request a medical interview with a physician
- The employer arranges the interview (typically within one month of the request)
- The physician provides a written opinion on any necessary work adjustments
- Adjustments such as reduced overtime, shift changes, or reassignment may be recommended
Key Differences from Workplaces with 50+ Employees
| Item | 50+ Employee Workplaces | Under 50 Employee Workplaces |
|---|---|---|
| Industrial physician (産業医) | Mandatory | Not required (voluntary) |
| Group analysis | Mandatory | Not required if under 10 respondents |
| Stress check administration | Internal or external | External provider recommended |
| Medical interview support | Employer's industrial physician | Regional Industrial Health Support Center (free) |
External Provider Recommended
In small workplaces, having employees' personal stress check data managed internally creates a significant risk of individual identification — employees may feel their results can be traced back to them, undermining the entire purpose of the survey.
The MHLW manual explicitly recommends outsourcing stress check administration to an external provider to protect privacy and ensure data integrity.
Using Regional Industrial Health Support Centers
The Regional Industrial Health Support Center (地域産業保健センター, commonly called "地産保") is a government-subsidized institution operating under the supervision of prefectural medical associations. For workplaces without a dedicated industrial physician — which describes most under-50 workplaces — this center provides key services free of charge:
- Medical interviews for high-stress employees
- Consultation on occupational health practices
- Advice on workplace environment improvements
Every prefecture has at least one such center. To find the nearest center, visit the MHLW's Occupational Health Support Center website.
Group Analysis Rules for Small Workplaces
Group analysis (集団分析) aggregates stress check results by department or team to identify organizational risk factors — a key tool for workplace improvement. However, the manual sets strict limits for small workplaces:
- 10 or more respondents: Group analysis may be conducted
- Fewer than 10 respondents: Group analysis requires the unanimous consent of all participants
- Entire workplace under 10 employees: Group analysis is optional
This rule protects individuals in small teams from having their responses effectively identified through aggregated data.
Who Must Take the Stress Check?
The mandatory requirement covers employees who meet all three conditions:
- Employed under an indefinite-term contract, or on a contract of one year or more
- Working three-quarters or more of the standard weekly hours
- Regularly working at the workplace
Part-time and contract workers meeting conditions 1 and 2 are included. Participation by individual employees, however, remains voluntary — employers cannot compel anyone to take the test.
Costs and Financial Support
External Provider Cost Estimate
Outsourcing stress check administration typically costs several hundred to several thousand yen per employee. Exact pricing depends on the scope of services (survey only, vs. survey + individual reporting + group analysis + medical interview coordination).
Available Subsidies
- Small Workplace Industrial Health Activity Support Subsidy (小規模事業場産業保健活動支援助成金): Subsidizes a portion of occupational health activity costs — check current eligibility with your local Labor Standards Inspection Office
- Health Management Promotion Subsidy: Available in some prefectures and municipalities
- Free services from Regional Industrial Health Support Centers: Medical interviews and consultations at no cost
What Should Employers Do Now?
The 2028 deadline may feel distant, but preparation takes time — especially for workplaces that have never run a formal health survey.
| Timeframe | Recommended Actions |
|---|---|
| FY2026 (Now) | Read the MHLW manual; research external providers; check local subsidies |
| FY2027 | Draft internal rules; run a pilot survey with voluntary participation |
| FY2028 | Full implementation under the mandatory framework |
Summary
| Key Point | Detail |
|---|---|
| Legal basis | Amended Industrial Safety and Health Act (May 14, 2025) |
| Official manual | MHLW Small Workplace Stress Check Manual (February 25, 2026) |
| Enforcement | ~2028 |
| Biggest difference from 50+ | No mandatory industrial physician; external provider recommended |
| Medical interview support | Regional Industrial Health Support Center (free) |
| Group analysis limit | Under 10 respondents requires unanimous consent |
| Employee participation | Voluntary — cannot be compelled |
For employers looking to get ahead of the 2028 requirement, starting preparation now allows time to select a trusted provider, draft internal policies, and build employee trust before the stress check becomes mandatory.
COCKPITOS provides stress check services for small workplaces, administered by a representative who holds both the certified mental health practitioner license (精神保健福祉士, a legally recognized stress check administrator credential) and a labor and social security attorney license (社会保険労務士). Contact us via our free consultation form.