Japan · Customer harassment (kasuhara)

Customer harassment is now an employer obligation in Japan.

Since October 1, 2026, every employer in Japan must take measures to protect employees from harassment by customers, clients and other outside parties. Here is what the law requires, where global policies tend to fall short, and how to train a team that works in both Japanese and English.

Last reviewed: October 12, 2026 · Based on the Ministry of Health, Labour and Welfare (MHLW) guidance. This page is a general overview, not legal advice.

In force
October 1, 2026
Amendment to the Act on Comprehensive Promotion of Labor Policies, promulgated in June 2025.
Who it applies to
Every employer
Including Japanese subsidiaries and branches of overseas companies. No size exemption.
What is required
10 measures
In five categories, set out in MHLW guidelines.
Enforcement
Name publication
Reports, advice, guidance and recommendations. A company that ignores a recommendation can be named. No criminal penalty.
Definition

What counts as customer harassment

Not every complaint is harassment. Under the guidance, conduct is customer harassment only when all three of the following apply.

01

By a customer or outside party

Customers, clients, business partners, facility users and other people the business deals with.

02

Beyond what is socially acceptable

For example, demands that are extremely hard to meet, verbal abuse, intimidation or shouting.

03

Harms the working environment

The employee's working environment is damaged as a result.

Legitimate complaints should still be handled as usual. The point is to agree, as an organization, on where the line is and how to switch responses once it is crossed.

What employers must do

The 10 measures, in five categories

Summarized from the MHLW leaflet. The right-hand column shows where training helps. Training supports these measures, but it does not replace the policy, the consultation desk or the response rules, which your company needs to put in place.

Category
Measures
Where training helps
Measures 1–2Clarify and communicate the company's policy
  • State that the company will respond firmly to customer harassment and protect employees, and make the policy known.
  • Communicate what counts as customer harassment and the agreed responses, for example asking a supervisor, never handling it alone, and reporting possible crimes to the police.
TrainingAll-staff session that explains the policy and the response rules.
Measures 3–4Set up a consultation system
  • Designate a consultation desk in advance and tell employees about it.
  • Make sure the people at the desk can respond appropriately.
TrainingSession for managers and consultation staff.
Measures 5–7Respond promptly and appropriately after an incident
  • Confirm the facts quickly and accurately.
  • Take care of the employee who was affected.
  • Take steps to prevent it from happening again.
TrainingRole-play based response practice.
Measure 8Deter especially serious cases
  • Decide in advance how the company will deal with especially serious customer harassment, make it known, and have the structure to act on it.
TrainingLeadership briefing on the response policy and escalation.
Measures 9–10Measures to take alongside
  • Protect the privacy of people who consult, and say so.
  • State that no one will be treated unfavorably for consulting, and make that known.
TrainingCovered in every session.

The same amendment also requires measures against sexual harassment of job seekers, such as interns and students in recruitment. Tokyo's own customer harassment ordinance (in force since April 1, 2025) asks businesses to make efforts such as preparing manuals; it carries no penalty.

For foreign-affiliated companies

Where global policies usually fall short in Japan

Most of the gaps we see are not about intent. They come from policies written for another country and teams that do not share a working language.

i.

The policy covers employees, not customers

Many global codes focus on conduct between colleagues. Japan now expects a stated policy on harassment by customers and clients, and agreed responses.

ii.

No consultation route in Japan

A global ethics hotline in English may not be a practical consultation desk for front-line staff in Japan. The desk needs to be known and able to respond.

iii.

Mixed-language teams get different messages

When Japanese and English-speaking employees are trained separately with different materials, the response rules drift apart.

iv.

HQ needs to approve, in English

Global HR or compliance often has to sign off on local training. Without English materials, approval slows down.

Bilingual training

Customer harassment training, in English and Japanese

The same content in both languages, with slides that match page by page. Japanese and English-speaking employees hear the same rules, and HQ gets English materials for approval.

All employees

Basics and response rules

What customer harassment is under Japanese law, where the line sits, and what to do when it happens.

  • Definition and examples
  • Your company's policy and rules
  • First response and escalation
Supports measures 1–2 · 60–120 min
Managers & consultation staff

Consultation and incident response

How to take a consultation, confirm facts, care for the employee and prevent recurrence, with role-play.

  • Running the consultation desk
  • Fact-finding and records
  • Care and recurrence prevention
Supports measures 3–7 · half day to full day
Leadership & HQ

Policy briefing in English

A briefing for country managers and HQ stakeholders on what the law requires and how the Japan policy fits with global policy.

  • The 10 measures at a glance
  • Gaps against your global policy
  • Response policy for serious cases
Supports measures 1, 8, 9–10 · 60–90 min
Japanese onlyEnglish onlyBoth languages, same daySeparate JP / EN sessionsIn person or onlineRecorded with subtitles
Pricing

Pricing guide

Single session
from JPY 85,000 per session
  • 5–30 participants, 60–120 minutes
  • Lecture or interactive format
  • Post-training report included
Fully bilingual program
from JPY 250,000 per program
  • Japanese and English sessions with matching slides
  • English curriculum summary for HQ approval
  • Series or multi-site rollout available

Prices exclude consumption tax. The final quote depends on headcount, number of sessions, customization and travel. Quotes are usually sent within three business days.

Instructor
Eiho "Nick"
Nakatani
Lead instructor · Representative Director, Maruninben Inc.

A practitioner who has run a foreign-affiliated company in Japan

Nick spent about ten years as Representative Director of the Japanese subsidiary of a German industrial company, and currently serves as a regional executive at a foreign-affiliated company. Earlier he worked as an engineer at Zuken, stationed at Sony on PlayStation Portable development, then in Silicon Valley, and led Asia-Pacific business development at a global manufacturer. He trains in both Japanese and English and has delivered training to more than 3,000 participants.

MBAMcGill University (2014)
Executive educationHarvard Business School AMP 193 (2017)
Author (Chuokoron-Shinsha)
EnglishTOEIC 955
FAQ

Frequently asked questions

Does the obligation apply to foreign-affiliated companies in Japan?
Yes. It applies to every employer that employs workers in Japan, including Japanese subsidiaries and branches of overseas companies. There is no exemption based on company size.
Is training itself legally required?
The guidelines require employers to clarify and communicate their policy, set up a consultation desk and make sure it can respond properly, and respond after incidents. Training is a practical way to communicate the policy and prepare managers and consultation staff, but training alone does not satisfy the obligation. You also need the policy, the consultation desk and response rules.
What happens if a company does not comply?
There is no criminal penalty. The labor authorities can request reports and give advice, guidance and recommendations, and the name of a company that does not follow a recommendation can be made public. Civil liability under the employer's duty of care is a separate risk.
Our headquarters already has a global anti-harassment policy. Is that enough?
Check whether it explicitly covers harassment by customers, clients and other outside parties, and whether it states how employees in Japan should respond and where they can consult. Many global policies focus on conduct between employees. A short Japan addendum is often the quickest fix.
Can you train Japanese and non-Japanese employees together?
Yes. Sessions can be delivered in Japanese, in English, or in both on the same day or on separate days, using slides with identical page numbers and content in each language.
Can you provide English materials for HQ approval?
Yes. An English curriculum summary, instructor bio and post-training report are included at no additional cost.
Sources

Checked October 12, 2026. For decisions in your company, confirm the latest official guidance or consult a labor lawyer (sharoushi or bengoshi).

Contact

Tell us about your team

Share your headcount, the languages your team works in, and whether HQ needs to approve the program. We will reply within one business day and send a proposal, usually within three business days.

Email: info@maruninben.com

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