INSIGHTS｜EMPLOYMENT & COMPLIANCE
Akira Kaneko, Attorney at Law (Kaneko Law Office)
Key takeaways
- Under amendments to the Act on the Comprehensive Promotion of Labor Policies, since October 1, 2026 all employers in Japan must take measures to protect their employees from serious misconduct by customers, business partners and other third parties (“customer harassment,” or kasuhara).
- There is no exemption based on company size. SMEs, startups and the Japanese subsidiaries of foreign companies are all covered.
- Employers must do five things: set and communicate a policy, set up a consultation desk, respond when incidents occur, prepare for particularly malicious cases, and protect the privacy of employees who seek help.
- The rules do not shut out legitimate complaints. It is important to agree internally on where the line falls.
Contents
Introduction
Many workplaces struggle with unreasonable demands, verbal abuse or customers who refuse to leave. Until now, responses were left to each company’s own initiative. Following the 2025 amendment to the Act on the Comprehensive Promotion of Labor Policies, measures against customer harassment became a legal obligation for employers on October 1, 2026.
This article explains what counts as customer harassment and what companies need to do in practice.
1. What is customer harassment?
Under the guidelines issued by the Ministry of Health, Labour and Welfare, customer harassment in the workplace is conduct that meets all three of the following conditions:
- It is conduct by a customer or similar person: customers, business partners, facility users and others connected with the business. It covers not only face-to-face conduct but also telephone calls, emails and social media.
- It goes beyond what is socially acceptable: in light of the nature of the work, the demand or the way it is made is not reasonable.
- It harms the employee’s working environment.
Typical examples include baseless demands, demands far beyond the terms of the contract, verbal abuse or personal insults, forcing an employee to kneel and apologize, threats or intimidation, persistent phone calls, and refusing to leave for long periods.
On the other hand, reasonable complaints, such as pointing out a defect in a product and asking for a replacement, are not customer harassment. Nor is a request by a person with a disability for reasonable accommodation.
2. Five things employers must do
The Ministry’s guidelines list the following as the main measures employers must take:
- Set and communicate a policy: Adopt a policy of responding firmly to customer harassment and protecting employees, and make it known within the company, together with what counts as customer harassment and how to respond to it.
- Set up a consultation desk: Designate a point of contact for employees, make it known, and make sure the staff in charge can respond appropriately.
- Respond promptly when incidents occur: Promptly confirm the facts when an employee seeks help, support the affected employee (for example, by reassigning the account or providing mental health support), and take steps to prevent recurrence.
- Prepare for particularly malicious cases: Decide in advance how the company will respond to particularly malicious customer harassment, for example by ending the business relationship or consulting the police, and put the necessary system in place.
- Protect privacy and prohibit retaliation: Protect the privacy of employees who seek help, and make it clear that they will not be treated unfavorably for doing so.
3. Practical points
- Update work rules and internal policies: The most efficient approach is to add provisions on customer harassment to your existing anti-harassment policy.
- Prepare a response manual: To make sure front-line employees do not have to cope alone, set concrete rules on when to escalate to a supervisor and when to end the interaction. The Ministry has also published a manual for companies (in Japanese).
- Relations with business partners: Remind your own employees not to engage in customer harassment toward the staff of your business partners.
- Consequences of non-compliance: There is no direct criminal penalty, but employers may receive advice, guidance or recommendations from the Labour Bureau, and the names of employers that do not follow a recommendation may be made public.
4. Sexual harassment of job seekers
Also from October 1, 2026, employers must take measures to prevent sexual harassment of job seekers, including students looking for work. Companies that conduct job interviews or run internships should review their practices as well.
Conclusion
Measures against customer harassment protect employees, help maintain the quality of customer service and support staff retention. If your company has not yet put a policy and consultation desk in place, a good first step is to write down your policy.
CONSULTATION
Kaneko Law Office advises companies, in English and Japanese, on anti-harassment policies, response manuals and individual customer harassment cases.
This article provides general information based on laws and published materials as of October 2026. It is not legal advice on any specific matter.
