Employers in Japan with 301 or more employees will have to disclose annually the gender pay difference between male and female employees within three months, for financial years ending on or after 8 July 2023. Smaller employers — with 101 to 300 employees — will have to report on certain gender balance information. The first reporting period will cover the 2022 financial year (1 April 2022 to 31 March 2023). The measures are included in the Act on the Promotion of Women’s Participation and Career Advancement in the Workplace that took effect on 8 July 2022. According to a 2022 survey by the Organization for Economic Cooperation and Development (OECD), the gender pay gap in Japan is 22%.
Disclosure of information. Depending on their workforce size, employers must disclose information included in two categories.
Workforce size. Employers with 301 or more regular employees will have to disclose information on at least two items (including a gender pay gap analysis) featured in Category 1, and on at least one item from Category 2. Employers with 101 to 300 regular employees must disclose information from at least one item in each category.
Gender pay gap analysis. Employers with 301 or more regular employees must analyze the average wages of regular female workers as a percentage of the average wages of regular male workers (rounded to the first decimal place) for the total population, and for each employee category (full-time, part-time and fixed-term). Temporary agency workers are excluded from the act’s scope.
Disclosure of gender pay gap. Employers with 301 or more employees must include the gender pay gap analysis in their annual “general employer action plans,” along with information about the measures taken to improve workplace gender equality, and an analysis of the employment situation of female employees. Employers must communicate their plan internally and externally and submit them to the prefectural labor bureaus.
Consequences for noncompliance. Though sanctions will not apply to noncompliant employers, the Ministry of Health, Labor and Welfare could publicly name those companies.
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