Can work rules drafted by an AI actually be filed?

In short: yes, they can be filed. There is no prescribed format for work rules (shūgyō kisoku), and no one asks who drafted them. The problems lie in the content and the procedure. A written record of the opinion of the majority representative must be attached (Labor Standards Act, Article 90), the rules must be made known to workers (Article 106) — and rules that do not match the company's reality will not function when a dispute comes.

More and more companies have tried having an AI draft their work rules. This page is for owners and back-office staff looking at such a draft and wondering, "can we file this as it is?" From how many employees the obligation arises is covered in From how many workers are work rules mandatory — and what is not mandatory?. This article deals with how to treat a draft produced by an AI.

Will a filing based on an AI draft be accepted?

Yes. Article 89 of the Labor Standards Act obliges an employer with ten or more workers regularly employed to draw up work rules and file them with the authorities — but it says nothing about who may draft them. Drafted in-house or built on an AI's draft, the statutory treatment is the same.

What Article 89 does prescribe is the content. Start and finish times, breaks, days off and leave (item 1); how wages are decided, calculated and paid, the cut-off and payment dates, and pay raises (item 2); and matters concerning retirement, including grounds for dismissal (item 3) — these must be included. Retirement allowances, bonuses, safety and hygiene, commendations and sanctions are matters that must be included if provided for. The first yardstick for checking an AI draft is this list of items.

Is "accepted" the same as "usable"?

No. Around the filing sit two statutory procedures.

Procedure	Basis	Substance
Hearing of opinions and attaching the written opinion	Labor Standards Act, Article 90	Hear the opinion of the majority union (or, absent one, the representative of the majority of workers) and attach a document recording that opinion to the filing
Making the rules known	Labor Standards Act, Article 106	Make the rules known to workers by posting or keeping them in a visible place at each workplace, distributing them in writing, or other methods prescribed by ministerial order

Hearing opinions does not require obtaining consent — but filing without hearing them is not possible. And work rules that have not been made known do not function as a basis for binding workers; this is territory with an accumulation of court decisions, and the effect in an individual case depends on its facts. Hold on to one point: "accepted" is not a guarantee of "effective".

What happens with rules that do not match reality?

What we often see in AI drafts is a set of rules that reads well as prose but is not connected to how the company actually works.

• The working-hours system differs from reality — the draft assumes the standard 8-hours-a-day, 40-hours-a-week shape while the company actually runs shifts or a modified working-hours system
• Allowances and fixed overtime pay diverge from the actual pay slips — when rules and actual payment part ways, the basis for calculating premium wages crumbles
• Amendments are not reflected — the way AI answers drift on article numbers and effective dates, described in Can I ask an AI about a labour question first, and then consult a shakai hoken roumushi?, happens in work-rules drafts too
• Provisions for systems the company does not have creep in — clauses for unused schemes left in the text become the entry point for diverging claims between labour and management

Work rules are the document the company stands on when a dispute comes. Rules that do not match reality will not protect the company when it matters. A completed filing and a working set of rules are different things.

With a draft in hand, what do you ask a shakai hoken roumushi to do?

Not "draft from zero" — bring the draft in and ask for a review. That is a perfectly good way in; in fact, a working draft makes the issues visible faster. Three things to ask for:

What to ask	Substance
Matching against reality	Checking the provisions on working hours, wages, allowances and leave against how people actually work and what the pay slips actually say. This is the main body of the work
Checking the required items and current law	Whether the items required by Article 89 are all present, and whether amendments are reflected
Designing the procedure	Selecting the majority representative, hearing opinions, filing, and making the rules known

Fees from reviewing a draft through drafting, revision and filing are published in the "work rules" rows of the fee schedule. Consultation is free of charge. Bring the AI's draft exactly as it is.

What can 四葉社会保険労務士事務所 do?

四葉社会保険労務士事務所, in Kohinata, Bunkyo City, handles the drafting, revision and filing of work rules, the fact-finding about working practices that underpins them, and labour and social insurance procedures. We also work in the form of reviewing and adjusting an AI draft you bring in. The questions we are asked most often are collected on the FAQ page.

Whom to consult

Tax (including the year-end adjustment) is work for a tax accountant; registration for a judicial scrivener; matters already in dispute for an attorney. Residence-status applications, subsidies and company-formation documents are handled by 四葉行政書士事務所 (a separate business from this office, engaged under a separate contract). In every case, no referral fees change hands.

Frequently asked questions

Q. Can we file AI-drafted work rules with the Labour Standards Inspection Office as they are?
A. Formally, yes. There is no prescribed format and no qualification requirement for the drafter. But a document recording the opinion of the majority representative must be attached (Labor Standards Act, Article 90), and making the rules known to workers is an obligation (Article 106). Acceptance of the filing is no guarantee that the rules will function effectively.

Q. Is filing required with fewer than ten employees?
A. The obligation to draw up and file applies to workplaces with ten or more workers regularly employed (Labor Standards Act, Article 89). Below ten there is no obligation, though having rules to anchor working conditions still has value. See From how many workers are work rules mandatory — and what is not mandatory?.

Q. What do you most often end up fixing in AI drafts?
A. As a general tendency: provisions on working hours and allowances that do not match reality, amendments not reflected, and clauses left in for schemes the company does not have. It is the matching against reality, not the prose, that takes the time.

Q. Is it cheaper if we bring our own draft?
A. It depends. The main body of the work is the fact-finding and the matching against reality, so the existence of a draft does not always change the workload much. Either way, we present an estimate in advance, following the fee schedule. Consultation is free.

Sources for this article

• Labor Standards Act (労働基準法, Act No. 49 of 1947), Article 89 (obligation to draw up and file; required items), Article 90 (procedure — hearing of opinions and attaching the written opinion), Article 106 (obligation to make the rules known) — current text confirmed on e-Gov on 14 August 2026

This article is general information. Whether rules match reality, and the effect of an individual set of rules, are judged by a qualified professional after a meeting. Written by Joji Uramatsu (Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist).