Labour in building maintenance and cleaning — aggregating working hours across sites and the expansion of social-insurance coverage

In short: Building maintenance and cleaning is a sector with many people working multiple jobs, short hours, and elderly part-timers, where working hours and social insurance are easy to get wrong. When the same person works at more than one workplace, working hours are aggregated (Labor Standards Act, Article 38, paragraph 1). Short-hour part-timers become covered by social insurance when they meet requirements such as scheduled working hours of 20 or more a week, scheduled monthly pay of 88,000 yen or more, and not being a student, and work at a specified applicable workplace with 51 or more insured persons under employees' pension (the October 2024 coverage expansion). Further, securing employment up to age 70 is an effort obligation (Act on Stabilization of Employment of Elderly Persons, Article 10-2). From the viewpoint of a shakai hoken roumushi's labour management, this page sets out the aggregation of working hours, the expansion of social-insurance coverage, employment of the elderly, late-night and early-morning premiums and health, and who to ask for what.

Building cleaning and facility management have three features — one person entering several sites, many short-hour workers, and elderly part-timers forming the workforce. This page is for the labour staff of building maintenance and cleaning companies that have many multiple-site, short-hour, and elderly part-time workers. It sets out the aggregation of working hours, the expansion of social-insurance coverage, securing employment up to age 70, late-night and early-morning premiums and health, and the line with the civil and tax sides of subcontracting.

When the same person enters several sites, how are working hours aggregated?

Working hours are aggregated even where the workplaces differ (Labor Standards Act, Article 38, paragraph 1). This covers not only working across several sites of the same company but also, under the administrative interpretation, a side job or dual employment where the employers differ. The part exceeding statutory working hours (8 hours a day, 40 hours a week) after aggregation is overtime.

Where a side job or dual employment has different employers, who bears the premium wages is set out in the side-job/dual-employment guideline and a circular (Rodo Kijun Kyoku circular Kihatsu No. 3 of September 1, 2020). In principle, the employer who later concluded the labour contract that set scheduled working hours exceeding statutory hours after aggregation bears the premium wages, and the part actually worked beyond scheduled hours is borne by the employer who had that work done. Hours at other companies are grasped by self-report from the worker and the like.

Situation	Approach to aggregation	Who bears the premium (in principle)
Working across several sites of the same company	Manage by aggregating all sites	That company bears it
Side job / dual employment with different employers	Aggregate your own and the other company's hours (the other's grasped by the worker's self-report)	The employer who concluded the contract later bears it in principle

If you manage time separately at each site without grasping the reality of multiple jobs, unpaid premiums for hours that become overtime after aggregation easily arise. For how the workers' accident compensation (benefits for a multiple-employment worker) works where a side job or dual employment has different employers, see Workers' accident benefits for a multiple-employment worker.

When do short-hour part-timers become covered by social insurance (20 hours a week, 51 persons)?

First, where the scheduled weekly working hours and the scheduled monthly working days are three-quarters or more of a regular worker's, the person becomes insured regardless of being short-hour. A short-hour worker who does not meet this three-quarters standard still becomes insured if all of the following are met (the coverage expansion from October 2024).

Requirement	Content
Working hours	Scheduled working hours of 20 or more a week (overtime and ad-hoc hours not included)
Pay	Scheduled monthly pay of 88,000 yen or more (overtime pay, bonuses, commuting allowance, etc. excluded)
Student	Not a student (with some exceptions)
Company scale	Working at a specified applicable workplace (more than 50, i.e. 51 or more, insured persons under employees' pension)

In addition, an expected employment period of more than two months is a general coverage requirement. Coverage was expanded in stages — to 101 or more in October 2022, and to 51 or more in October 2024. Whether the number is met is judged by whether the standard is met in 6 of the most recent 12 months. For the outlook on the coverage expansion, see The expansion of social-insurance coverage (2027).

Note that "51 or more" is counted per corporation (the same corporate number), so judge it by the whole company's number of insured persons under employees' pension, not by the number at a site.

In a workplace with many elderly part-timers, how do you handle securing employment up to age 70?

The Act on Stabilization of Employment of Elderly Persons makes securing employment up to age 65 an obligation (Article 9) and securing work up to age 70 an effort obligation (Article 10-2, in force from April 1, 2021). There are five measures for securing work up to age 70.

Category	Measure
Measures by employment	(1) Raise the retirement age to 70; (2) Abolish the retirement-age system; (3) Introduce a continued-employment system up to 70
Measures not by employment	(4) Continuously conclude a work-outsourcing contract up to 70; (5) Introduce a system allowing continued engagement in social-contribution work up to 70

(4) and (5) must be introduced with the consent of the majority labour union or the like. For the reduction and review of benefits where pay falls on continued employment of the elderly, see The reduction of the continued-employment benefit for the elderly (2025), and for designing re-employment after retirement age, see Securing employment up to age 70. In a workplace with many elderly workers, you design the work rules, wage rules, and whether social insurance applies at the same time, through short-hour and alternating-day work and the like.

For late-night and early-morning building cleaning, how are premiums and health handled?

For work made late at night (from 10 p.m. to 5 a.m.), a late-night premium of 25% or more is required (Labor Standards Act, Article 37, paragraph 4). Where overtime overlaps, overtime of 25% or more (50% or more over 60 hours a month) and the late-night 25% or more are added, and holiday work is 35% or more. Whether someone counts as a person in a managerial position is judged on the actual situation, and a nominal title alone does not avoid the late-night premium (the "manager in name only" issue is covered in A manager in name only and the late-night premium).

For health, a worker who regularly engages in work that includes late-night work is subject to a health check at the time of a reassignment and once every 6 months or less (the health check for those engaged in specified work, Ordinance on Industrial Safety and Health, Article 45). In a workplace with many elderly workers, safety consideration including prevention of falls and back pain is also important. Whether nap and standby time counts as working time is judged on the actual situation (the thinking on naps and intermittent work in the security industry, in Naps and intermittent work and working hours in the security industry, is a useful reference).

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Where do labour (shakai hoken roumushi) and the civil / tax sides of subcontracting divide?

The labour response for building maintenance and cleaning is not completed by labour matters alone. The party in charge differs by task.

What to do	Whose work it is
Drafting the work rules, wage rules and 36 Agreement; aggregated management of working hours across sites; social-insurance and employment-insurance acquisition and loss procedures; calculating premium wages	A Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant) (this office)
Civil disputes over the subcontract itself (interpretation of the contract, damages, unpaid receivables)	An attorney
Among payroll, the fixing of tax at year-end adjustment and decisions on withholding income tax	A tax accountant

This office is limited to providing information and handling procedures for labour management. Shakai hoken roumushi work and the work of an attorney or tax accountant are each carried out by an independent business entity and contracted separately. We do not take these on together under a single contract.

What can 四葉社会保険労務士事務所 do for you?

四葉社会保険労務士事務所 in Kohinata, Bunkyo Ward, handles, for building maintenance and cleaning businesses, putting the work rules and wage rules in order, aggregated management of working hours across sites, responding to the coverage expansion (judging 20 hours a week / 51 persons and acquiring coverage), designing the measures for securing work up to age 70, and calculating late-night and overtime premium wages. The initial consultation is free. We quote according to the content and the number of employees; for how fees are thought about, see the fee schedule, and the questions we are asked most often are collected on the FAQ page.

Where a civil dispute over a subcontract has already arisen, we will guide you to engage an attorney directly. This office does not accept referral fees.

Frequently asked questions

Q. If the same person enters two of our sites, how do we count working hours?
A. If they are several sites of the same company, manage by aggregating all sites. The part exceeding the statutory 8 hours a day and 40 hours a week after aggregation is overtime and requires a premium. If you manage time separately at each site, unpaid premiums for hours that become overtime after aggregation easily arise. Even for a side job or dual employment with different employers, working hours are aggregated (Labor Standards Act, Article 38, paragraph 1).

Q. Does a part-timer with 20 hours a week and 88,000 yen a month always join social insurance?
A. The requirements are scheduled working hours of 20 or more a week, scheduled monthly pay of 88,000 yen or more, not being a student, plus the workplace being a specified applicable workplace (a company with 51 or more insured persons under employees' pension) and an expected employment period of more than two months. Where the three-quarters standard (three-quarters or more of a regular worker's hours and days) is met, the person becomes insured regardless of being short-hour.

Q. Is securing work up to age 70 an obligation or an effort obligation?
A. Securing employment up to age 65 is an obligation (Act on Stabilization of Employment of Elderly Persons, Article 9), and securing work up to age 70 is an effort obligation (the same Act, Article 10-2). The measures include raising the retirement age, abolishing it, and a continued-employment system, as well as a work-outsourcing contract and engagement in social-contribution work; the latter two are introduced with the consent of the majority labour union or the like.

Q. For late-night building cleaning, how are the premium and health check handled?
A. Work from 10 p.m. to 5 a.m. requires a late-night premium of 25% or more (Labor Standards Act, Article 37, paragraph 4). Where overtime or holiday work overlaps, the premiums are added. Also, a worker who regularly engages in work that includes late-night work is subject to a health check at the time of a reassignment and once every 6 months or less (Ordinance on Industrial Safety and Health, Article 45).

Sources for this article

• Labor Standards Act (労働基準法, Act No. 49 of 1947), Article 32 (statutory working hours), Article 38, paragraph 1 (aggregation of working hours where the workplaces differ), Article 37, paragraph 4 (late-night premium: 25%+ from 10 p.m. to 5 a.m.; overtime 25%+, 50%+ over 60 hours a month, holiday 35%+), Article 89 (drawing up and filing work rules)
• Aggregation of working hours and treatment of premium wages in a side job / dual employment = the Ministry of Health, Labour and Welfare's "Guideline on promoting side jobs and dual employment" and Rodo Kijun Kyoku circular Kihatsu No. 3 of September 1, 2020. Premium wages are borne in principle by the employer who later concluded the contract setting scheduled working hours exceeding statutory hours after aggregation; the part actually worked beyond scheduled hours is borne by that employer (referenced October 2026)
• Expansion of social-insurance coverage to short-hour workers = Health Insurance Act (健康保険法, Act No. 70 of 1922) and Employees' Pension Insurance Act (厚生年金保険法, Act No. 115 of 1954). Requirements: scheduled working hours of 20 or more a week, scheduled monthly pay of 88,000 yen or more, not a student, and a specified applicable workplace (51 or more insured persons under employees' pension). Expanded from 101 or more to 51 or more in October 2024 (referenced October 2026 against materials of the Ministry of Health, Labour and Welfare and the Japan Pension Service)
• Act on Stabilization of Employment of Elderly Persons (高年齢者等の雇用の安定等に関する法律, Act No. 68 of 1971), Article 9 (measures to secure employment of the elderly up to 65 = obligation), Article 10-2 (measures to secure work of the elderly up to 70 = effort obligation; in force from April 1, 2021)
• Ordinance on Industrial Safety and Health (労働安全衛生規則, Labour Ministry Ordinance No. 32 of 1972), Article 45 (health check for those engaged in specified work that includes late-night work = at the time of a reassignment and once every 6 months or less)

This article does not go so far as to decide whom you should consult. Drafting the work rules, wage rules and 36 Agreement, aggregated management of working hours, social-insurance and employment-insurance procedures, and calculating premium wages are the work of a shakai hoken roumushi. Civil disputes over a subcontract are the work of an attorney; fixing tax at year-end adjustment and decisions on withholding income tax are the work of a tax accountant. Shakai hoken roumushi work and the work of an attorney or tax accountant are each carried out by an independent business entity and contracted separately. This office does not accept referral fees. The cost of consulting 四葉社会保険労務士事務所 is set out in the fee schedule, and the questions we are asked most often are collected on the FAQ page.

This article is general information. Judgments that fit your particular circumstances are made 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).