Bus drivers' 2024 Improvement Standards Notice — on-duty hours, rest, continuous driving, and the 36 Agreement

In short: Bus drivers' working hours are managed under the Labor Standards Act plus the Improvement Standards Notice (Standards for Improving the Working Hours, etc., of Motor Vehicle Drivers). Under the current standard (amended December 23, 2022 (Reiwa 4), applied from April 1, 2024 (Reiwa 6)), on-duty hours are managed either "per year and month" or "per 52 weeks and 4-week average week," with a principle of up to 3,300 hours a year and 281 hours a month (or 3,300 hours over 52 weeks and 65 hours on a 4-week average week). Daily on-duty hours are 13 in principle and up to 15, and the rest period is based on a continuous 11 hours and never below a continuous 9 hours. This page sets out, from the viewpoint of a shakai hoken roumushi's labour management, how bus differs from taxi and trucking, the limits on on-duty hours, continuous driving and rest periods, alignment with the 36 Agreement and its special clause, and who to ask for what.

Bus work is a sector where on-duty management easily becomes complex — the difference between route (noriai) and chartered (kashikiri) service, long-distance and overnight operation, and two-driver crewing. This page is for the labour and operation-management staff of route and chartered bus operators. It sets out the bus figures in the Improvement Standards Notice, the two ways of managing on-duty hours, continuous driving and rest periods, how to align the 36 Agreement and its special clause, and the line between labour matters and transport licensing and operation management.

How does the bus Improvement Standards Notice differ from taxi and trucking?

The Improvement Standards Notice is a notice of the Minister of Health, Labour and Welfare that sets upper and lower limits on "on-duty hours" (working hours plus breaks and standby time), the "rest period" between shifts, "driving time," and "continuous driving time." It was amended on December 23, 2022 (Reiwa 4) and has applied since April 1, 2024 (Reiwa 6). From the same April 1, 2024, the overtime cap also applies to motor-vehicle driving (up to 960 hours a year even under a special clause; Labor Standards Act, Supplementary Provisions, Article 140, paragraph 1). The "overtime cap" and the "Improvement Standards Notice" are different yardsticks, and you must satisfy both at the same time.

Bus, truck, and taxi are covered by the same notice, but the figures are set separately by sector. The main differences are as follows.

Item	Bus	Truck	Taxi
On-duty hours per year	3,300 hours in principle	3,300 hours in principle	(set separately for day-shift / alternating-day)
On-duty hours per month	281 hours in principle	284 hours in principle	288 (day shift) / 262 (alternating-day)
Daily on-duty (guideline for exceeding 14 hours)	up to 3 times a week	up to 2 times a week	up to 3 times a week
Driving time	9 hours a day on a two-day average; 40 hours a week on a 4-week average	9 hours a day on a two-day average; 44 hours a week on a two-week average	—

The taxi figures for alternating-day work (22 hours per two days, etc.) are in Taxi drivers' 2024 Improvement Standards Notice and alternating-day work, and trucking's "2024 problem" is in The "2024 problem" in trucking and the Improvement Standards Notice. What stands out for bus is that monthly on-duty hours are shorter than for trucking, and the weekly driving-time standard is on a 4-week average.

How are the daily, monthly, and yearly on-duty limits decided?

Bus on-duty hours are managed by choosing one of two methods — "per year and month" or "per 52 weeks and 4-week average week." The principle values and the extensions available by labour-management agreement (for chartered-bus and similar drivers) are as follows.

Management method	Principle	Exception by labour-management agreement (chartered-bus etc. drivers)
Per year and month	Within 3,300 hours a year and 281 hours a month	Up to 294 hours a month within 3,400 hours a year (for up to 6 months a year; exceeding 281 hours for up to 4 consecutive months)
Per 52 weeks and 4-week average week	Within 3,300 hours over 52 weeks and 65 hours on a 4-week average week	Up to 68 hours on a 4-week average week within 3,400 hours over 52 weeks (for up to 24 of the 52 weeks; exceeding 65 hours for up to 16 consecutive weeks)

On a daily basis, on-duty hours are 13 in principle, and even when extended the limit is 15 hours. Exceeding 14 hours is a guideline of up to 3 times a week, with an effort to keep it as few as possible.

The Improvement Standards Notice is not the Labor Standards Act itself but a notice; still, a breach is subject to corrective guidance from the Labor Standards Inspection Office and can lead to transport-administration sanctions (administrative dispositions against the operator). The difference from the overtime cap is that it is not "unlimited as long as you have an agreement."

How short can continuous driving and the rest period be?

The rest period is based on an effort to give a continuous 11 hours or more between shifts and does not fall below a continuous 9 hours. Where it is difficult to give 9 hours or more after duty, the rest period may be split, up to one month and for up to half of all shifts, with each split part being a continuous 4 hours or more, totalling 11 hours or more, in up to two parts.

Driving time and continuous driving time are as follows.

Item	Standard
Driving time	Up to 9 hours a day on a two-day (48 hours from the start of duty) average; up to 40 hours a week on a 4-week average
Continuous driving time	Within 4 hours (an interruption needs non-driving time of a continuous 10 minutes or more per time, totalling 30 minutes or more)
Expressway service sections (highway/chartered bus)	An effort to keep them to roughly 2 hours

For unforeseeable events such as an accident, breakdown, or disaster that cause a delay, the time required to deal with them may, only where objective records are recognised, be excluded in applying the per-day on-duty, two-day-average driving, and continuous-driving limits. However, after duty the ordinary rest period (based on a continuous 11 hours, not below 9) must still be secured. Recording the reality of naps and standby through a digital tachograph or daily log is the starting point.

How do you align the 36 Agreement and the special clause with the notice?

Bus is also motor-vehicle driving, so the overtime cap is up to 960 hours a year even under a special clause (Labor Standards Act, Article 36 and Supplementary Provisions Article 140, paragraph 1). The 36 Agreement and the work rules must be designed so they do not conflict with the on-duty hours and rest periods of the Improvement Standards Notice. The points to fix are as follows.

What to do	Point to review
36 Agreement (special clause)	Design overtime within 960 hours a year, and state the frequency of the special clause (up to 6 times a year), the reasons, and the procedure
Work rules and wage rules	State the on-duty hours, rest periods, late-night premium (25%+ from 10 p.m. to 5 a.m.), and breaks, and align them with the notice figures
Variable working-hour system	Design long-distance and overnight operation under a one-month variable working-hour system (Labor Standards Act, Article 32-2) and put the scheduled hours and days off into the rules
Records of on-duty and driving hours	Cross-check the digital tachograph and daily logs against attendance, and run day-to-day management against 281 hours a month (or 65 hours on a 4-week average week), driving time, and 4-hour continuous driving
Selection of the majority representative	Select someone who is not in a managerial position through a proper procedure, and keep a record (Ordinance for Enforcement of the Labor Standards Act, Article 6-2)

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Work rules must be drawn up and filed by a workplace that regularly employs 10 or more workers (Labor Standards Act, Article 89). For how many employees make work rules mandatory, see How many employees make work rules mandatory, and for the basics of the 36 Agreement and the overtime ceiling, see The 36 Agreement and the overtime ceiling.

Where do labour management (shakai hoken roumushi) and transport licensing / operation management divide?

The labour response for a bus business 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; putting on-duty and driving-hour management in place; calculating premium wages	A Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant) (this office)
Licence applications for a general route / general chartered passenger-car transport business and papers for business-plan changes	A Gyoseishoshi (Certified Administrative Procedures Legal Specialist)
Transport-administration decisions on fares, operations, operation managers, and safety oversight	The District Transport Bureau (Un'yu Shikyoku)
Claims for unpaid premium wages, labour disputes, labor tribunal proceedings or litigation	An attorney
Tax decisions on withholding and year-end adjustment of premium pay	A tax accountant

This office is limited to providing information and handling procedures for labour management. For licences and business-plan changes in a bus business, we can connect you to 四葉行政書士事務所; on the premise that shakai hoken roumushi work and gyoseishoshi work are each carried out by an independent business entity and are 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 bus businesses, aligning the work rules and wage rules with the Improvement Standards Notice, designing a one-month variable working-hour system, designing and filing the 36 Agreement (special clause), calculating late-night and overtime premium wages, and putting on-duty and driving-hour management in place. 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 claim for unpaid premium wages or a dispute has already arisen, we will guide you to engage an attorney directly. This office does not accept referral fees.

Frequently asked questions

Q. Should bus on-duty hours be viewed per year or per month?
A. You choose and run one of two methods — "per year and month" or "per 52 weeks and 4-week average week." The former is 3,300 hours a year and 281 hours a month in principle; the latter is 3,300 hours over 52 weeks and 65 hours on a 4-week average week in principle. For chartered-bus and similar drivers, a labour-management agreement can extend the former to 294 hours a month within 3,400 hours a year (for up to 6 months a year), and the latter to 68 hours on a 4-week average week within 3,400 hours over 52 weeks (for up to 24 of the 52 weeks).

Q. What is the maximum daily on-duty time allowed?
A. 13 hours in principle, and even when extended the limit is 15 hours. Exceeding 14 hours is a guideline of up to 3 times a week, with an effort to keep it as few as possible. For trucks, exceeding 14 hours is up to 2 times a week, while for bus and taxi it is up to 3 times a week — the guideline differs by sector.

Q. How many hours of continuous driving are allowed, and how should breaks be taken?
A. Continuous driving time is within 4 hours. An interruption needs non-driving time of a continuous 10 minutes or more per time, totalling 30 minutes or more. For expressway service sections of highway and chartered buses, the effort is to keep them to roughly 2 hours.

Q. Can you also handle the bus licence?
A. Labour management is the work of a shakai hoken roumushi, and the papers for a general route or general chartered passenger-car transport business licence or a business-plan change are the work of a gyoseishoshi. On the premise that each is an independent business entity contracted separately, we can connect you to 四葉行政書士事務所. We do not take these on together under a single contract.

Sources for this article

• "Standards for Improving the Working Hours, etc., of Motor Vehicle Drivers" (the Improvement Standards Notice; Labour Ministry Notice No. 7 of 1989, amended by Ministry of Health, Labour and Welfare Notice No. 367 of December 23, 2022, applied from April 1, 2024), provisions on bus drivers. On-duty hours: 3,300 hours a year and 281 hours a month in principle (or 3,300 hours over 52 weeks and 65 hours on a 4-week average week); for chartered-bus and similar drivers, by labour-management agreement, up to 294 hours a month within 3,400 hours a year (for up to 6 months a year; exceeding 281 hours for up to 4 consecutive months) and up to 68 hours on a 4-week average week within 3,400 hours over 52 weeks (for up to 24 of the 52 weeks; exceeding 65 hours for up to 16 consecutive weeks). Daily on-duty 13 hours in principle, up to 15 (exceeding 14 hours: a guideline of up to 3 times a week). Rest period based on a continuous 11 hours, not below 9. Driving time 9 hours a day on a two-day average and 40 hours a week on a 4-week average. Continuous driving within 4 hours (interruption of a continuous 10 minutes or more, totalling 30 minutes or more)
• Labor Standards Act (労働基準法, Act No. 49 of 1947), Article 32, Article 32-2 (one-month variable working-hour system), Article 36 (agreement on overtime and holiday work), Article 37 (premium wages: 25%+ for overtime, 50%+ over 60 hours a month, 35%+ for holiday work, 25%+ for late-night work), Article 89 (drawing up and filing work rules), and Supplementary Provisions Article 140, paragraph 1 (application of the overtime cap to motor-vehicle driving: up to 960 hours a year even under a special clause)
• Ordinance for Enforcement of the Labor Standards Act (労働基準法施行規則, Ordinance No. 23 of 1947), Article 6-2 (requirements for the majority representative)
• The figures for on-duty hours, rest periods, driving time, continuous driving, and unforeseeable events were checked against the Ministry of Health, Labour and Welfare's portal site on improving long working hours of motor vehicle drivers, the page for bus drivers, and the Ministry of Health, Labour and Welfare / Ministry of Land, Infrastructure, Transport and Tourism leaflets for bus drivers (referenced October 2026)

This article does not go so far as to decide whom you should consult. Drafting the work rules, wage rules and 36 Agreement, putting on-duty and driving-hour management in place, and calculating premium wages are the work of a shakai hoken roumushi. Licence applications for a general route or general chartered passenger-car transport business and papers for business-plan changes are the work of a gyoseishoshi; claims for unpaid premium wages and disputes are the work of an attorney; tax decisions on withholding and the year-end adjustment are the work of a tax accountant. Shakai hoken roumushi work and gyoseishoshi work 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).