Can freelancers (specified entrusted businesses) join workers' accident insurance too? The special-enrollment requirements and procedure after the November 2024 expansion

In short: Freelancers (specified entrusted businesses) can, from November 1, 2024, join workers' accident insurance by special enrollment regardless of industry. Accident insurance is originally a system for workers, but the injuries of people who take on work on commission without employing workers can be made a target of coverage through the special-enrollment system (Workers' Accident Compensation Insurance Act, Articles 33 to 37). What was newly established that day is the "specified freelance business (the business carried on by a specified entrusted business)" under Type 2 special enrollment (sole proprietors and the like, Article 35), so special enrollment of sole proprietors and the like, formerly limited to certain industries such as construction and transport, spread to freelancers generally. Enrollment is applied for by the person through a special-enrollment association, choosing a daily benefit base (in the range of 3,500 to 25,000 yen), which the prefectural labour bureau director decides. Separately, the Freelance Act effective the same November 1, 2024 (the Act on Optimising Transactions Related to Specified Entrusted Businesses, Act No. 25 of 2023) is a system that imposes duties such as disclosure of transaction terms on the ordering side, with an aim different from accident-insurance special enrollment. From the viewpoint of a shakai hoken roumushi, this page covers the target, procedure and premium of special enrollment, the difference from the Freelance Act, how ordering companies should approach it, and who to ask for what — leaving the design of commission contracts to a gyoseishoshi or an attorney and disputes over fees or contracts to an attorney, under separate engagements with each as an independent business entity.

Freelancers who work on commission could not, as a rule, receive accident-insurance benefits when injured at work, because they are not workers. The November 1, 2024 amendment fills this gap. This page is for both the freelancer and companies that order work from freelancers, setting out the key points of the special-enrollment system from the viewpoint of a shakai hoken roumushi.

From November 1, 2024, how far can freelancers (specified entrusted businesses) join accident insurance?

Workers' accident insurance is originally a system for workers. Freelancers who work without employing workers become a target of the special-enrollment system (Workers' Accident Compensation Insurance Act, Articles 33 to 37, Chapter 4-2), a voluntary enrollment on the person's own application where it is appropriate to protect them in a way similar to workers given the nature of their business.

On November 1, 2024, the "specified freelance business (the business carried on by a specified entrusted business)" was newly established under Type 2 special enrollment (sole proprietors and the like, Article 35). This made special enrollment possible regardless of industry, for the business a specified entrusted business carries on by taking work on commission. Formerly, special enrollment of sole proprietors and the like was limited to listed industries such as construction, transport and fishing, and other freelancers (IT, design, interpreting, lecturing, sales agency and so on) were outside it, but this expansion opened the way widely.

Here, a "specified entrusted business" follows the Freelance Act's definition — a business that takes on work on commission and does not employ workers (an individual, or a company with only one representative). Injuries in the course of taking on the same kind of work from consumers (so-called B-to-C) are also included in the coverage.

What are the target, procedure and premium (daily benefit base) of special enrollment?

Special enrollment is applied for not directly by the person but through a special-enrollment association approved by the labour bureau director. The key points of procedure and cost are as follows.

Item	Content
Who may enroll	A specified entrusted business that carries on a business by taking work on commission without employing workers (specified freelance business)
Where to apply	The special-enrollment association for the specified freelance business (the person applies through the association to the prefectural labour bureau)
Daily benefit base	Applied for from a step within the range of 3,500 to 25,000 yen, and decided by the prefectural labour bureau director (the basis for both benefits and premium)
Premium	Daily benefit base × 365 (premium-calculation base) × the premium rate for the specified freelance business
Scope of coverage	Employment injury, multiple-employer-factor injury, and commuting injury. Medical, absence, disability, survivors' and other benefits

The daily benefit base is both the basis of benefit amounts such as absence compensation and the basis for calculating the premium. Set it higher and both the benefits and the premium grow. After enrollment, the premium is paid through the special-enrollment association. Check specific amounts and eligibility with the association and the latest guidance. This differs from the Type 1 special enrollment of a small-business owner who uses workers (Article 34) in both the window and the requirements (the difference is covered in an executive's accident-insurance special enrollment, and the construction sole-proprietor example in social insurance in construction and a sole proprietor's accident-insurance special enrollment).

What are the ordering side's duties under the Freelance Act, and how do they differ?

The Freelance Act, effective the same November 1, 2024 (the Act on Optimising Transactions Related to Specified Entrusted Businesses, Act No. 25 of 2023), is a completely separate system from accident-insurance special enrollment. Whereas special enrollment is "a scheme the freelancer joins voluntarily," the Act is "a law that imposes transaction optimisation on the side that orders work from freelancers."

The main duties imposed on the ordering side (specified business-committing businesses and the like) are as follows.

Duty of the ordering side	Outline	Target
Disclosure of transaction terms	Disclose work content, fee amount, payment date and the like in writing (Article 3)	All business commissions
Fee payment date	As a rule, pay within as short a period as possible within 60 days from the day the deliverable is received (Article 4)	All business commissions
Prohibited acts	Prohibits seven types such as refusal of receipt, fee reduction, returns and undervaluing (Article 5)	Commissions of 1 month or more
Accurate display of recruitment information	Display recruitment information accurately in advertisements and the like (Article 12)	Where recruiting
Consideration for childcare / care and harassment measures	Consideration for requests (Article 13); a consultation system (Article 14)	Article 13 is 6 months or more
Advance notice of mid-term termination	As a rule, notice 30 days in advance (Article 16)	Commissions of 6 months or more

The Act aims at transaction optimisation and does not impose on the orderer a duty to enroll freelancers in accident insurance. The ordering side's duties are set out in detail in the Freelance Act and what ordering companies must check.

How should ordering companies approach special enrollment?

Special enrollment is a system the freelancer joins voluntarily. Ordering companies have no duty to enroll them and cannot do the procedure on the person's behalf. That said, if the substance of the commission contract is strong in worker-ness — subject to direction and supervision, bound as to time and place — then even if named a commission, the person is treated as a worker and becomes a target of accident and social insurance. In ordering, the starting point is first to discern whether the substance is a commission or employment.

On that basis, ordering companies must correctly fulfil the Freelance Act's duties such as disclosure of transaction terms and the fee payment date. Given that special enrollment is the person's voluntary enrollment, making the roles clear in the contract for safety and in the event of an accident helps avoid later trouble. The final judgment of worker-ness is made against the actual situation by a qualified professional.

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Who do you ask for what (the special-enrollment procedure, the contract side, disputes)?

Let us separate the roles. Explaining the special-enrollment system of accident insurance, arranging labour and social insurance, and checking the substance of work and worker-ness are the work of a shakai hoken roumushi. That is what this office handles. However, the special-enrollment application itself is done by the person through a special-enrollment association.

Drafting a commission contract with a freelancer, and designing the disclosure of transaction terms the Act requires, are the work of a gyoseishoshi or an attorney. Disputes over non-payment of fees or termination of the contract are the work of an attorney. We will guide you to contract with each as an independent business entity, separately, and this office does not accept referral fees.

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 companies that order work from freelancers, checking worker-ness — whether it is a commission or employment — arranging labour and social insurance, and, where workers are hired, condition disclosure and putting the work rules in order. For the freelancer, we explain how the special-enrollment system works and the flow of the procedure through a special-enrollment association. The initial consultation is free. We quote according to the content; for how fees are thought about, see the fee schedule, and the questions we are asked most often are on the FAQ page.

Drafting a commission contract and designing the Act's disclosure of transaction terms are the work of a gyoseishoshi or an attorney, and disputes over fees or contracts are the work of an attorney; we will guide you to contract with each separately, as an independent business entity. This office does not accept referral fees.

Frequently asked questions

Q. From when, and in which industries, can freelancers join accident insurance?
A. From November 1, 2024. On that day, the "specified freelance business (the business carried on by a specified entrusted business)" was newly established under Type 2 special enrollment (sole proprietors and the like, Workers' Accident Compensation Insurance Act, Article 35), so freelancers who work on commission without employing workers can join by special enrollment regardless of industry. Formerly it was limited to certain industries such as construction and transport, but it now covers IT, design, interpreting, lecturing, sales agency and more widely. Injuries in taking the same kind of work from consumers are also covered.

Q. Where is special enrollment applied for, and how is the premium decided?
A. The person applies through a special-enrollment association for the specified freelance business, approved by the prefectural labour bureau director. A daily benefit base is applied for from a step within the range of 3,500 to 25,000 yen, and the prefectural labour bureau director decides it. The premium is calculated as "daily benefit base × 365 (premium-calculation base) × the premium rate for the specified freelance business" and paid through the association. Check specific amounts and eligibility with the association and the latest guidance.

Q. Are the Freelance Act and accident-insurance special enrollment the same thing?
A. No, they are separate systems. Special enrollment is a scheme the freelancer joins voluntarily in accident insurance. The Freelance Act (the Act on Optimising Transactions Related to Specified Entrusted Businesses, Act No. 25 of 2023, effective November 1, 2024) is a law that imposes on the side ordering work from freelancers duties such as disclosure of transaction terms (Article 3) and the fee payment date (Article 4); it does not impose on the orderer a duty to enroll freelancers in accident insurance. They merely share an effective date, with different aims.

Q. Does an ordering company have a duty to enroll freelancers in accident insurance?
A. No. Special enrollment is a system the person joins voluntarily, and the ordering company has neither a duty to enroll nor the ability to do the procedure on the person's behalf. However, even if named a commission, if the substance is employment — subject to direction and supervision, bound as to time and place — the person is treated as a worker and becomes a target of accident and social insurance. In ordering, the starting point is first to discern whether the substance is a commission or employment. The final judgment of worker-ness is made against the actual situation by a qualified professional.

Sources for this article

• Workers' Accident Compensation Insurance Act (労働者災害補償保険法, Act No. 50 of 1947), Chapter 4-2 "Special Enrollment," Articles 33 to 37. Article 33 lists those who may enroll by special enrollment; Article 34 provides for small-business owners and the like (Type 1) and Article 35 for sole proprietors and the like (Type 2). The daily benefit base is set by the prefectural labour bureau director on application (confirmed against e-Gov on October 26, 2026)
• Enforcement Regulation of the Workers' Accident Compensation Insurance Act (労働者災害補償保険法施行規則, Ministry of Labour Ordinance No. 22 of 1955). By the amendment effective November 1, 2024, the "specified freelance business (the business carried on by a specified entrusted business)" was added to the target of Type 2 special enrollment. Regardless of industry, a business carried on by taking work on commission without employing workers is the target (referenced October 26, 2026)
• Act on Optimising Transactions Related to Specified Entrusted Businesses (the Freelance Act, 特定受託事業者に係る取引の適正化等に関する法律, Act No. 25 of 2023, effective November 1, 2024). Article 2 (a specified entrusted business = a business that takes work on commission and does not employ workers), Article 3 (disclosure of transaction terms), Article 4 (fee payment date = within 60 days from receipt of the deliverable), Article 5 (prohibited acts for commissions of 1 month or more), Article 12 (accurate display of recruitment information), Articles 13 and 14 (consideration for childcare / care and harassment measures), Article 16 (advance notice of mid-term termination for commissions of 6 months or more) (confirmed against e-Gov on October 26, 2026)
• Ministry of Health, Labour and Welfare, guidance on special enrollment such as the "Guide to the Special-Enrollment System (specified freelance business)." That the specified freelance business was newly established on November 1, 2024, targets freelancers of all industries, covers injuries in the same kind of business taken on from consumers, and is applied for through a special-enrollment association (referenced October 26, 2026)
• The range of choice of the daily benefit base (3,500 to 25,000 yen) follows the general range of the special-enrollment system. The specific premium rate and steps for the specified freelance business must be checked with the special-enrollment association and the latest Ministry of Health, Labour and Welfare guidance (referenced October 26, 2026)

This article does not go so far as to decide whom you should consult. Explaining the special-enrollment system of accident insurance, arranging labour and social insurance, and checking worker-ness are the work of a shakai hoken roumushi. The special-enrollment application itself is done by the person through a special-enrollment association. Drafting a commission contract and designing the Act's disclosure of transaction terms are the work of a gyoseishoshi or an attorney, and disputes over fees or contracts are the work of an attorney; each is 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 on the FAQ page.

This article is general information. Judgments that fit your particular circumstances are made by a qualified professional after a meeting, in light of the latest primary materials (the Ministry of Health, Labour and Welfare, e-Gov, etc.). Written by Joji Uramatsu (Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist).