What to prepare when you first hire someone — the three statutory ledgers and how long to keep them
Joji Uramatsu
Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist — 四葉社会保険労務士事務所/四葉行政書士事務所
When you first hire, the law requires you to prepare a workers' roster and a wage ledger (Labour Standards Act Articles 107 and 108). In practice an attendance record is added and the three are called the "three statutory ledgers." The retention period is five years under Article 109, read as three years for the time being under supplementary Article 143 (both from the 1 April 2020 amendment). This article sets out what each ledger must record, the retention period and its start date, whether electronic storage is allowed, and how ledger-keeping (a shakai hoken roumushi) divides from tax (a tax accountant).
In short: When you first hire someone, the law first requires you to prepare two things — a workers' roster and a wage ledger (Labour Standards Act, Articles 107 and 108). In practice an attendance record is added and the three are called the "three statutory ledgers." The Labour Standards Act has no direct rule naming an "attendance record," but because the wage ledger must record the number of working days and hours, and because there is a duty to grasp the state of working hours by an objective method (Industrial Safety and Health Act, Article 66-8-3, in force 1 April 2019), an attendance record is needed to support them. The retention period is five years under Article 109, read as three years for the time being under supplementary Article 143 (both from the amendment in force 1 April 2020). This article sets out, from a shakai hoken roumushi's viewpoint, what each ledger records, the retention period and its start date, whether electronic storage is allowed, and how ledger-keeping divides from tax and disputes.
This page is for small business owners hiring an employee for the first time and for the first person put in charge of the labour side of hiring. Because whether a given entry is required and how storage is handled vary with the reality of the workplace, confirm finally with the Labour Standards Inspection Office with jurisdiction. For a sense of the cost of payroll itself, see How much does it cost to have a shakai hoken roumushi do payroll?.
What must you prepare first, by law, once you hire?
The Labour Standards Act requires an employer who hires even one worker to keep ledgers at each workplace. What the law expressly requires by name are two: the workers' roster and the wage ledger.
| Ledger | Basis | Position |
|---|---|---|
| Workers' roster | Labour Standards Act Art. 107 | Prepared for each worker at each workplace (except day labourers) |
| Wage ledger | Labour Standards Act Art. 108 | Entered without delay at each wage payment, at each workplace |
| Attendance record (time cards, etc.) | No direct naming rule in the Act | Supports the working-days/hours entries in the wage ledger and the duty to grasp working hours (ISHA Art. 66-8-3) |
"Three statutory ledgers" is a working term; the Act does not group "three ledgers" as such. The workers' roster and wage ledger are expressly in the Act, but the attendance record is needed in practice from other duties (the wage-ledger entries and grasping the state of working hours). The duty to draw up work rules arises from a workplace with 10 or more workers (Work rules are said to start from 10 people — what is needed?), but the three ledgers are needed at the entrance of employment regardless of headcount.
What goes in the workers' roster, the wage ledger and the attendance record?
For the workers' roster and wage ledger the entries are set out concretely in the Ordinance for Enforcement. Because gaps invite correction, grasp "what to write" before the form.
| Ledger | Main entries | Basis |
|---|---|---|
| Workers' roster | Name, date of birth, career (Art. 107); sex, address, type of work, date of hire, date and reason of retirement (including the reason if dismissal), date and cause of death (Enforcement Ordinance Art. 53) | Act Art. 107 / Enforcement Ordinance Art. 53 |
| Wage ledger | Name, sex, wage calculation period, working days, working hours, overtime/holiday/night hours, amounts by type of wage such as base pay and allowances, and any deducted amount | Act Art. 108 / Enforcement Ordinance Art. 54 |
| Attendance record, etc. | Attendance days, start/finish times, breaks, overtime/holiday/night hours — a record showing the state of working hours | Support for the wage ledger / ISHA Art. 66-8-3 |
The "type of work" in the workers' roster need not be entered at a workplace regularly using fewer than 30 workers (Enforcement Ordinance Art. 53(2)). Day labourers are outside the workers' roster (Act Art. 107(1), parenthetical). The state of working hours is to be grasped in principle by an objective method such as time cards or the record of a computer's usage time, not by self-report alone (ISHA Art. 66-8-3 and the Ministry's working-hours guidelines).
How many years must ledgers be kept, and from when do you count?
The retention period is set together in Labour Standards Act Article 109. Here the number changed with the amendment in force 1 April 2020, and a transitional measure remains — note both.
| Ledger / document | Retention | Start date (Enforcement Ordinance Art. 56) |
|---|---|---|
| Workers' roster | 5 years (3 years for the time being) | The day of the worker's death, retirement or dismissal |
| Wage ledger | 5 years (3 years for the time being) | The day of the last entry |
| Attendance record and other important documents on wages and labour relations | 5 years (3 years for the time being) | The day it is completed |
| (Reference) Record of the state of working hours under the ISHA | 3 years | Prepared and kept under the ISHA ordinance |
Article 109 sets the retention at "five years," but supplementary Article 143 reads it as "three years for the time being" (an amendment aligned with the review of the extinctive prescription of wage claims following the Civil Code amendment; in force 1 April 2020). So current practice is satisfied with three years' retention, but the statutory principle is five years. The start date differs by ledger — not from the date of hire or of preparation, but for the roster from the day of retirement/dismissal and for the wage ledger from the day of the last entry. Mistaking the count risks discarding a ledger earlier than the period required.
May you store ledgers electronically rather than on paper, and on what conditions?
The workers' roster, wage ledger and attendance record may be prepared and stored as electronic data if certain requirements are met. Whether paper or data, the premise is that they can be checked and printed at once when requested.
| Point | Thinking on electronic storage |
|---|---|
| Medium of preparation/storage | Electronic data is acceptable if the entries are complete and requirements such as tamper-prevention and searchability are met |
| Ability to output | On an inspection by a labour standards inspector, the required items can be shown at once and printed to paper |
| Backup | Management against loss or alteration (access control, backup) is in place |
Even when managing the roster or attendance in a cloud labour/attendance system, completeness of entries and management of the retention period and start date do not change. What is easy to overlook after installing a system is the retention of former employees' records. Even after someone retires, the workers' roster and wage ledger must be kept for the set years from the start date, so set up an operation that does not delete them at the moment of retirement. For the line-drawing when payroll is done in-house on a system, see also How much does it cost to have a shakai hoken roumushi do payroll?.
How does ledger-keeping (a shakai hoken roumushi) divide from tax (a tax accountant)?
Setting up the three ledgers is the labour of the entrance of employment itself — the work of a shakai hoken roumushi. Meanwhile withholding and year-end adjustment, tied to payroll, are the field of tax, and the party in charge differs.
| What to do | Whose work |
|---|---|
| Setting up the workers' roster, wage ledger and attendance record; designing entries and retention; attendance and payroll; arranging work rules and employment contracts | A Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant) (this office) |
| Withholding, year-end adjustment, income-tax filing | A tax accountant (filed with the tax office) |
| Individual labour disputes such as unpaid wages | An attorney |
This office is limited to information and procedures on labour and social insurance. We guide you to a tax accountant (filed with the tax office) for tax such as withholding and year-end adjustment, and connect you to an attorney for individual wage disputes. These are, on the premise that each is carried out by an independent business entity and contracted separately, and we do not accept everything under one contract. This office does not accept referral fees. The final judgment on whether a given entry is required and how storage is handled is made by the Labour Standards Inspection Office with jurisdiction.
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 owners hiring an employee for the first time, setting up the workers' roster, wage ledger and attendance record, designing the entries and the retention period and start date, building the attendance and payroll flow, and arranging employment contracts and (as needed) work rules. Whether you run on paper or electronically, we help design the retention including former employees' records. The initial consultation is free. For how fees are thought about, see the fee schedule; the questions we are asked most often are on the FAQ page.
We guide you to a tax accountant (filed with the tax office; an independent business entity, contracted separately) for withholding, year-end adjustment and income-tax filing, and to an attorney for wage disputes. This office does not accept referral fees.
Frequently asked questions
Q. Even with just one employee, must I prepare a workers' roster and a wage ledger?
A. Yes. Labour Standards Act Articles 107 and 108 require an employer who hires even one worker to prepare a workers' roster and a wage ledger at each workplace. The duty to draw up work rules arises from a workplace with 10 or more workers, but the three ledgers are needed at the entrance of employment regardless of headcount. Day labourers are outside the workers' roster.
Q. Do I keep ledgers for three years, or five?
A. Labour Standards Act Article 109 sets the principle at "five years," but supplementary Article 143 reads it as "three years for the time being" (in force 1 April 2020). So current practice is satisfied with three years, but keep in mind that the statutory principle is five. The start date differs by ledger (Enforcement Ordinance Art. 56).
Q. Does the law require an attendance record to be made?
A. The Labour Standards Act has no direct duty to make a ledger named "attendance record." But because the wage ledger must record working days and hours (Act Art. 108, Enforcement Ordinance Art. 54), and because there is a duty to grasp the state of working hours by an objective method (Industrial Safety and Health Act Art. 66-8-3, in force 1 April 2019), an attendance record or time cards are needed in practice to support them.
Q. May I store ledgers electronically on a PC or in the cloud?
A. If the entries are complete and requirements such as tamper-prevention and searchability are met, and they can be checked and printed at once when requested, preparation and storage as electronic data is allowed. Even when managing on a system, the retention period and start date for former employees' records do not change, so it matters to run an operation that does not delete them at the moment of retirement.
Sources for this article
- Labour Standards Act (Act No. 49 of 1947), Article 107 (workers' roster), Article 108 (wage ledger), Article 109 (retention of records) / confirmed against the e-Gov law text (referenced September 2026). The retention in Article 109 is "five years," read as "three years for the time being" under supplementary Article 143
- The amendment changing retention from three to five years (three for the time being), aligned with the review of the extinctive prescription of wage claims following the Civil Code amendment; in force 1 April 2020 / confirmed against the e-Gov law text and Ministry of Health, Labour and Welfare guidance (referenced September 2026)
- Ordinance for Enforcement of the Labour Standards Act (Ministry of Health and Welfare Ordinance No. 23 of 1947), Article 53 (workers'-roster entries), Article 54 (wage-ledger entries), Article 56 (start date of retention) / confirmed against the e-Gov law text (referenced September 2026)
- Industrial Safety and Health Act (Act No. 57 of 1972), Article 66-8-3 (grasping the state of working hours; in force 1 April 2019; by an objective method), and the "Guidelines on measures employers should take to grasp working hours appropriately" (Ministry of Health, Labour and Welfare, drawn up 20 January 2017) / confirmed against the e-Gov law text and Ministry guidance (referenced September 2026)
- The handling of electronic preparation/storage of ledgers is confirmed against Ministry of Health, Labour and Welfare / Labour Standards Inspection Office guidance (referenced September 2026), on the premise that the required items can be shown at once and printed on an inspection
This article does not go so far as to decide whom you should consult. Setting up the workers' roster, wage ledger and attendance record, designing entries and retention, attendance and payroll, and arranging work rules and employment contracts are the work of a shakai hoken roumushi. Withholding, year-end adjustment and income-tax filing are the work of a tax accountant (filed with the tax office); labour disputes such as unpaid wages are the work of an attorney. Shakai hoken roumushi work and these are each carried out by an independent business entity and contracted separately. This office does not accept referral fees. The final judgment on whether a given entry is required and how storage is handled is made by the Labour Standards Inspection Office with jurisdiction. The cost of consulting 四葉社会保険労務士事務所 is on 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. Written by Joji Uramatsu (Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist).
Shall we start by reviewing how you work?
四葉社会保険労務士事務所 (Kohinata, Bunkyo-ku; a 5-minute walk from Myogadani Station on the Tokyo Metro Marunouchi Line) helps you, starting with a review of your current labour practices.
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