Duty to publish childcare-leave uptake — does it reach companies over 300 from April 2025?
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
From 1 April 2025 (Reiwa 7), the duty to publish the state of male employees' childcare-leave uptake widened from companies with more than 1,000 ordinarily-employed workers to those with "more than 300". What you publish is the male childcare-leave uptake rate, once a year, for the immediately preceding business year, within roughly three months after that year ends, by a method anyone can view. Preparing the childcare/family-care leave rules and handling the calculation and publication of the uptake rate is a Shakai Hoken Roumushi's work; this office accepts work as an independent business entity, and individual determinations are made by a qualified professional after a consultation.
Bottom line first: From 1 April 2025 (Reiwa 7), the duty to publish the state of male employees' childcare-leave uptake widened from companies with more than 1,000 ordinarily-employed workers to those with "more than 300". What you publish is the male childcare-leave uptake rate — once a year, for the immediately preceding business year, within roughly three months after that year ends, by a method anyone can view.
Preparing the childcare/family-care leave rules and handling the calculation and publication of the uptake rate is a Shakai Hoken Roumushi's work. We design the calculation and publication method together with you, but the final check and approval are done by the company. 四葉社会保険労務士事務所 accepts work as an independent business entity, and individual determinations are made by a qualified professional after a consultation.
From April 2025, to whom does the publication duty widen?
Publication of childcare-leave uptake was originally imposed, from April 2023 (Reiwa 5), on companies with more than 1,000 ordinarily-employed workers. By the amended Child Care and Family Care Leave Act enacted in 2024 (Reiwa 6) (Act No. 42 of 2024), from 1 April 2025 (Reiwa 7) the scope widened to companies with "more than 300". The basis is Article 22-2 of the Act (publication of the state of childcare-leave uptake).
| Time | Companies subject to the publication duty |
|---|---|
| From April 2023 | companies with more than 1,000 ordinarily-employed workers |
| From April 2025 | companies with more than 300 ordinarily-employed workers (including 1,000 or fewer) |
Newly covered are companies with more than 300 and up to 1,000 employees. The duty of companies over 1,000 that were already publishing does not change. The 2025 amendment to the Act is not only this widening of the publication duty; several items — benefits and flexible working — move at the same time. The whole picture is set out in The 2025 amendment to the Child Care and Family Care Leave Act — what employers should do.
How do you count "more than 300 ordinarily-employed workers"?
"Ordinarily-employed workers" does not mean only full-time staff. Regardless of employment form or title, you count in workers who are in effect in the same state as being employed without a fixed term.
| Way of counting | Include? |
|---|---|
| Persons employed without a fixed term | include |
| Part-timers etc. who have been continuously employed for 1 year or more, or are expected to be employed for 1 year or more from hiring | include |
| Short-term workers not falling under the above | in principle, do not include |
"More than 300" does not include exactly 300. It means 301 or more. When your headcount is near the line, you need to count including the employment reality of part-timers and casual staff, so it is safer to confirm the way of counting together with preparing the work rules. The duty for the work rules themselves is set out in From how many employees are work rules mandatory. The concrete application of the headcount can differ depending on the employment reality.
By what formula do you calculate the uptake rate to publish?
What you publish is the male employees' childcare-leave uptake rate. You choose and publish one of the following two.
| Indicator to publish | Formula |
|---|---|
| ① Childcare-leave uptake rate | number of male workers who took childcare leave etc. ÷ number of male workers whose spouse gave birth |
| ② Uptake rate of childcare leave and childcare-purpose leave | (number of male workers who took childcare leave etc. + number of male workers who used a childcare-purpose leave scheme) ÷ number of male workers whose spouse gave birth |
The denominator is "the number of male workers whose spouse gave birth in that business year". A male worker who took childcare leave several times for the same child is counted as one person. You also publish the name of the indicator so it is clear which you chose. Keeping the childcare-leave benefit and childcare-purpose-leave records organised keeps the calculation from wobbling. The amendments on the benefit side are set out in Requirements for the reduced-hours childcare working benefit and The post-birth leave support benefit.
By when and where must you publish?
Publication is once a year. You publish, for the business year immediately preceding the one in which the publication date falls, within roughly three months after that immediately preceding business year ends.
| Item | Content |
|---|---|
| Target period | the immediately preceding one business year |
| Timing | within roughly three months after the immediately preceding business year ends |
| Method | use of the internet, or another appropriate method that the general public can view |
| Examples of where | your own website, or the Ministry of Health, Labour and Welfare's "Ryoritsu Shien no Hiroba" |
Even without a company website, publishing by a method anyone can view, such as "Ryoritsu Shien no Hiroba", is enough. Because the published figures are information that job-seekers and business partners will see, keeping the basis of the calculation is important. The practice of extending the childcare-leave benefit is compiled in Extending the childcare-leave benefit — the 2025 tightening.
What disadvantage arises if you do not publish?
Even a breach of the publication duty does not immediately bring a fine. However, as a breach of the Act, it becomes subject to the following responses.
| Stage | Content |
|---|---|
| Report demand / advice / guidance / recommendation | the Minister of Health, Labour and Welfare (the Prefectural Labour Bureau) demands a report and gives advice, guidance and recommendation (Child Care and Family Care Leave Act Article 56) |
| Publication of the company name | where the company does not follow the recommendation, that fact may be published (same Act, Article 56-2) |
| Non-penal fine | where a report is not made, or a false report is made, a non-penal fine of up to 200,000 yen (same Act, Article 66) |
Even without a criminal fine, having the company name published for not following a recommendation is a practical burden. In addition, the fact that the publication duty is met is itself seen as the company's stance in the recruitment scene. As a company working on the balance of childcare and work, there is value in publishing correctly, also for the sake of preparing the ground for things like Kurumin certification. The final application of when and which figures a given company should publish changes with the business year and the employment reality.
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What can 四葉社会保険労務士事務所 do?
What this office takes on is designing the labour to comply with publication of childcare-leave uptake.
- Organising the idea of the number of ordinarily-employed workers, and confirming whether the company is subject to the publication duty
- Preparing the childcare/family-care leave rules and a childcare-purpose leave scheme
- Designing the calculation method for the male childcare-leave uptake rate, and the content, timing and method of publication
- Building a mechanism to organise the uptake records that form the basis of publication
- Supporting related procedures such as the childcare-leave benefit, the reduced-hours childcare working benefit and the post-birth leave support benefit
We design the calculation and publication method together, but the final check of the figures and the act of publishing are done by the company. 四葉社会保険労務士事務所 accepts work as an independent business entity, and where another professional is needed, we introduce them under a contract you conclude directly. This office takes no referral fee.
Consultations are free of charge. Fees are set out in the fee schedule; see also our services and how a consultation proceeds.
Frequently asked questions
Q. From April 2025, who is subject to the childcare-leave uptake publication duty?
A. Companies with more than 300 ordinarily-employed workers. Originally companies over 1,000 were subject, but by the amended Child Care and Family Care Leave Act enacted in 2024 (Act No. 42 of 2024), from 1 April 2025 (Reiwa 7) the scope widened to more than 300. The basis is Article 22-2 of the Act. Newly covered are companies with more than 300 and up to 1,000 employees; the duty of the over-1,000 companies that were already publishing does not change.
Q. Do you count part-timers among "ordinarily-employed workers"?
A. Yes. Regardless of employment form or title, in addition to persons employed without a fixed term, you count in part-timers etc. who have been continuously employed for 1 year or more, or are expected to be employed for 1 year or more from hiring. "More than 300" means 301 or more; exactly 300 is not included. When near the line, confirmation is needed including the employment reality, and the concrete application can differ depending on the reality.
Q. How do you calculate the uptake rate to publish?
A. You choose one of the male "childcare-leave uptake rate" (number of male workers who took childcare leave etc. ÷ number of male workers whose spouse gave birth) or the "uptake rate of childcare leave and childcare-purpose leave" (the sum of male workers who took childcare leave etc. and those who used a childcare-purpose leave scheme ÷ number of male workers whose spouse gave birth), and publish it together with the name of the indicator. A male worker who took leave several times for the same child is counted as one person.
Q. Is there a penalty if you do not publish?
A. No fine arises immediately. However, it becomes subject to a report demand, advice, guidance and recommendation by the Minister of Health, Labour and Welfare (the Prefectural Labour Bureau) (Child Care and Family Care Leave Act Article 56), and where the company does not follow the recommendation, the company name may be published (same Act, Article 56-2). Also, where a report is not made or a false report is made, it is subject to a non-penal fine of up to 200,000 yen (same Act, Article 66).
Basis for this article
- Act on Childcare Leave, Caregiver Leave, and Other Measures for the Welfare of Workers Caring for Children or Other Family Members (Act No. 76 of 1991) Article 22-2 — publication of the state of childcare-leave uptake; an employer whose number of ordinarily-employed workers exceeds a set figure is required to publish, once a year, the state of male employees' childcare-leave uptake
- Act No. 42 of 2024 amending the same Act — the scope of the publication duty widened from more than 1,000 ordinarily-employed workers to more than 300; enforced on 1 April 2025 (Reiwa 7) (the over-1,000 scope has applied since April 2023)
- The indicators to publish (① the childcare-leave uptake rate = male workers who took childcare leave etc. ÷ male workers whose spouse gave birth; ② the uptake rate of childcare leave and childcare-purpose leave), the timing (within roughly three months after the immediately preceding business year ends) and the method (use of the internet or another method the general public can view; "Ryoritsu Shien no Hiroba" etc.) — the leaflet of the Ministry of Health, Labour and Welfare and the Prefectural Labour Bureaus, "From April 2025, publication of male workers' childcare-leave uptake rate etc. is made mandatory also for companies with more than 300 and up to 1,000 employees" (accessed 18 September 2026)
- The idea of ordinarily-employed workers (in addition to persons employed without a fixed term, including part-timers etc. who have been continuously employed for 1 year or more, or are expected to be employed for 1 year or more from hiring) — the Ministry of Health, Labour and Welfare's materials on the Child Care and Family Care Leave Act (accessed 18 September 2026)
- Report demand, advice, guidance and recommendation (same Act, Article 56); publication where the recommendation is not followed (same Act, Article 56-2); a non-penal fine of up to 200,000 yen where a report is not made or a false report is made (same Act, Article 66)
- Whether a given company is subject to the publication duty, and when and which figures it should publish, turn in the final application on the business year and the employment reality. This article does not conclude on the individual case (unverified)
This article is general information. Individual determinations are made by a qualified professional after a consultation, in light of individual circumstances. 四葉社会保険労務士事務所 can advise on organising the idea of the number of ordinarily-employed workers, confirming whether the company is subject to the publication duty, preparing the childcare/family-care leave rules and a childcare-purpose leave scheme, designing the calculation method for the male childcare-leave uptake rate and the content, timing and method of publication, building a mechanism to organise the uptake records, and supporting related benefit procedures. The check of the figures and the act of publishing are done by the company. 四葉社会保険労務士事務所 accepts work as an independent business entity, and where another professional is needed, we introduce them under a contract you conclude directly. There is no referral fee. Frequently asked questions are collected in the FAQ. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).
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