The 2024 overtime cap for hospital and clinic doctors — how do you comply?

Bottom line first: From 1 April 2024 (Reiwa 6), a cap on overtime and holiday work applies to doctors employed at hospitals and clinics. The rule is, in principle, 960 hours a year and under 100 hours a month (Level A); a medical institution with regional-medicine circumstances can be designated by the prefectural governor and allowed up to 1,860 hours a year (Levels Coordinated-B, B and C). In exchange for relaxing the cap, face-to-face guidance and a work-interval become mandatory health-securing measures.

Managing doctors' overtime, the Article 36 agreement and work rules is a Shakai Hoken Roumushi's work. The place to apply for an on-call (yado-nikko) permit is the Labour Standards Inspection Office, and this office supports the application. The opening permit and facility-standard applications for a medical institution are a Gyoseishoshi's work; 四葉行政書士事務所 accepts these as an independent business entity, under a separate contract. Individual determinations are made by a qualified professional after a consultation.

From 2024, how many hours is the overtime cap for doctors?

Ordinary workers have been under the overtime cap since 2019, but doctors were given a five-year grace period, and the application began on 1 April 2024 (Reiwa 6). The basis is Article 141 of the Labor Standards Act (a special provision for doctors engaged in medical practice), and the specific cap hours are set by ministerial ordinance and notice under that Article.

Level	Annual cap	Monthly cap	Main target
Level A	960 hours	under 100 hours (in principle)	the principle for all doctors
Coordinated-B	1,860 hours (aggregate)	under 100 hours (in principle)	doctors who become long-hours when work at multiple institutions is aggregated
Level B	1,860 hours	under 100 hours (in principle)	work necessary to secure regional medicine
Level C	1,860 hours	under 100 hours (in principle)	training of residents and specialty trainees; developing advanced skills

The under-100-hours-a-month cap is treated as not applying where the face-to-face guidance described below is carried out. Making doctors work beyond the cap can be a violation of the Labor Standards Act, subject to penalty. Without a concluded and filed Article 36 agreement and a grasp of working hours, cap management is impossible in the first place. The idea of the Article 36 agreement is set out in The Article 36 agreement and overtime — how far does a Shakai Hoken Roumushi look.

How do you choose among Levels A, Coordinated-B, B and C?

A medical institution cannot freely name its own level. Level A is the principle and needs no designation. Where it is necessary to have a doctor work overtime/holiday beyond 960 hours a year, the institution receives a prefectural governor's designation to become a Coordinated-B, B or C institution.

Level	Type of designated institution	When to choose it
Level A	no designation (the principle)	can be run within 960 hours a year
Coordinated-B	coordinated specified regional-medicine provider	has doctors dispatched from a university hospital, etc., who become long-hours when work across institutions is aggregated
Level B	specified regional-medicine provider	has work indispensable to regional medicine, such as emergency, home-care and disaster medicine
Level C-1	intensive skill-improvement training institution	residents and specialty trainees intensively experience cases under a training programme
Level C-2	specified advanced-skill training institution	plans to have advanced skills acquired

To be designated, the institution must take set steps such as drawing up a working-hours-reduction plan and receiving an evaluation from the Medical Institution Work Environment Evaluation Center. Coordinated-B and B are aimed to end by the end of FY2035, and Level C is also directed toward reduction; they are provisional special measures. The final judgment on which level a given doctor falls under rests with the designating authority and the institution's structure.

What decides the line between 960 and 1,860 hours a year?

The line is decided by "whether that doctor's work falls under the designated work". Even at the same hospital, a doctor engaged in Level-B designated work is capped at 1,860 hours a year, while other doctors are at Level A's 960 hours — the cap changes doctor by doctor.

Coordinated-B has a distinctive idea. At each dispatch-destination institution the Article 36 agreement cap is kept within 960 hours a year, while the aggregate working hours across multiple institutions are allowed up to 1,860 hours a year. Because looking only at one's own hospital cannot reveal that the aggregate cap is exceeded, an arrangement is needed for the dispatching and receiving sides to grasp each other's working hours.

Issue	What to confirm
Cap per doctor	organise, doctor by doctor, which work falls under which level's designation
Aggregation (Coordinated-B)	grasp the hours of side jobs, concurrent work and dispatch destinations by the person's declaration, etc.
Grasping working hours	record start and end objectively (including separating self-development)
Premium wages	correctly calculate the premiums for overtime, late-night and holiday work (Labor Standards Act Article 37)

Whether self-development counts as working time is an issue that turns on things such as whether there was a superior's instruction, and this article does not conclude on the individual case.

How far are face-to-face guidance and the work-interval mandatory?

In exchange for relaxing the cap, health-securing measures under the Medical Care Act come as a set. The core is face-to-face guidance and the work-interval.

Face-to-face guidance is given, before it reaches 100 hours, to a doctor for whom overtime/holiday work of 100 hours or more a month is expected, and is imposed on the institution's manager by Article 108 of the Medical Care Act. This is a common duty of all medical institutions, including Level-A ones.

The work-interval, the continuous-work-hours limit and compensatory rest are mandatory at specified labour-management institutions (those designated as Coordinated-B, B or C) and are best-effort duties at Level A.

Measure	Content	Level A	Coordinated-B, B, C
Face-to-face guidance	for a doctor expected to reach 100+ hours a month, carried out before reaching it	duty	duty
Continuous-work-hours limit	up to 28 hours from the start (except the morning after permitted on-call)	best effort	duty
Work-interval (ordinary day shift / on-call without permit)	9 continuous hours of rest within 24 hours from the start	best effort	duty
Work-interval (on-call with permit)	18 continuous hours of rest within 46 hours from the start	best effort	duty
Compensatory rest	where the interval etc. could not be secured, granted by the end of the following month	best effort	duty

Where the face-to-face guidance finds it necessary, work-related measures (such as suspension from duty) are taken. In a medical institution's labour, the core of practice is how to fit these health-securing measures into the work rules and the shift roster. The idea of shifts including night and on-call duty and working hours is also set out in Labour when opening a clinic — on-call duty and nurses' social insurance.

How do the on-call permit and the cap combine in operation? (sorting the referrals)

The on-call permit is an issue to consider together with the cap. Time under a Labour Standards Inspection Office's on-call permit is, in principle, not treated as working time and is not counted toward the cap hours. Conversely, without the permit, the on-call time becomes working time in full and quickly exceeds the cap. The standard for the on-call permit itself is set out in The permit standard for on-call duty in medicine and care. This article focuses not on the on-call permit but on the annual overtime cap (Levels A, B, C) and the health-securing measures.

The responsibilities split as follows.

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Issue	In charge
Article 36 agreement, work rules, shift roster, grasping working hours, design of premium wages	Shakai Hoken Roumushi (this office)
On-call permit application (filed with the Labour Standards Inspection Office)	Shakai Hoken Roumushi supports the application
Support for the working-hours-reduction plan needed for level designation	Shakai Hoken Roumushi
Opening permit / facility-standard and other applications under the Medical Care Act	Gyoseishoshi
Tax on medical-institution management	Tax accountant

The opening permit and facility-standard applications for a medical institution are a Gyoseishoshi's work; 四葉行政書士事務所 accepts them as an independent business entity, and where needed we introduce it under a separate contract that you conclude directly. This office takes no referral fee.

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 the doctors' overtime cap.

• Drawing up and filing the Article 36 agreement (including the special clause) and designing cap management by level
• Preparing work rules and wage rules, and building operating rules for face-to-face guidance, the work-interval and compensatory rest
• Designing the mechanism to grasp working hours (including separating self-development and on-call duty)
• Supporting the on-call permit application
• Designing the calculation of overtime, late-night and holiday premium wages

The following are not handled here.

• Opening permit / facility-standard and other applications under the Medical Care Act → 四葉行政書士事務所 accepts these as a separate business entity
• The final judgment on which level a doctor falls under, and the propriety of a designation → decided by the designating authority (the prefecture)
• Tax on medical-institution management → we connect you with a tax accountant

四葉社会保険労務士事務所 and 四葉行政書士事務所 each accept work as an independent business entity. Where another professional is needed, we introduce them under a contract you conclude directly, and 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 2024, how many hours can doctors work overtime?
A. The principle is 960 hours a year and under 100 hours a month, called Level A. Where there are circumstances such as work necessary to secure regional medicine or training, an institution designated by the prefectural governor may allow up to 1,860 hours a year as Coordinated-B, B or C. The basis is Article 141 of the Labor Standards Act and the ministerial ordinance and notice under it. Making doctors work beyond the cap can be a violation subject to penalty. Which level a given doctor falls under depends on the content of the work and the institution's designation.

Q. Can every hospital become a Level-B or Level-C institution?
A. No. Level A is the principle, and only an institution that needs to have a doctor work overtime/holiday beyond 960 hours a year receives a prefectural governor's designation as Coordinated-B, B or C, after steps such as drawing up a working-hours-reduction plan and receiving an evaluation from the Medical Institution Work Environment Evaluation Center. Coordinated-B and B are provisional special measures aimed to end by the end of FY2035, and Level C is directed toward reduction. The propriety of designation is judged by the designating authority.

Q. Are face-to-face guidance and the work-interval mandatory at any hospital?
A. Face-to-face guidance is a duty at all medical institutions including Level A, for a doctor for whom 100+ hours a month of overtime/holiday work is expected (Medical Care Act Article 108). Meanwhile, the 28-hour continuous-work-hours limit, the work-interval (for an ordinary day shift etc., 9 continuous hours of rest within 24 hours from the start; for on-call with a permit, 18 continuous hours of rest within 46 hours from the start) and compensatory rest are duties at Coordinated-B, B and C institutions and best-effort duties at Level A.

Q. With an on-call permit, what happens to the cap hours?
A. Time under a Labour Standards Inspection Office's on-call permit is, in principle, not treated as working time and is not counted toward the overtime cap hours. Conversely, without the permit, the on-call time becomes working time in full and the cap is easily exceeded. The on-call permit is filed with the Labour Standards Inspection Office, and this office supports the application. The details of the permit standard are set out in the on-call permit article.

Basis for this article

• Labor Standards Act (Act No. 49 of 1947) Article 141 — a special provision for the overtime/holiday work of doctors engaged in medical practice; the specific cap hours are set by ministerial ordinance and notice under that Article. Enforced on 1 April 2024 (Reiwa 6)
• Same Act, Article 37 — premium wages for overtime, holiday and late-night work
• The doctors' overtime/holiday caps (Level A = 960 hours a year; Coordinated-B, B, C = 1,860 hours a year, all under 100 hours a month in principle), the level categories and prefectural-governor designation (specified regional-medicine provider = B; coordinated specified regional-medicine provider = Coordinated-B; intensive skill-improvement training institution = C-1; specified advanced-skill training institution = C-2), and the aim to end Coordinated-B and B by the end of FY2035 with Level C directed toward reduction — the Ministry of Health, Labour and Welfare's materials and Q&A on the doctors' work-style reform (accessed 18 September 2026)
• Medical Care Act (Act No. 205 of 1948) Article 108 — face-to-face guidance; the institution's manager is required to carry it out, before it is reached, for a doctor for whom 100+ hours a month of overtime/holiday work is expected (common to all institutions including Level A)
• That the additional health-securing measures (28-hour continuous-work-hours limit; work-interval = for an ordinary day shift and on-call without a permit, 9 continuous hours of rest within 24 hours from the start; for on-call with a permit, 18 continuous hours of rest within 46 hours from the start; compensatory rest granted by the end of the following month) are duties at specified labour-management institutions (Coordinated-B, B, C) and best-effort duties at Level A — the Ministry's materials and administrative notices on the doctors' work-style reform (accessed 18 September 2026)
• The treatment, for working-time and cap purposes, of time under an on-call permit — the on-call permit standard (Kihatsu No. 17 of 1947, etc.) and the Ministry's Q&A on doctors' overtime (accessed 18 September 2026)
• Whether self-development counts as working time, which level a given doctor falls under, and the propriety of level designation turn on the circumstances of the case and the designating authority. This article does not conclude on them (unverified)
• The specific article numbers, among the Medical Care Act's additional health-securing measures, on securing rest time are set by the provisions, ordinance and guidelines following face-to-face guidance (Article 108 et seq.), and confirmation against the latest text and guidelines is assumed (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 drawing up and filing the Article 36 agreement (including the special clause), designing cap management by level, preparing work rules and wage rules, building operating rules for face-to-face guidance, the work-interval and compensatory rest, designing the mechanism to grasp working hours, supporting the on-call permit application, and designing premium-wage calculation. The opening permit / facility-standard and other applications under the Medical Care Act are accepted by 四葉行政書士事務所 as a separate business entity, each contracted separately. Tax on medical-institution management is a matter we connect you with a tax accountant for. If a different professional is needed, each is contracted separately, and 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).