Once you have 101 or more employees, must you file an action plan?

In short: When the number of workers you employ on an ongoing basis reaches 101 or more, both the Act on Promotion of Women's Active Engagement (Women's Active Engagement Act) and the Act on Advancement of Measures to Support Raising Next-Generation Children (Next-Generation Act) make it mandatory to formulate, file, publicise and disclose a general employer action plan (Women's Active Engagement Act, Article 8; Next-Generation Act, Article 12). Information disclosure under the Women's Active Engagement Act (Article 20) is also mandatory, and a 2025 amendment expanded the duty to disclose the male-female wage gap and the ratio of women in management to employers with 101 or more from 1 April 2026 (previously 301 or more). Employers with 100 or fewer are, in every case, under an obligation to make efforts. Obtaining Eruboshi or Kurumin certification is voluntary. This article sets out the contents of the two plans, what you concretely do when you pass 101, and the items and destinations of information disclosure.

"We're about to pass 100 employees, but is any filing required?" and "Do we formulate the action plan separately for women's active engagement and for childcare?" — these are questions we often hear from HR and general-affairs staff at small and medium-sized companies growing to around 100. This page organises where the duty to formulate, file and disclose a general employer action plan arises, and how the Women's Active Engagement Act and the Next-Generation Act differ. Setting individual targets and carrying out disclosure are done by the company, so this article focuses on the thinking behind the system.

What does a general employer action plan set out?

A general employer action plan is a plan in which a company sets a plan period, targets, measures to achieve them and the timing of implementation to put its employment environment in order. A plan of the same name exists in two laws with different bases.

Law	Purpose of the plan	Certification
Women's Active Engagement Act (Act No. 64 of 2015), Article 8	Putting in order an environment where women can be active (recruitment, continued employment, promotion, etc.)	Eruboshi / Platinum Eruboshi (voluntary)
Next-Generation Act (Act No. 120 of 2003), Article 12	Support for balancing work and childcare (childcare leave, exemption from work beyond prescribed hours, etc.)	Kurumin / Platinum Kurumin (voluntary)

For both, the flow is the same: first grasp your own situation and analyse issues, then create an action plan with numerical targets, publicise it internally and disclose it externally, and file it with the director of the prefectural labour bureau. Because the purpose and governing law differ, the two plans are basically formulated separately, though you can formulate and disclose them in an integrated form by adapting the format. Advancing them together with work rules and childcare/care systems is efficient. The 2025 amendment to the Child Care and Family Care Leave Act is set out in what changes under the 2025 amendment to the Child Care and Family Care Leave Act.

What becomes mandatory with 101 or more employees?

The dividing point is 101 or more workers employed on an ongoing basis. The scope of the duty changes as follows.

Ongoing workers	Women's Active Engagement Act	Next-Generation Act
101 or more	Formulate, file, publicise and disclose the action plan + information disclosure (mandatory)	Formulate, file, publicise and disclose the action plan (mandatory)
100 or fewer	Obligation to make efforts	Obligation to make efforts

"Workers employed on an ongoing basis" generally includes not only those employed without a fixed term but also fixed-term workers who have been continuously employed for at least a year (including where expected), so part-timers and casual workers who meet this are counted. Judging "we are under 100, so we are out of scope" by counting regular employees only therefore causes omissions. Once you formulate the action plan, you file it with the director of the prefectural labour bureau (Form No. 1, etc.) and publicise it to workers and disclose it externally. Disclosure is made on the "Database of Companies Promoting Women's Active Engagement," your own website, and the like. Note that the number differs from the duty to prepare and file work rules (10 or more workers at all times). See from how many workers must you prepare and file work rules.

How do the Women's Active Engagement Act and Next-Generation Act plans differ?

Even with the same "general employer action plan," what you put in differs.

• Women's Active Engagement Act plan: grasp and analyse the share of women among recruits, the share of women in management, the gap in average years of continued service between men and women, and the state of working hours, then set numerical targets to match the issues
• Next-Generation Act plan: set targets for balancing work and childcare — the childcare-leave take-up rate, reducing work beyond prescribed hours, promoting annual paid leave, and systems that make it easy for employees raising children to work

The Women's Active Engagement Act centres on "women's active engagement" and the Next-Generation Act on "childcare support (for both sexes)." The Next-Generation Act was originally time-limited to the end of March 2025, but has been extended by a 2024 amendment. On the expansion of the duty to disclose childcare-leave take-up, see how far has the duty to disclose childcare-leave take-up expanded; on balancing support and harassment prevention, see are anti-power-harassment measures mandatory for small and medium enterprises too.

Which items of information do you disclose, and where?

The scope required of information disclosure under the Women's Active Engagement Act changes by size. The following includes the expansion from 1 April 2026 under the 2025 amendment.

Ongoing workers	Scope of information disclosure
101 to 300	At least one item of choice from the prescribed items (existing). Plus, from 1 April 2026, the male-female wage gap and the ratio of women in management become mandatory
301 or more	At least one from each of the two prescribed categories + the male-female wage gap (mandatory from 8 July 2022). The ratio of women in management is also covered

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The point is that the duty to disclose the male-female wage gap was expanded to 101 or more from 1 April 2026 (previously 301 or more). The ratio of women in management was also newly made a disclosure duty for 101 or more. This follows the 2025 amendment to the Women's Active Engagement Act, with amended ordinances and guidelines. Disclosure is by a method a job-seeker can easily check, such as the "Database of Companies Promoting Women's Active Engagement" or your own website. Calculating and carrying out disclosure of the specific figures is done by the company; a Shakai Hoken Roumushi supports designing the situation-grasp and issue-analysis, preparing the action plan, filing, and reflecting it in work rules and regulations. For labour at establishments with staffing standards, such as care and disability welfare, see labour management for care and disability welfare.

Do companies with 100 or fewer have to do nothing?

For companies with 100 or fewer, the action plan and information disclosure under both Acts are an obligation to make efforts, not a duty with penalties. Still, keep the following in mind.

• Watch when you will cross the number. The duty arises the moment recruitment pushes you to 101 or more. So you don't scramble afterwards, start preparing once you are around 100
• There is value in taking it up even voluntarily. If you formulate and file an action plan and meet certain criteria, you can obtain Eruboshi or Kurumin certification (voluntary). Certification can be used in recruitment and publicity
• Neighbouring duties have different thresholds. Work rules apply from 10 or more, harassment-prevention measures apply to all employers, and so on — each law has a different threshold

Leaving it because it is only an effort obligation means you become subject to the duty unprepared the moment you pass 101. A company where the number moves through re-employment after retirement or renewal of fixed-term contracts should settle how it counts ongoing workers early. For the relationship with securing older workers' employment, see how do you advance re-employment after retirement and securing employment to 70. 四葉社会保険労務士事務所 supports designing the situation-grasp, the action plan, filing and information disclosure. Consultation is free. For fees, see the fee schedule; for FAQs, see the FAQ.

FAQ

Q. When we reach 101 or more employees, is filing an action plan always required?
A. Yes. When workers employed on an ongoing basis reach 101 or more, both Article 8 of the Women's Active Engagement Act and Article 12 of the Next-Generation Act make formulating, filing, publicising and disclosing a general employer action plan mandatory. With 100 or fewer, it is an obligation to make efforts.

Q. Do you count part-timers among "workers employed on an ongoing basis"?
A. Generally you include not only those employed without a fixed term but also fixed-term workers continuously employed for at least a year (including where expected). Part-timers and casual workers who meet this are counted, so judging by regular employees only causes omissions.

Q. Does a 101-employee company also disclose the male-female wage gap?
A. From 1 April 2026, the duty to disclose the male-female wage gap and the ratio of women in management was expanded to 101 or more ongoing workers (previously 301 or more). This follows the 2025 amendment to the Women's Active Engagement Act, and disclosure is on the Database of Companies Promoting Women's Active Engagement, your own website, and the like.

Q. Must we obtain Eruboshi or Kurumin certification?
A. No. Obtaining Eruboshi (Women's Active Engagement Act) or Kurumin (Next-Generation Act) certification is voluntary. It is separate from the duty to formulate, file and disclose the action plan; a company that meets certain criteria applies for and receives it. It can be used in recruitment and publicity.

Sources

• Act on Promotion of Women's Active Engagement in Professional Life (Act No. 64 of 2015), Article 8 (formulation of a general employer action plan; mandatory for employers with over 100 ongoing workers, an effort obligation for 100 or fewer), Article 20 (disclosure of information on women's active engagement in professional life)
• The Women's Active Engagement Act took effect on 1 April 2016. The scope of the duty to formulate, file and disclose was expanded to 101 or more ongoing workers on 1 April 2022 (previously 301 or more)
• Disclosure of the male-female wage gap became mandatory for 301 or more from 8 July 2022. Under the 2025 amendment to the Women's Active Engagement Act, from 1 April 2026 the duty to disclose the male-female wage gap and the ratio of women in management was expanded to 101 or more (with amended ordinances and guidelines). The same amendment also extended the law's period of validity
• Act on Advancement of Measures to Support Raising Next-Generation Children (Act No. 120 of 2003), Article 12 (general employer action plan; formulation and filing mandatory for employers with over 100 ongoing workers, an effort obligation for 100 or fewer). The Act was originally time-limited to the end of March 2025 and has been extended by a 2024 amendment
• Eruboshi / Platinum Eruboshi (Women's Active Engagement Act) and Kurumin / Platinum Kurumin (Next-Generation Act) certification is voluntary
• How "workers employed on an ongoing basis" are counted and the specific scope of disclosure items are confirmed from the Ministry of Health, Labour and Welfare's guides, ordinances and guidelines (as of September 2026). Setting individual target figures and carrying out disclosure are done by the company

This article does not decide the specific target figures. Designing the situation-grasp and issue-analysis, supporting the action plan, filing, reflecting it in work rules and regulations, and designing information disclosure are the work of a Shakai Hoken Roumushi. Calculating and carrying out disclosure of the specific figures are done by the company, and certification applications are voluntary.

This article is general information. A judgment on individual circumstances is made by a qualified professional after a consultation. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).