What a job posting must state
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
At the recruiting stage there is already a duty to state the work, pay, hours and other conditions (Employment Security Act, Article 5-3) — separate from the disclosure at hiring under Article 15 of the Labor Standards Act. We list the required items, what happens when the posting and the real conditions diverge, and what was added from April 2024.
In short: at the stage of putting out a job posting, there is already a duty to state the work to be performed, the pay, the working hours and other working conditions (Employment Security Act, Article 5-3, paragraph 1). This is a separate duty from the disclosure at hiring (Labor Standards Act, Article 15). When the posting and the written conditions diverge, you will be asked to explain.
This page is for owners and back-office staff about to put out a job posting. Treating "disclosure at recruiting" and "disclosure at hiring" as one duty is what plants the seed of later disputes.
What differs between recruiting time and contract time?
The disclosure duty arises twice — at different moments, on different bases, to different counterparts.
| At recruiting | At hiring | |
|---|---|---|
| Basis | Employment Security Act, Article 5-3 | Labor Standards Act, Article 15 (items in Article 5 of its Ordinance) |
| Counterpart | Job seekers; those responding to the recruitment | The individual entering the contract |
| Scene | Job postings, adverts, offers to placement services | The written working conditions at offer/joining |
The two are continuous: what you stated at recruiting is the starting point of the contract terms, and any divergence requires a disclosure of the change. Seen this way, a job posting is not an advertisement — it is the document that precedes the contract.
What, exactly, goes on the posting?
The items are listed in Article 4-2, paragraph 3 of the Ordinance for Enforcement of the Employment Security Act — usable directly as a checklist.
| Required items |
|---|
| The work to be performed (including the scope of future changes) |
| The term of the labour contract |
| The trial period |
| For renewable fixed-term contracts, the renewal criteria (including any cap on total term or number of renewals) |
| The place of work (including the scope of future changes) |
| Start and finish times, whether work beyond scheduled hours exists, breaks, days off |
| The amount of wages (excluding ad-hoc payments and bonuses) |
| Coverage under health insurance, employees' pension, workers' compensation and employment insurance |
| The name of the recruiting employer |
| (Where hiring as a dispatched worker) that fact |
| Measures to prevent passive smoking at the place of work |
The four most commonly missed: the trial period, the existence of overtime, the insurance coverage, and the passive-smoking measures. None of them may be waved off with "details at the interview."
What if the posting and the real conditions diverge?
Where the conditions stated at recruiting are later made specific, deleted or added to, the change must itself be disclosed (Employment Security Act, Article 5-3, paragraph 3; Ordinance, Article 4-2, paragraphs 1 and 2). The idea that "the posting is only indicative" is blocked by the system itself.
In practice, the best seawall is to check the written working conditions against the posting at offer time. Where something has moved, show the person what changed and obtain their agreement. Skipping that one step is the classic entrance to the post-joining "this isn't what was advertised."
What was added from April 2024?
The amendment that took effect in April 2024 added "the scope of changes" to the required items — for the work to be performed and the place of work, you now state how far future reassignment can reach. Renewal caps on fixed-term contracts (where set) also became required items. These entered both sides: recruiting (Employment Security Act side) and hiring (Labor Standards Act side).
The renewal cap and the period of stay are treated in Which expires first — the period of stay or the employment contract?; the work-rules side in From how many workers are work rules mandatory?.
What can 四葉社会保険労務士事務所 do?
四葉社会保険労務士事務所, in Kohinata, Bunkyo City, takes on — as part of recruitment and hiring support — the design of the working conditions on the posting (checking against the disclosure duties), the reconciliation with the written working conditions, and the procedure for disclosing changes. Fees: the "recruitment and hiring consultant" item in the fee schedule (package, quoted). Consultation is free of charge. Bring your current posting and we start by checking it against the list.
Whom to consult
Candidate introduction and placement belong to licensed employment placement businesses (this office does not handle them, and no referral fees change hands). Residence-status applications go to 四葉行政書士事務所 (a separate business from this office, engaged under a separate contract); payroll taxation to a tax accountant; posting-related matters that have turned contentious to an attorney.
Frequently asked questions
Q. The job board's input fields are too small for everything.
A. Small fields do not shrink the duty. The rule is disclosure in writing or equivalent, by the time the person responds to the recruitment. A two-tier design — the board entry plus a detailed document — is one workable shape; the design of the disclosure itself is something we can take on.
Q. Is "salary negotiable based on experience" alone acceptable?
A. The amount of wages is a required item (Ordinance, Article 4-2, paragraph 3). Even stating a range, a presentation that diverges widely from the actual starting salary invites the change-disclosure problem and post-joining friction. Write the wage line backwards from the written working conditions.
Q. We forgot the trial period on the posting and have already hired.
A. Introducing a trial period for the first time at contract time can amount to adding a condition absent at recruiting. How to explain and obtain agreement depends on the situation — consult us early.
Q. Can we ask you to check the posting only?
A. Yes. Within the recruitment and hiring consulting package we check the posting against the required-items list and propose corrections. Consultation is free.
Sources for this article
- Employment Security Act (職業安定法, Act No. 141 of 1947), Article 5-3, paragraphs 1 to 3 (disclosure of working conditions; disclosure of changes) — current text confirmed on e-Gov on 14 August 2026
- Ordinance for Enforcement of the Employment Security Act (職業安定法施行規則, Ministry of Labour Order No. 12 of 1947), Article 4-2, paragraphs 1 to 3 (cases of change disclosure; the item list — scope of changes for work and place, trial period, renewal criteria and caps, existence of overtime, insurance coverage, passive-smoking measures, etc.) — confirmed the same day
- Labor Standards Act (労働基準法, Act No. 49 of 1947), Article 15, and Article 5 of its Ordinance (disclosure at hiring; scope of changes and renewal caps added by the amendment effective April 2024) — confirmed the same day
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).
Let’s start by sorting out where things stand.
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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