How did the working-conditions notice rules change? The scope of changes to workplace and duties, and the renewal cap for fixed-term contracts

In short: From April 2024, the rules for stating working conditions changed. For all workers, you must state "the scope of changes to the place of work and duties"; for fixed-term workers, you must additionally state the "renewal cap," the "opportunity to apply for conversion to open-ended employment," and the "working conditions after conversion." It is not enough to swap out the template of the working-conditions notice — the essence is to put it in order so that it matches the reality.

What was added to the statement of working conditions from April 2024?

When concluding a labour contract, an employer must state the wages, working hours and other working conditions (Labour Standards Act, Article 15, paragraph 1). Article 5 of the Ordinance for Enforcement of the Labour Standards Act, which prescribes these matters, was amended (Ministry of Health, Labour and Welfare Ordinance No. 39 of 2023, promulgated on 30 March 2023), and from 1 April 2024 the matters to be stated were added to.

Four items were added. Who must be told, and when, differs by item.

Added matter to be stated	Covered	Timing of statement
The scope of changes to the place of work and duties	All workers	At conclusion of the labour contract / at renewal of a fixed-term contract
The presence and content of a renewal cap (a cap on the total contract period or the number of renewals)	Fixed-term workers	At conclusion / at renewal of a fixed-term contract
The fact that conversion to open-ended employment may be applied for (the conversion application opportunity)	Fixed-term workers	Each time a renewal at which the conversion application right arises occurs
Working conditions after conversion to open-ended employment	Fixed-term workers	Same as above

The first item above covers all workers, including regular employees; the remaining three cover only fixed-term workers. Confusing this line leads to writing about open-ended conversion in a regular employee's notice, or, conversely, omitting the renewal cap in a part-timer's notice.

How far must "the scope of changes to the place of work and duties" be written?

What was stated previously was the place of work and duties "immediately after hiring." From April 2024, in addition, you state "the scope of changes" — that is, the range within which the place of work and duties may change, through reassignment and the like, during the term of that labour contract.

The point is to write "immediately after hiring" and "the scope of changes" separately. Because it shows the range including future possibilities, there is latitude in how it is written depending on the company's operation.

• If nationwide transfers are possible, indicate a range that makes this clear
• If transfers or changes of job type are not envisaged, write it so that it is clear the range stays within those bounds

Writing a broad range divorced from the reality here sows the seeds of a discrepancy later at the reassignment stage — "I never heard of such a range." Conversely, writing it too narrowly makes necessary transfers difficult. The point is to align the provisions on reassignment in the work rules with the statement in the notice; the duty to draw up and file work rules itself is organised in from how many employees are work rules mandatory, and what is not mandatory. This article does not go into individual judgments such as whether a particular transfer is valid.

When and how must the renewal cap for a fixed-term contract be shown?

For fixed-term workers, you state the presence and content of a renewal cap (a cap on the total contract period or the number of renewals) at the conclusion and at the renewal of the contract. If there is a cap such as "renewals up to a total of three years" or "renewals up to four times," you show it.

Alongside this, an effort duty to explain is provided by administrative notice. Where you newly set a renewal cap, or shorten a cap, after the initial contract, you are to endeavour to explain the reason to the worker in advance.

Setting a renewal cap is not itself unlawful, but whether a non-renewal (refusal to renew) when the cap is reached is valid is a separate judgment. This is an area prone to disputes, and we do not handle individual determinations of whether it is permissible. The design of the contract type at the entry point is also covered in if you are aiming for a subsidy, it is decided by the first contract type.

What are the conversion application opportunity and the statement of post-conversion working conditions?

When a fixed-term labour contract is repeatedly renewed and exceeds a total of five years, the worker can, by application, convert to an open-ended labour contract (Labour Contract Act, Article 18 — this is the open-ended conversion rule).

From April 2024, each time a renewal at which this conversion application right arises occurs, you state the following two.

1. The fact that conversion to open-ended employment may be applied for (the conversion application opportunity)
2. The working conditions after conversion to open-ended employment

In other words, you show both the notice that "if you apply, you can become open-ended," and "what the working conditions will be if you become open-ended," each time a renewal at which the right arises occurs. When determining the post-conversion working conditions, you are also required by administrative notice to endeavour to explain the matters considered for balance with other workers, such as regular employees.

Open-ended conversion is not the same as "becoming a regular employee." Only the contract term changes from fixed to open-ended; the working conditions may remain the same as before conversion. Confusing this leads to inconsistent explanations within the company. The relationship between fixed-term/open-ended status and treatment is also organised in how do the rules for part-time and fixed-term employment change in October 2026?.

Where should the notice and the employment contract be fixed?

First, replace the template of the working-conditions notice with the latest one. The Ministry of Health, Labour and Welfare has published a model form, with fields reflecting the added matters to be stated. Statement is in principle by delivery of a written document; where the worker so wishes, methods such as facsimile or e-mail may also be used.

On top of that, fixing only the notice does not make the practice work. Cross-check the following.

• Working-conditions notice: whether the four added matters are complete and the form is up to date
• Employment contract: whether it contradicts the notice
• Work rules and wage regulations: whether the provisions on reassignment, renewal and open-ended conversion match the reality

The statement shown at the recruitment stage in a job advertisement (Employment Security Act) is a separate duty from the statement at hiring (Labour Standards Act). Their relationship is organised in what must be written in a job advertisement. If you are reviewing the method of wage payment, checking the notice and the regulations together at the same opportunity as introducing digital wage payment avoids duplicated work.

Frequently asked questions

Q. If I renew the template of the working-conditions notice, is the response then complete?
A. Replacing the template is the starting point, and that alone does not complete it. The added "scope of changes to the place of work and duties" and the "renewal cap" for fixed-term contracts must be consistent with the reassignment and renewal provisions of the work rules and with actual practice. The essence is to cross-check that the notice, the employment contract and the work rules do not diverge.

Q. For "the scope of changes," is it enough to write every conceivable reassignment broadly?
A. Writing a broad range divorced from the reality sows the seeds of a discrepancy later at the reassignment stage — "I never heard of such a range." Conversely, writing it too narrowly makes necessary transfers difficult. The point is to show a range in line with the company's operation and the provisions of the work rules. Individual judgments on whether a particular transfer is valid are beyond the scope of this article.

Q. If I newly set a renewal cap, is it unlawful?
A. Setting a renewal cap is not itself immediately unlawful. However, where you newly set, or shorten, a renewal cap after the initial contract, you are to endeavour to explain the reason in advance. Also, whether a non-renewal when the cap is reached is valid is a separate judgment, and for matters with a dispute nature we point you to a consultation with a lawyer.

Q. If a part-timer converts to open-ended, do they become a regular employee?
A. Open-ended conversion only changes the contract term from fixed to open-ended; it is not the same as becoming a regular employee. The working conditions may remain the same as before conversion. From April 2024, however, each time a renewal at which the conversion application right arises occurs, you must state the fact that an application may be made and the post-conversion working conditions.

Sources

• Labour Standards Act (Act No. 49 of 1947), Article 15, paragraph 1 — an employer must, on concluding a labour contract, state to the worker the wages, working hours and other working conditions
• Ordinance for Enforcement of the Labour Standards Act (Ministry of Health and Welfare Ordinance No. 23 of 1947), Article 5 — the provision prescribing the working conditions to be stated. By amendment, the scope of changes to the place of work and duties, the cap on the total contract period or the number of renewals of a fixed-term contract, the conversion application opportunity, and the working conditions after conversion were added to the matters to be stated
• Ordinance Partially Amending the Ordinance for Enforcement of the Labour Standards Act and others (Ministry of Health, Labour and Welfare Ordinance No. 39 of 2023, promulgated on 30 March 2023) — adds, to the working conditions to be stated under the first sentence of Article 15, paragraph 1 of the Labour Standards Act, the cap on the total contract period or the number of renewals of a fixed-term contract, and the scope of changes to the place of work and duties. In force from 1 April 2024
• Labour Contract Act (Act No. 128 of 2007), Article 18 — where a fixed-term labour contract with the same employer is repeatedly renewed and exceeds a total of five years, it converts to an open-ended labour contract on the worker's application (the open-ended conversion rule)
• Ministry of Health, Labour and Welfare, "Change to the working-conditions notice rules from April 2024" — (1) state "the scope of changes to the place of work and duties" to all workers at conclusion of the labour contract and at renewal of a fixed-term contract; (2) state the "renewal cap" to fixed-term workers at conclusion and renewal; (3) state the "conversion application opportunity" and the "working conditions after conversion" each time a renewal at which the conversion application right arises occurs. In addition, explaining the reason for newly setting or shortening a renewal cap, and explaining the matters considered for balance with other workers when determining the post-conversion working conditions, are made effort duties. Statement is in principle by delivery of a written document; where the worker so wishes, methods such as facsimile or e-mail are also permitted (confirmed on 30 August 2026)
• The validity of a particular transfer or a non-renewal, and other individual determinations of applicability, are not handled in this article. They vary with the circumstances; this article is limited to introducing the framework of the system

This article is general information. Individual judgments, in light of the latest primary sources (Ministry of Health, Labour and Welfare, e-Gov, etc.), are made by a qualified professional after a consultation. What 四葉社会保険労務士事務所 supports on the statement of working conditions is revising the templates of the working-conditions notice and the employment contract, and checking their consistency with the work rules and wage regulations. Individual disputes and litigation are pointed to the domain of a lawyer. For fees, see the fee schedule; for frequently asked questions, see the FAQ. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).