An employee is injured at work — what does the company do? The workers accident claim and the Report on Worker Casualties

Bottom line first: An injury at work sets two separate procedures in motion — the benefit claim (filed by the worker; the company certifies) and the Report on Worker Casualties (the employer's own duty). Since January 2025 the latter must in principle be made using the electronic data processing system.

Absence of four days or more is reported without delay; less than four days is reported quarterly. Failing to report is subject to a penalty (Industrial Safety and Health Act, Article 100, paragraph 1 and Article 120, item 5).

Health insurance cannot be used for the treatment, because Article 1 of the Health Insurance Act (健康保険法) covers injury and illness other than employment injury.

Whether a particular injury is an employment injury is decided by the head of the competent Labour Standards Inspection Office — not by the company, and not by this office. This article does not reach a conclusion on any individual case either.

Which documents does a company file when an injury happens?

Two things that are easily confused have entirely different natures.

	Report on Worker Casualties	Benefit claim form
Basis	Ordinance on Industrial Safety and Health, Article 97	Workers' Accident Compensation Insurance Act (労働者災害補償保険法), Article 12-8, paragraph 2 and others
Whose duty	The employer's duty to report	The worker's (or survivor's) claim; the company certifies
Filed with	The head of the competent Labour Standards Inspection Office	The same office (medical treatment benefits go via the designated medical institution)
If not filed	Penalty	Benefits do not start
Purpose	Grasping and preventing industrial accidents	Covering treatment costs and income during absence

Treating the two as one produces the mistake of thinking "we handed the claim form to the hospital, so the report is done". Filing a claim form is not filing the Report on Worker Casualties.

Benefits are provided "upon a claim" (Workers' Accident Compensation Insurance Act, Article 12-8, paragraph 2). The company does not claim on the worker's behalf; the injured worker claims, and the company assists. Article 23 of the Ordinance for Enforcement of that Act provides that where the person entitled cannot carry out the procedure themselves because of the accident, the employer must assist, and that where certification is requested the employer must certify promptly.

By when must the Report on Worker Casualties be filed?

It depends on the number of days of absence.

Days of absence	Deadline	Basis
Death, or absence of four days or more	Without delay	Ordinance on Industrial Safety and Health, Article 97, paragraph 1
Absence of less than four days	For each of January–March, April–June, July–September and October–December, by the end of the month following the last month of that period	Same Article, paragraph 2

So the quarterly deadlines fall on the last day of April, July, October and the following January. The fewer such cases a company has, the more easily the deadline is missed.

The report is not limited to "industrial accidents" in the narrow sense. The text covers death or absence caused by "an industrial accident or other injury, suffocation or acute poisoning occurring during work, or within the workplace or its attached buildings". Even where it is not clear whether an injury is an employment injury — a fall inside the premises during a break, for example — the wording of the provision is broad.

Since 2025, must the report be filed electronically?

As a rule, yes. Article 97, paragraph 1 of the Ordinance on Industrial Safety and Health provides that the employer must report the listed items to the head of the competent Labour Standards Inspection Office "without delay, using the electronic data processing system". The quarterly report under paragraph 2 is the same.

That "electronic data processing system" is the one prescribed in Article 6, paragraph 1 of the Act on the Advancement of Government Administration Utilising Information and Communications Technology (Act No. 151 of 2002) — see Article 2, paragraph 2 of the Ordinance.

The basis is the Ordinance Partially Amending the Ordinance for Enforcement of the Pneumoconiosis Act and Others (Ministry of Health, Labour and Welfare Ordinance No. 45 of 2024), promulgated on 18 March 2024 and in force from 1 January 2025. Electronic filing was made mandatory for eight procedures:

1. Report on Worker Casualties
2. Report on the appointment of the general safety and health manager, safety officer, health officer and industrial physician
3. Report on the results of periodic health examinations
4. Report on the results of dental health examinations for hazardous work
5. Report on the results of the check on the degree of psychological burden
6. Report on the results of health examinations for organic solvents
7. Report on the state of pneumoconiosis health management
8. Report on disasters within a dormitory attached to the business

Paper did not become unusable overnight. The circular (Kihatsu 0328 No. 15, 28 March 2024) states that, since some filers may not have the terminals or the environment for electronic filing, "for the time being, as a transitional measure, reporting in writing may be made". The Ministry likewise advises that written reporting remains possible for the time being where electronic filing is difficult because the filer does not have a computer terminal.

The name "Form 23" no longer exists in the current Ordinance. Forms 23 and 24 have been deleted, and the items to be reported are now listed directly in Article 97, paragraph 1: the labour insurance number; the type of business and the name, location and telephone number of the workplace; the number of workers ordinarily employed; the injured worker's name, date of birth and age, sex, occupation, length of experience in that occupation, and the name and site of the injury; the expected period of absence or the date and time of death; and the date, time, place, circumstances, sketch and cause of the accident. On the check-results report, see also Stress checks become mandatory for workplaces with fewer than 50 workers from April 2028.

What happens if the report is not filed?

There is a penalty. Article 100, paragraph 1 of the Industrial Safety and Health Act allows the Labour Standards Inspection Office and others to require reports on necessary matters, and Article 120, item 5 provides a fine of up to 500,000 yen for failing to report or making a false report.

This is what "concealing an industrial accident" amounts to. Reports are sometimes suppressed to avoid a premium increase or a report to the main contractor, but the duty to report exists under the safety and health legislation independently of the insurance benefits. "We paid the treatment costs ourselves, so no report is needed" does not work.

Where foreign nationals are employed, the reported items include the name of the nationality or region and the category of status of residence (Article 97, paragraph 1, item 10 of the Ordinance; holders of the diplomat or official statuses and special permanent residents are excluded). This is separate from the notification on hiring and separation, which is set out in Notify Hello Work when you hire a foreign national.

Can health insurance be used for the treatment costs?

It cannot. Article 1 of the Health Insurance Act (Act No. 70 of 1922) states the purpose as providing benefits "in respect of illness, injury or death, or childbirth, other than employment injury (meaning employment injury as prescribed in Article 7, paragraph 1, item 1 of the Workers' Accident Compensation Insurance Act), of a worker or the worker's dependant". Employment injury falls outside health insurance.

Where treatment is received at a designated medical institution, the claim form for medical treatment benefits (Form 5 for employment injury, Form 16-3 for commuting injury) is submitted to the head of the competent Labour Standards Inspection Office via that institution (Ordinance for Enforcement of the Workers' Accident Compensation Insurance Act, Article 12, paragraph 1). There is no payment at the counter.

Where treatment is received elsewhere and paid for personally, the claim is for the cost of medical treatment (Form 7 for employment injury, Form 16-5 for commuting injury) — Article 12-2 of the same Ordinance.

If a health insurance card was used at the counter, contact the medical institution and the health insurance society or other insurer promptly and confirm the switch-over procedure. How the switch is handled varies between insurers.

Who pays for the first three days of absence?

For an employment injury, the company does. Absence compensation benefits under the workers accident insurance are paid from the fourth day on which the worker is unable to work and receives no wages, at 60 per cent of the basic daily benefit amount (Workers' Accident Compensation Insurance Act, Article 14, paragraph 1). Nothing is paid from the insurance for the first three days.

For those three days, Article 76, paragraph 1 of the Labor Standards Act provides that "the employer shall provide absence compensation at 60 per cent of average wages during the worker's medical treatment". Article 84, paragraph 1 relieves the employer of the compensation duty where corresponding benefits are to be provided under the workers accident insurance, but that relief does not operate for the three waiting days, when no benefit is provided.

For a commuting injury, this three-day compensation is not required. Articles 75 and 76 of the Labor Standards Act apply to injury or illness "in the course of employment". A commuting injury is covered by Article 7, paragraph 1, item 3 of the Workers' Accident Compensation Insurance Act but is not within the accident compensation provisions of the Labor Standards Act.

Average wages are the total wages paid in the three months before the day on which the cause arose, divided by the total number of days in that period (Labor Standards Act, Article 12, paragraph 1), with a minimum guarantee for daily, hourly and piece rates (item 1 of the same paragraph). Payroll practice therefore needs the formula ready in advance. On running payroll itself, see What does it cost to have a Shakai Hoken Roumushi run payroll.

What does the employer certification column certify?

It is not a column in which the company certifies "this is an employment injury". What is certified is the facts.

On the claim form for medical treatment benefits, the employer certifies the date of the injury or onset and the cause and circumstances of the accident (Ordinance for Enforcement of the Workers' Accident Compensation Insurance Act, Article 12, paragraph 2). On the absence compensation claim form, average wages, the period of absence and whether the worker was insured under employees' pension insurance and the like are added (Article 13, paragraph 2).

Whether the case is an employment injury is decided by the head of the competent Labour Standards Inspection Office. Even where the company believes the injury is unrelated to its work, certifying what factually happened and the determination are different things. Where the facts are disputed, the form can be submitted with a note to that effect. Where worker status itself is in question, see The line between subcontracting and employment is not set by the contract.

Is an injury on the commute treated the same way?

The names of the benefits and the treatment of the three waiting days change.

Commuting means a worker's travel, in connection with employment, between residence and place of work and the like, by a reasonable route and method, excluding travel of a business nature (Article 7, paragraph 2). Where the worker deviates from or interrupts that travel, that period and the travel thereafter are not commuting. However, where the deviation or interruption is a minimal one for an act necessary in daily life prescribed by Ministry ordinance, carried out for unavoidable reasons, the travel other than during the deviation or interruption remains commuting (paragraph 3).

The benefit names drop the word "compensation": they become medical treatment benefits and absence benefits, and the claim form numbers differ.

What if a third party, such as a road accident, is involved?

A separate notification is required. Where the accident giving rise to the benefit was caused by the act of a third party, the person entitled to the benefit must notify the head of the competent Labour Standards Inspection Office without delay of the fact, the third party's name and address (or that they are unknown) and the state of the damage (Ordinance for Enforcement of the Workers' Accident Compensation Insurance Act, Article 22).

A settlement with the other party affects the insurance benefits. In practice the content and timing of a settlement are confirmed with the Labour Standards Inspection Office before the notification. The damages negotiation itself belongs to a lawyer and is not handled here.

Until when can a claim be made?

It depends on the benefit. Article 42 of the Workers' Accident Compensation Insurance Act provides that the right to medical treatment benefits, absence compensation benefits, funeral expenses, nursing care benefits and secondary health examination benefits is extinguished by prescription two years after it may be exercised, and the right to disability compensation benefits and survivors' compensation benefits five years after.

Because the right to absence compensation benefits is understood to arise for each day of absence, claims are filed in blocks such as monthly. Leaving everything to a single later filing means the oldest parts fall away first.

Article 19, paragraph 1 of the Labor Standards Act prohibits dismissal during a period of absence for medical treatment for an injury or illness in the course of employment, and for 30 days thereafter (except where compensation for discontinuance is paid and in the other cases in the proviso). Where absence becomes long, employment questions are considered against that restriction. This office does not judge whether a particular dismissal is permissible; we refer you to a lawyer. On absence for a non-occupational illness, see When an employee takes leave for mental health reasons.

What can 四葉社会保険労務士事務所 do?

What this office takes on is the paperwork and the internal sequence that keeps a company from freezing when an injury happens.

• Preparing the Report on Worker Casualties and filing it, including electronically
• Organising the content of the employer certification column on benefit claim forms, and supporting their submission
• Identifying when a third-party accident notification is required
• Organising the calculation of average wages and the compensation for the three waiting days
• Designing the internal flow (who goes to the hospital, who records what, who reports and when)
• Organising the response to a Labour Standards Inspection Office investigation

The Industrial Safety and Health Act is listed in item 20-6 of Appended Table 1 of the Certified Social Insurance and Labour Consultant Act (社会保険労務士法), the Workers' Accident Compensation Insurance Act in item 2 and the Labor Standards Act in item 1. Preparing applications and notifications under them falls under Article 2, paragraph 1, item 1, acting on the filing procedure under item 1-2, and advice and guidance under item 3.

The following are not handled here.

• Determining whether a case is an employment or commuting injury → that is for the head of the competent Labour Standards Inspection Office
• Damages negotiation, settlement and litigation → we refer you to a lawyer (Bengoshi)
• Medical judgments and the assessment of residual disability → these belong to physicians
• Tax treatment of condolence or damages payments → we connect you with a tax accountant (Zeirishi)
• Registration procedures → we connect you with a judicial scrivener (Shiho Shoshi)
• Preparing licence and permit applications → 四葉行政書士事務所 accepts this as a separate business entity
• Leases of premises or company housing → 四葉不動産株式会社 accepts this as a separate business entity

On injuries to the company president, see There is no workers accident cover for the president; on injuries while working abroad, see Overseas business trips and overseas assignments are entirely different.

四葉不動産株式会社, 四葉行政書士事務所 and 四葉社会保険労務士事務所 each accept work as an independent business entity, under a separate contract. Where another professional is introduced, you contract with them directly, and this office receives 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. The injured worker went home that day and came in as usual the next day. Is a report needed?
A. If there was no absence, it is not covered by Article 97 of the Ordinance on Industrial Safety and Health, which makes death or absence the trigger. But if even one scheduled working day was taken off for a hospital visit, it becomes a report of absence of less than four days, due by the end of the month following the last month of that quarter. Medical treatment benefits can be claimed even where there is no absence at all.

Q. We have no environment for electronic filing. Is filing on paper a breach?
A. The circular (Kihatsu 0328 No. 15) states that where the filer does not have the terminals or the environment for electronic filing, reporting in writing may be made for the time being as a transitional measure, and the Ministry advises the same. What does not change is that this is a transitional measure "for the time being" and that electronic filing is the rule. Confirming the handling with the competent Labour Standards Inspection Office in advance is the safe course.

Q. Can a Shakai Hoken Roumushi file the Report on Worker Casualties for us?
A. Yes. The Industrial Safety and Health Act is listed in item 20-6 of Appended Table 1 of the Certified Social Insurance and Labour Consultant Act; preparing the report falls under Article 2, paragraph 1, item 1 and acting on the filing procedure under item 1-2. Where a Shakai Hoken Roumushi files electronically on a client's behalf, the Labour Bureau requires a document evidencing the filing agency contract and a copy of the certificate to be attached. Follow the guidance of the relevant Prefectural Labour Bureau.

Q. Will using the workers accident insurance raise our premiums?
A. It is not uniform, because it depends on the size and type of the business. Labour insurance premiums are collected under the Act on Collection of Insurance Premiums of Labour Insurance, and for businesses above a certain size the merit system moves the workers accident insurance rate according to the balance ratio. Commuting injuries are in principle excluded from that balance ratio. Whether a particular company is covered, and how the figures actually move, is an individual calculation, and this article does not reach a conclusion on it. In any event, the effect on premiums is not a reason to escape the duty to report.

Basis for this article

• Ordinance on Industrial Safety and Health (労働安全衛生規則, Ministry of Labour Ordinance No. 32 of 1972) Article 97, paragraph 1 — the employer must report "without delay, using the electronic data processing system" the items in items 1 to 12, including item 10 (nationality or region and category of status of residence where the worker is a foreign national, excluding the diplomat and official statuses and special permanent residents)
• Same Ordinance, Article 97, paragraph 2 — where absence is less than four days, report for each of January–March, April–June, July–September and October–December by the end of the month following the last month of that period, using the electronic data processing system
• Same Ordinance, Article 2, paragraph 2 — "electronic data processing system" as prescribed in Article 6, paragraph 1 of the Act on the Advancement of Government Administration Utilising Information and Communications Technology (Act No. 151 of 2002)
• Same Ordinance, Forms 23 and 24 — deleted (current text confirmed on e-Gov on 22 August 2026)
• Ordinance Partially Amending the Ordinance for Enforcement of the Pneumoconiosis Act and Others (Ministry of Health, Labour and Welfare Ordinance No. 45 of 2024) — promulgated 18 March 2024, in force 1 January 2025
• Kihatsu 0328 No. 15 (28 March 2024, Director-General of the Labour Standards Bureau) — the eight procedures made subject to mandatory electronic filing; "for the time being, as a transitional measure, reporting in writing may be made"; the reported items for absence of less than four days are the same as for four days or more
• Ministry of Health, Labour and Welfare, "The reported items of the Report on Worker Casualties have been amended and electronic filing has been made mandatory (in force 1 January 2025)" — written reporting remains possible for the time being where electronic filing is difficult
• Industrial Safety and Health Act (労働安全衛生法, Act No. 57 of 1972) Article 100, paragraph 1 and Article 120, item 5 — a fine of up to 500,000 yen for failing to report, making a false report, or failing to appear
• Workers' Accident Compensation Insurance Act (労働者災害補償保険法, Act No. 50 of 1947) Article 7, paragraphs 1 to 3; Article 12-8, paragraphs 1 and 2; Article 14, paragraph 1; Article 42 — the categories of benefit, "upon a claim", payment from the fourth day at 60 per cent of the basic daily benefit amount, and prescription of two years and five years
• Ordinance for Enforcement of the Workers' Accident Compensation Insurance Act (労働者災害補償保険法施行規則, Ministry of Labour Ordinance No. 22 of 1955) Articles 12, 12-2, 13, 22 and 23 — the claim via the designated medical institution and the employer certification, the claim for the cost of medical treatment, the absence compensation claim, the third-party accident notification, and the employer's duty to assist and to certify "promptly"
• Health Insurance Act (健康保険法, Act No. 70 of 1922) Article 1 — benefits in respect of illness, injury, death or childbirth other than employment injury
• Labor Standards Act (労働基準法, Act No. 49 of 1947) Article 12, paragraph 1; Article 19, paragraph 1; Articles 75 and 76, paragraph 1; Article 84, paragraph 1 — average wages, the restriction on dismissal, medical treatment compensation and absence compensation at 60 per cent of average wages, and relief from the compensation duty where corresponding benefits are provided
• Ministry of Health, Labour and Welfare, "Main forms for workers accident insurance benefits" — Form 5, Form 7, Form 8, Form 16-3, Form 16-5 and Form 16-6
• Certified Social Insurance and Labour Consultant Act (社会保険労務士法, Act No. 89 of 1968) Article 2, paragraph 1, items 1, 1-2 and 3, and items 1, 2 and 20-6 of Appended Table 1
• Statutory texts were confirmed on 22 August 2026 from the e-Gov law data API (law IDs 347M50002000032, 347AC0000000057, 322AC0000000050, 330M50002000022, 211AC0000000070, 322AC0000000049 and 343AC1000000089). Public materials were confirmed the same day
• Whether the merit system applies depends on the size and type of the business. The specific calculation for a particular company is not covered here (unverified)

This article does not determine whether any particular case qualifies. 四葉社会保険労務士事務所 can advise on preparing and filing the Report on Worker Casualties including electronically, organising the employer certification column on benefit claim forms and supporting their submission, identifying when a third-party accident notification is required, organising the calculation of average wages and the compensation for the three waiting days, designing the internal flow after an injury, and organising the response to a Labour Standards Inspection Office investigation. Whether a case is an employment or commuting injury is decided by the head of the competent Labour Standards Inspection Office. Damages negotiation, settlement and litigation are not handled by this office; we refer you to a lawyer (Bengoshi). Medical judgments belong to physicians. Tax treatment of condolence or damages payments is a matter we connect you with a tax accountant (Zeirishi) for, and registration with a judicial scrivener (Shiho Shoshi). Licence and permit applications are accepted by 四葉行政書士事務所, and leases of premises or company housing by 四葉不動産株式会社, each as a separate business entity. If a different professional is needed, each is contracted separately, and there is no referral fee. Frequently asked questions are collected in the FAQ.

This article is general information. Individual determinations are made by a qualified professional after a consultation, in light of individual circumstances. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).