How to set up labor at a judo-therapy clinic — a judo therapist's working hours and how to think about opening hours

In short: The starting point for labor at a judo-therapy (seikotsuin/sekkotsuin) clinic is to separate "reception hours (opening hours)" from an employee's "working hours." Even when no patient has come, waiting time in which staff must respond if a patient arrives counts as working hours. Social insurance for judo therapists and reception staff is compulsory with even one person at a corporation; for a sole proprietorship it turns on the industry classification. The opening notification is handled separately from labor.

A judo-therapy clinic typically centers on an opener who is a judo therapist, with employed judo therapists and reception/assistant staff. Because opening hours often run from morning to night with a midday break, treating "the time we are open = working hours" misses how breaks and waiting time are treated, leading to later unpaid overtime and insufficient breaks. Pin down how hours are counted and the social-insurance foundation first.

How do a judo-therapy clinic's "reception hours" differ from an employee's "working hours"?

Reception hours (opening hours) are the posted time band for receiving patients, and are a separate thing from an employee's working hours. Working hours are the time a worker is under the employer's command and control; even time not actually spent treating counts as working hours if the worker must respond immediately on the employer's instruction (on the meaning of working hours, Supreme Court judgment of 9 March 2000).

Time	Meaning	Working hours?
Reception hours (opening hours)	The posted band for receiving patients	Not itself the definition of working hours
Actual work time	Time actually working, such as treatment or reception	Working hours
Waiting time	Time waiting for patients, with a duty to respond if one arrives	Working hours (under command and control)
Break time	Time freely usable, guaranteed release from work	Not working hours (Labor Standards Act, Article 34(3))

Working-hour management follows the Labor Standards Act's principles regardless of industry: in principle 8 hours a day and 40 hours a week (Article 32); breaks of 45 minutes for over 6 hours and 1 hour for over 8 hours (Article 34); an Article 36 agreement for overtime and holiday work (Article 36); and premium wages for overtime, late-night, and holiday work (Article 37). At clinics with long opening hours, a monthly-unit variable working-hours system (Article 32-2) can allocate scheduled hours to weekly peaks and troughs (see how to choose between the variable working-hours system and flextime).

Does time when no patient comes (waiting time) count as working hours?

Yes. This is where misunderstanding is common at judo-therapy clinics. Treating "the time with no patients" as a break actually turns waiting time into an unpaid break, becoming a problem of unpaid wages and insufficient breaks.

The dividing line between waiting time and break time is whether the worker is completely released from work during that time.

• Waiting time (working hours): Sitting at reception on standby, responding when a patient comes; answering the phone, tidying up, otherwise being ready for arrivals. During this the worker is under command and control — working hours.
• Break time (not working hours): The clinic is closed, staff can freely go out and rest, and are released from the duty to handle arrivals. This is time with the free use guaranteed by Article 34(3).

At a clinic that sets a midday "long break," if you require phone or arrival handling during it, that is waiting time = working hours and subject to wages. If you want it unpaid as a break, you must actually release staff from the duty to handle arrivals and let them spend it freely. Leaving waiting time unaddressed excludes untreated bands from attendance records and can even throw off late-night and overtime premium calculations. The longer the opening hours, the more important objective grasp of working hours is. Whether you can treat someone as a manager and not pay overtime has strict requirements — see nominal managers and late-night premiums.

From what point is social insurance required for judo therapists and reception staff?

For social insurance (health insurance and employees' pension), first confirm whether the clinic is a covered workplace. The judging framework is as follows.

Business form	Health insurance / employees' pension
Corporation (KK, general incorporated association, etc.)	Compulsory even with the opener alone
Sole-proprietor clinic	Even with 5 or more regular staff, the treatment turns on whether the clinic is an applicable industry (see below)

If incorporated, coverage is compulsory regardless of headcount. Once the workplace is covered, whether part-time judo therapists and reception staff join is judged against regular employees: they join if both weekly scheduled hours and monthly scheduled workdays are three-quarters or more of a regular employee's, and at a specified covered workplace they become subject under conditions such as 20+ hours a week and a monthly wage of 88,000 yen or more. The size requirement expands in stages (51 or more insured persons, 36 or more from October 2027), and the 88,000-yen wage requirement is scheduled to be abolished in October 2026. Counting is in what happens to social insurance when you hire for short hours, and the timing in social-insurance coverage expansion to 36+ from October 2027. For employment insurance, someone with 20+ scheduled weekly hours (10+ from October 2028) and expected employment of 31 days or more is insured. Work rules must be drawn up and filed from 10 or more regular staff (Article 89; from how many people are work rules mandatory).

How do labor and social insurance differ between a sole proprietorship and a corporation?

The Labor Standards Act applies as is whether sole proprietorship or corporation, once even one worker is used. Working hours, breaks, premium wages, and stating working conditions (Article 15) apply regardless of business form. The difference appears at the entry point of compulsory social-insurance coverage.

Business form	Compulsory social-insurance (health/pension) coverage
Corporation	Compulsory regardless of headcount (even with the opener alone)
Sole proprietorship	5 or more regular staff in principle; but whether the clinic falls within an applicable industry (the statutory 16 industries) is at issue

Note here that when a judo-therapy clinic is a sole proprietorship, it cannot be said that 5 or more regular staff necessarily makes it compulsorily covered. The applicable industries under the Health Insurance Act and Employees' Pension Insurance Act include "the treatment of disease, midwifery, and other medical business," but a judo therapist differs from a physician, and whether a clinic falls under "medical business" is not uniformly clear. Whether a sole-proprietor clinic is an applicable industry is a matter to confirm with the local pension office, and this article makes no definitive judgment. In practice, it is surest to confirm with the local pension office at opening, including options such as incorporating to make coverage compulsory, or being voluntarily covered (voluntary comprehensive coverage). For how other medical-sector industries are treated, compare labor at a medical clinic, labor at a dental clinic and dental lab, and the service-industry side labor and social insurance when opening a beauty salon.

Have a question about your situation?

Tell us about your social insurance, payroll or employment enquiry.

Chat on LINEContact us

How do you run the opening notification and the labor preparation in parallel? (Notification to a Gyoseishoshi / public health center)

Opening a judo-therapy clinic splits by qualification, and each is a separate contract.

Task	Main responsibility
Work rules and shift design, social/labor-insurance tests and procedures, payroll	Shakai Hoken Roumushi (our office)
Support for the clinic opening notification (public health center)	Gyoseishoshi (or the opener)
Opening taxes and returns	Tax accountant
Brokerage and disclosure for the clinic premises	Real estate transaction agent

Under Article 19 of the Judo Therapists Act, a person who has opened a clinic must, within 10 days of opening, notify the prefectural governor (the mayor for cities/special wards with a public health center) of the location, the names of the judo therapists engaged in the work, and other matters. We can introduce you to 四葉行政書士事務所 for this opening notification and to 四葉不動産 for the premises, but 四葉行政書士事務所 and 四葉不動産 are independent entities separate from our office, and the Shakai Hoken Roumushi work, Gyoseishoshi work, and real estate work are contracted separately (we do not take them on together). Our office receives no referral fee. Judgments on billing for treatment, such as the assignment of benefit claims, are outside our office's labor scope.

四葉社会保険労務士事務所 can advise on separating reception hours from working hours, designing waiting time and breaks, the social-insurance test for judo therapists and reception staff, and preparing work rules. Fees are in the fee schedule.

Frequently asked questions

Q. Can time when no patient comes be made an unpaid break at a judo-therapy clinic?
A. If staff must respond should a patient arrive during that time, it is waiting time — working hours, subject to wages. You can make it an unpaid break only for time in which staff are completely released from the duty to handle arrivals, such as by closing the clinic, and can spend it freely. If you require phone or arrival handling during a midday long break, that is not a break but working hours.

Q. Are reception hours (opening hours) the same as an employee's working hours?
A. They are different. Reception hours are the posted band for receiving patients, while working hours are the time a worker is under the employer's command and control. Preparation before opening, tidying up after, and waiting time on standby are also included in working hours, so recording only the opening hours as work time risks treating actual working hours as shorter than they are.

Q. Our judo-therapy clinic is a sole proprietorship — with 5 or more staff, is social insurance always compulsory?
A. It cannot be said uniformly. For a sole proprietorship with 5 or more regular staff, whether the clinic falls within an applicable industry (the statutory 16 industries) for health and pension is at issue; because it is unclear whether a judo-therapy clinic is "medical business," confirmation with the local pension office is needed. Incorporating makes coverage compulsory regardless of headcount, so that is clear. It is surest to confirm with the pension office at opening.

Q. At a judo-therapy clinic with long opening hours, can shifts be built to avoid overtime?
A. To have people work beyond 8 hours a day or 40 hours a week you need an Article 36 agreement filed, and premium wages apply to the excess. At a clinic open from morning to night, a monthly-unit variable working-hours system lets you allocate scheduled hours to daily peaks and troughs. Counting waiting time correctly as working hours, and making breaks actually takeable, is the premise for preventing unpaid overtime.

Sources

• Labor Standards Act (Act No. 49 of 1947) Article 15 (stating working conditions), Article 32 (working hours), Article 32-2 (monthly-unit variable working-hours system), Article 34 (breaks; free use in paragraph 3), Article 36 (overtime and holiday work), Article 37 (premium wages), Article 89 (duty to draw up and file work rules with 10 or more regular staff). Confirmed on the e-Gov law search on 27 September 2026
• Meaning of working hours: the time a worker is under the employer's command and control, which includes waiting time (Supreme Court judgment of 9 March 2000, the Mitsubishi Heavy Industries Nagasaki Shipyard case framework for judging working hours). Break time is freely usable time guaranteed release from work (Labor Standards Act, Article 34(3))
• Judo Therapists Act (Act No. 19 of 1970) Article 19: a person who opens a clinic must, within 10 days of opening, notify the prefectural governor of the clinic's location of the location, the names of the judo therapists engaged, and other matters specified by MHLW ordinance. Confirmed on the e-Gov law search on 27 September 2026. The notification procedure itself is done by a Gyoseishoshi or the opener
• Health Insurance Act (Act No. 70 of 1922) Article 3(3) and Employees' Pension Insurance Act (Act No. 115 of 1954) Article 6: a corporation is compulsory with even one representative; a sole proprietorship is compulsory with 5 or more in an applicable industry. Whether a judo-therapy clinic falls within an applicable industry (medical business, etc.) is not uniformly clear, so this article makes no definitive judgment and treats it as a matter to confirm with the local pension office (Japan Pension Service, "Covered workplaces and insured persons"; referenced 27 September 2026)
• Social-insurance coverage expansion for short-time workers: the three-quarters standard; at a specified covered workplace, 20+ hours a week, monthly wage of 88,000 yen or more, expected employment over 2 months, and not a student. The size requirement expands to 51+ insured persons and 36+ from October 2027; the 88,000-yen wage requirement is scheduled to be abolished in October 2026 (MHLW special site; Japan Pension Service; referenced 27 September 2026)
• Employment Insurance Act (Act No. 116 of 1974) Articles 4 and 6: workers with 20+ scheduled weekly hours etc. are insured; 10+ hours from October 2028. Size and wage requirements are revised, so check the latest with the Japan Pension Service and MHLW

This article does not decide whom you should consult. Social/labor-insurance tests and procedures, work rules, and payroll are the work of a Shakai Hoken Roumushi. The clinic opening notification goes to a Gyoseishoshi or the opener, opening taxes to a tax accountant, and property brokerage to a real estate transaction agent — each contracted separately as an independent entity. Our office receives no referral fee. If you consult 四葉社会保険労務士事務所, fees are in the fee schedule and common questions in FAQ.

This article is general information. Individual judgments, such as classifying waiting time or the social-insurance test, are made by a qualified professional after a consultation. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).