Employee periodic health checks: how far does the duty go, and who pays for the cost and the time?

Bottom line first: A periodic health check is the employer's duty, done once within each year for regularly employed workers (Industrial Safety and Health Regulations Article 44). The cost is in principle borne by the employer; pay for the time is set by labour-management discussion for general checks and treated as working time for special checks.

You hear that you must give health checks once you hire staff, but owners often get stuck on "who is covered," "what about part-timers," and "who bears the cost and the pay for the time." This article sets out the scope of the duty and the treatment of cost and time, in order.

Who must have a periodic health check, and when?

An employer must have a physician give a health check to regularly employed workers (Industrial Safety and Health Act Article 66(1)): on hiring (Industrial Safety and Health Regulations Article 43) and once within each year thereafter (Article 44). This duty applies regardless of headcount; not giving checks is a breach.

Type	Basis	Timing
Hiring health check	ISH Regulations Art. 43	When hiring a regular worker
Periodic health check	ISH Regulations Art. 44	Once within each year
Specified-task-worker check	ISH Regulations Art. 45	On reassignment and once every six months (twice a year)
Special health check	ISH Act Art. 66(2)(3) and each special rule	Periodically, for workers in hazardous tasks

From where are part-timers and short-hour workers covered?

"Regularly employed workers" includes not only full-timers but certain part-time and short-hour workers. By the administrative-notice guide, a short-hour worker is covered when both hold:

Requirement	Content
Contract term	No fixed term, or expected to be used for 1 year or more on renewal (6 months for specified-task workers) / already used for 1 year or more (6 months)
Working hours	Weekly contracted hours are 3/4 or more of a comparable regular worker's

Where they are under 3/4 but roughly 1/2 or more, the check is desirable. Being a part-timer does not uniformly put someone outside the scope. Note the standard differs from the social-insurance eligibility test — do not confuse them. See what employers do as the ¥1.06m wall is removed.

What is the twice-a-year check for specified-task workers such as night workers?

Workers who regularly do specified tasks — those including night work, or heat, cold, underground, hazardous radiation and the like — need a check on reassignment and once every six months (twice a year) (Industrial Safety and Health Regulations Article 45). That is double the once-a-year periodic check. Night work arises across retail, food service, transport, security and petrol stations. Some items, such as chest X-rays, need only be done once a year, while blood pressure, blood tests and ECG are done twice. See petrol-station labour and hazardous-materials staffing, and for the move to extend stress checks to workplaces under 50, extending the stress check to under 50.

When is a special health check for organic solvents, asbestos and the like needed?

Workers in hazardous tasks need, separately from the general check, a special health check under the rule for each task (Industrial Safety and Health Act Article 66(2)(3)).

Task	Governing rule
Work with organic solvents	Ordinance on Prevention of Organic Solvent Poisoning
Work with lead	Ordinance on Prevention of Lead Poisoning
Work with specified chemical substances	Ordinance on Prevention of Hazards due to Specified Chemical Substances
Work with asbestos	Ordinance on Prevention of Asbestos Hazards
Work exposed to ionising radiation	Ordinance on Prevention of Ionising Radiation Hazards
High-pressure/diving work	Ordinance on Safety and Health of Work under High Pressure

A special check is a continuing duty while the worker is in the task, done on reassignment and periodically. For some substances health management is required even after the work ends.

Who bears the cost of the check, and the pay for the time spent?

Because the law places the duty to conduct checks on the employer, the cost is to be borne by the employer (administrative notice). Pay for the time spent, however, differs by type of check.

Target	Cost	Pay for the time
General check (hiring, periodic, specified-task)	Employer	To be set by labour-management discussion (not automatically payable, but payment is desirable)
Special check	Employer	Treated as working time; pay it

Whether to pay for general-check time is best made clear in the work rules or a labour-management agreement to avoid disputes. Where 50 or more workers are regularly employed, a periodic-health-check results report (Form No. 6) goes to the head of the Labour Standards Inspection Office when a periodic check is done (Industrial Safety and Health Regulations Article 52).

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Who handles conducting, reporting and cost processing?

The check itself and special checks belong to an industrial physician and medical institutions. The tax handling of check costs belongs to a tax accountant. The labour side — designing the system, setting out the treatment of check time in the work rules and a labour-management agreement, and preparing and submitting the results report — is a Shakai Hoken Roumushi's. Each is engaged as a separate, independent entity under separate contracts, and this office takes no referral fee.

Your first consultation is free. Please see the fee schedule, the services and how we work.

Frequently asked questions

Q. Does a three-day-a-week part-timer need a health check?
A. If the contract is expected to last 1 year or more and weekly contracted hours are 3/4 or more of a comparable regular worker's, the person is covered by the periodic check (administrative-notice guide). Under 3/4 but roughly 1/2 or more, it is desirable. This is a different test from social-insurance eligibility, so judge them separately.

Q. Can we make employees bear the cost of the health check?
A. No. Because the law places the duty to conduct checks on the employer, the cost is to be borne by the employer (administrative notice). Making employees pay is not appropriate. As for pay for the time, general-check time is set by labour-management discussion, while special-check time is working time and must be paid.

Q. An employee refuses a health check. Can they refuse?
A. Workers have a duty to undergo the check, but they may instead undergo a check by a physician other than the one the employer designates and submit a document certifying the result (Industrial Safety and Health Act Article 66(5)). As the employer must fulfil the conducting duty, set a provision in the work rules requiring the check and operate it to fit the facts. Individual handling varies case by case.

Q. Must a company under 50 also submit the results report?
A. The duty to submit the periodic-health-check results report falls on workplaces that regularly employ 50 or more workers (Industrial Safety and Health Regulations Article 52). Under 50 there is no submission duty, but the duty to conduct the checks itself applies regardless of headcount. Conducting and recording are needed even under 50.

This article's basis

• Industrial Safety and Health Act (Act No. 57 of 1972) Article 66(1) (the employer must have a physician give a health check to workers), Article 66(2)(3) (special health checks for hazardous tasks), Article 66(5) (a worker may undergo a check by a physician other than the one designated and submit a certifying document)
• Industrial Safety and Health Regulations (Ministry of Labour Order No. 32 of 1972) Article 43 (hiring health check), Article 44 (periodic check once within each year), Article 45 (specified-task-worker check, on reassignment and once every six months; some items such as chest X-rays once a year suffice), Article 52 (employers of 50 or more regular workers submit the periodic-health-check results report, Form No. 6, to the head of the Labour Standards Inspection Office)
• The special rules for special health checks (Organic Solvent Poisoning, Lead Poisoning, Specified Chemical Substances, Asbestos Hazards, Ionising Radiation Hazards, High-Pressure Work, etc.)
• Administrative notice on the scope of health checks for short-hour workers (the guide of contract term and weekly hours of 3/4 or more; roughly 1/2 or more is desirable), under the enforcement notice of the Act on Improvement of Employment Management for Part-Time Workers
• Administrative interpretation that the cost of health checks is borne by the employer (18 September 1972, Kihatsu No. 602), and the view on pay for the time (general checks by labour-management discussion, special checks as working time) — Ministry of Health, Labour and Welfare explanation (accessed 1 October 2026)
• Whether a particular worker is a "regularly employed worker," and how to set out paid check-time in the work rules and a labour-management agreement, vary case by case. This article does not give an individual conclusion (unverified).

This article is general information. An individual judgment on your circumstances is made by a qualified professional after a meeting. At the Yotsuba Shakai Hoken Roumushi Office we can advise on designing the health-check system, setting out the treatment of check time in the work rules and a labour-management agreement, identifying specified-task and special-check targets, and preparing and submitting the periodic-health-check results report. Conducting checks and special checks belong to an industrial physician and medical institutions, and the tax processing of costs to a tax accountant — each a separate, independent entity engaged under separate contracts, with no referral fee. Common questions are gathered in the FAQ. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Licensed Real Estate Transaction Agent).