Japan’s new guidelines warn employers not to mislabel disability requests as harassment

From The Fukushi Shimbun

February 14 2026

TOKYO – As countermeasures to protect employees from nuisance behavior by customers and others – so-called “customer harassment” – will be made mandatory for employers such as companies, local governments, and welfare facilities, the Ministry of Health, Labour and Welfare has compiled guidelines setting out specific response methods. The measures will come into force on Oct. 1 under the revised Comprehensive Promotion of Labor Policies Act.

The guidelines make clear that employers must take care not to interpret requests for reasonable accommodation from persons with disabilities as customer harassment. They note that discriminatory treatment is prohibited and the provision of reasonable accommodation is mandatory under the Act for Eliminating Discrimination against Persons with Disabilities, and state that appropriate responses are required through “constructive dialogue” to build mutual understanding.

Customer harassment is defined as behavior by customers, business partners, facility users, and others that exceeds socially accepted norms and harms employees’ working environment. Examples include assault, coercion to perform dogeza (prostration in apology), sexual demands, and unjustified claims for damages. Statements hinting at posting negative reviews on social media are also included.

Employers are to clearly state in internal communications their policy of protecting employees, establish response procedures for customer harassment, and ensure these are communicated to staff. Response measures include, as far as possible, not having an employee deal with incidents alone, and having supervisors step in when necessary. Recording interactions by audio or video—handled with due attention to personal information—is also cited. In cases involving acts that constitute crimes, such as assault, notifying the police is listed as an example response.

The guidelines also call for designating personnel to handle employee consultations and for swiftly confirming the facts. They further outline taking measures to prevent recurrence, such as improving the workplace environment, and implementing necessary deterrent actions in particularly malicious cases.