SAKURA Law Office | Legal Update by Managing Partner Kenshiro Michishita
September 24, 2026
SAKURA Law Office | Kenshiro Michishita, Managing Partner
SAKURA Law Office has published the ninth installment of its Legal Update series by Managing Partner Kenshiro Michishita, entitled “Mandatory Customer Harassment Prevention Measures in Japan from October 1, 2026 — Policies, Consultation Systems and Practical Measures Employers Should Implement.”
From October 1, 2026, amendments to Japan’s Act on Comprehensive Promotion of Labor Policies, Stability of Employment of Workers and Enhancement of Vocational Life will require all employers to take necessary employment-management measures to prevent workers’ working environments from being harmed by customer harassment. Customer harassment has often been addressed in practice as a matter of voluntary crisis management or employee protection. From October 2026, however, employers will be expected to establish a legally compliant framework covering consultation systems, frontline response, fact-finding, victim protection, recurrence prevention, deterrence of particularly serious conduct, protection of privacy, and prohibition of disadvantageous treatment of persons who consult or cooperate in investigations.
The purpose of the reform is not to label ordinary complaints or legitimate requests from customers as “customer harassment.” Legitimate complaints, reasonable requests, and requests for reasonable accommodation under disability discrimination law must continue to be addressed in good faith. At the same time, employers should no longer leave individual employees to deal indefinitely with violence, threats, insults, forced apologies or kneeling, prolonged detention, repeated abusive contact, intimidation involving threatened social-media posts, or unjustified demands for money or special treatment.
This Legal Update explains, as of September 24, 2026, the amended Labor Policies Comprehensive Promotion Act and Ministry of Health, Labour and Welfare Notice No. 51 of 2026, which sets out the Guidelines on Measures Concerning Employment Management to Be Taken by Employers in Connection with Problems Caused by the Words and Conduct of Customers and Other Persons in the Workplace. It addresses the legal definition of customer harassment, the scope of covered workers and customers, mandatory measures, frontline response, recording and preservation of evidence, cooperation with police and counsel, suspension or refusal of services, cases involving employees of business counterparties, dispatched workers and external personnel, and the design of internal policies and operating manuals.
Executive Summary
Beginning October 1, 2026, employers in Japan must take necessary employment-management measures so that workers’ working environments are not harmed by customer harassment. These measures include establishing systems for consultation and appropriate response, adopting measures to ensure an effective response to particularly serious conduct by customers and other persons, and implementing other necessary employment-management measures. The obligation is not limited to retail or hospitality businesses. It is relevant to a wide range of businesses whose employees interact with customers, users, patients, residents, business counterparties, vendors, prospective customers or other persons connected with the employer’s business.
Under the statutory framework, customer harassment requires all three of the following elements: first, words or conduct by a customer or other covered person; second, conduct that exceeds what is socially acceptable in light of the nature of the employee’s duties and other circumstances; and third, resulting harm to the worker’s working environment. Employers should therefore avoid deciding cases solely on whether a customer was “difficult” or a complaint was expressed strongly. The substance of the request, the manner of expression, frequency, duration, context, the employee’s own response, and the characteristics of the relevant business must be considered together.
Before the effective date, employers should prioritize a clear management policy, frontline response manuals, consultation channels, escalation routes, procedures for fact-finding and evidence preservation, victim-protection measures, criteria for warnings, requests to leave, police involvement and legal action in serious cases, privacy safeguards, a prohibition on disadvantageous treatment of complainants, and coordination arrangements with business counterparties. A one-page policy alone will not be sufficient. The framework must be incorporated into actual operating processes in stores, call centers, sales organizations, healthcare and welfare settings, facilities management, field services and B2B transactions.
1. What Changes on October 1, 2026 — Customer Harassment Prevention Becomes a Statutory Employer Obligation
Amendments enacted by Act No. 63 of 2025 impose new employment-management obligations on employers from October 1, 2026 in relation to problems caused by the words and conduct of customers and other persons in the workplace. On February 26, 2026, the Ministry of Health, Labour and Welfare issued Notice No. 51 pursuant to amended Article 33, paragraph (4), providing detailed guidelines on the measures employers are required to take.
Amended Article 33, paragraph (1) requires employers to take necessary measures, including establishing a system to respond appropriately to consultations from workers and measures necessary to ensure an effective response to conduct by customers and other persons that exceeds socially acceptable limits and harms the worker’s working environment.
This obligation is not confined to conventional customer-facing industries. Retail, restaurants, hotels, transportation, healthcare, nursing care, education, finance, real estate, IT, professional services, manufacturing and B2B businesses may all need measures suited to their business models where employees interact with customers, users, business counterparties or other persons connected to the business. The Ministry has expressly stated that the obligation will apply to all employers from October 1, 2026.
For employers, the practical shift is from an ad hoc model — deciding what to do only after a serious incident occurs — to a pre-established framework covering policy, decision criteria, consultation channels, frontline authority, escalation, evidence preservation, victim protection, external response and criteria for legal action.
2. Legal Definition of Customer Harassment — All Three Elements Must Be Satisfied
The MHLW Guidelines define workplace customer harassment through three cumulative elements: the conduct must be words or conduct of a customer or other covered person; it must exceed the scope considered socially acceptable in light of the nature of the employee’s duties and other relevant circumstances; and it must harm the worker’s working environment.
An important consequence is that not every customer complaint constitutes harassment. A request to replace a defective product, a demand for performance of an agreed service, a reasonable request for a refund, or a complaint arising from inadequate explanation should be treated as a legitimate request when it is objectively made within socially acceptable bounds.
Conversely, even where the underlying request has some legitimate basis, the manner of pursuing it may constitute customer harassment if it involves assault, threats, insults, attacks on personal dignity, forcing an employee to kneel or apologize in a humiliating manner, prolonged detention, repeated calls or emails, or intimidation involving threats to post damaging content online. Similarly, even outwardly calm conduct may become problematic where a person persistently demands services far beyond contractual obligations, impossible performance, or unjustified compensation.
In practice, employers should separate two questions: whether the substance of the customer’s request has merit, and whether the means and manner used to pursue that request remain acceptable. A partially legitimate complaint does not require employees to tolerate abuse, threats or prolonged coercion.
3. “Beyond Socially Acceptable Limits” Requires a Contextual Assessment, Not a Mechanical Keyword Test
The Guidelines indicate that whether conduct exceeds socially acceptable limits should be assessed comprehensively by considering the purpose of the conduct, whether the worker engaged in any problematic conduct and to what degree, the background and circumstances, the industry and business model, the nature of the work, the manner of conduct, its frequency and duration, the worker’s attributes and physical or mental condition, and the relationship between the parties.
Accordingly, internal manuals should not rely solely on bright-line rules such as “this word always constitutes harassment” or “anything beyond thirty minutes automatically constitutes harassment.” Time limits and identified behaviors can be useful escalation triggers, but final classification should remain contextual.
Employers should also consider whether shortcomings in their own product, service, explanation or customer handling contributed to the incident. A customer-harassment framework is not a mechanism for concealing legitimate service failures. Where the employer has something to correct, that issue should be separated from the abusive conduct and addressed on its own merits.
4. What Does It Mean for the “Working Environment to Be Harmed”? — A Single Serious Incident May Be Enough
The Guidelines explain that a worker’s working environment is harmed where the conduct causes physical or psychological distress and makes the working environment so unpleasant that it creates a material adverse impact on the worker’s ability to perform, or otherwise causes a level of disruption that cannot reasonably be disregarded.
The assessment is not based exclusively on the subjective feelings of the individual worker. The Guidelines use an objective benchmark: whether an ordinary worker placed in similar circumstances would experience disruption serious enough that it could not reasonably be disregarded in performing work.
This does not mean that repeated conduct is always required. Assault, serious threats, extreme insults or other conduct that causes intense physical or psychological harm may satisfy the requirement even on a first occurrence. An internal culture of “endure the first incident and report only if it happens again” can delay intervention in precisely the cases where prompt escalation is most important.
5. The Term “Customer and Other Persons” Is Broad — It May Include Business Counterparties, Facility Users, Prospective Customers and Nearby Residents
The statutory concept is broader than consumers who have actually purchased goods or services. The Guidelines give examples that include prospective customers, potential business counterparties, users of stations, airports, hospitals, schools, welfare facilities and public facilities, family members of users, persons making inquiries about the business, employees of business counterparties, personnel involved in contract negotiations, and residents living near the employer’s facilities.
B2B companies should therefore not assume that the rules are irrelevant merely because they do not operate consumer-facing stores. Repeated demeaning treatment by a customer’s procurement team, prolonged detention of sales personnel at a client site, or intimidation during commercial negotiations may fall within the framework if the statutory elements are satisfied.
Telephone calls, emails, social media and other online conduct can also be relevant. An effective framework should therefore cover not only store-floor procedures but also call centers, inquiry forms, social-media operations, sales teams, complaints handling and business-to-business account management.
6. Covered “Workplaces” and Workers — Incidents at Client Sites and Customers’ Homes Must Also Be Anticipated
The workplace is not limited to the employer’s office or store. A client’s office, a restaurant used for a business meeting, or a customer’s home may also be a workplace where an employee is performing duties. Businesses involving outside sales, home-care services, repair visits, delivery or on-site services should establish practical procedures for communication, withdrawal from the location and requesting assistance.
Covered workers include not only regular employees but also part-time workers, fixed-term employees and other non-regular workers employed by the employer. For dispatched workers, legal obligations may also extend to the client company in addition to the dispatching employer. Employers should therefore avoid creating a separate, lower level of protection for dispatched personnel who perform the same frontline work.
Independent contractors, freelancers and employees of other companies are not identical to the employer’s own workers for purposes of the statutory employment-management obligation. Nevertheless, the Guidelines indicate that employers should seek to protect persons other than their own employees who are present in the workplace and should respond appropriately, where necessary, when such persons consult them. In mixed workforces, a coherent site-wide safety approach will often be more practical than a legal-minimum approach based solely on employment status.
7. First Mandatory Pillar — A Clear Policy and Frontline Response Rules
The Guidelines first require employers to clearly communicate a policy that customer harassment will be addressed firmly and that workers will be protected, and to make that policy known to workers, including managers and supervisors. A message from the chief executive or senior management is one way of demonstrating that commitment.
An abstract statement that “we protect our employees,” however, is not enough. Employers should identify realistic scenarios and specify when frontline staff must escalate, who takes over the interaction, what time or repetition thresholds may trigger a pause or termination of communication, how recordings may be made, when a customer may be asked to leave, when police should be contacted, and when head office or legal counsel must become involved.
The Guidelines give practical examples such as not requiring a worker to handle a serious situation alone, having a supervisor take over, ending a call or requesting a customer to leave after sufficient explanation where unreasonable demands continue, contacting police where conduct may constitute a criminal offense, and consulting legal counsel through the legal department where legal procedures may be required.
The key is to give frontline personnel actual authority. A policy will not function where workers are held responsible for the outcome but have no authority to terminate a call, transfer a case, call security or management, or withdraw from an unsafe situation.
8. Publicizing the Policy to Customers Is Useful, but It Does Not Replace Internal Controls
The Guidelines recognize that communicating to customers the employer’s policy of responding firmly to customer harassment and protecting workers can help prevent incidents. Notices in stores, website statements, terms of use, reservation screens and call-center messages may state that assault, threats, insults or excessive demands may result in suspension of service, removal from premises or contact with law enforcement where appropriate.
External notices are not a substitute for internal procedures. Nor should the wording be so broad that it appears to prohibit legitimate complaints or good-faith disagreement with employees. Overly aggressive notices can discourage legitimate requests and create new customer-relations disputes.
A well-designed public statement should make clear that the employer will protect workers while also responding sincerely to legitimate feedback and requests. From a brand perspective, the message should be framed as a rule for maintaining a safe service environment, not as a declaration of hostility toward customers.
9. Second Mandatory Pillar — The Consultation Channel Must Accept Uncertain and Emerging Cases
Employers must establish in advance a consultation channel for customer harassment and make it known to workers. The Guidelines contemplate using an existing harassment hotline or outsourcing consultation functions to an external provider.
Importantly, the channel is not only for cases that have already been legally classified as customer harassment. The Guidelines require employers to respond broadly where customer harassment is occurring, where there is a risk that it may occur, and where it is uncertain whether the conduct falls within the definition.
Consultation personnel should therefore not act as gatekeepers who mechanically respond, “this is not customer harassment.” They should assess the worker’s physical and mental condition, the background, frequency, specific demands and available objective evidence, and have clear authority to coordinate with management, HR, legal, compliance or occupational-health personnel as appropriate.
In smaller businesses, a direct supervisor may also serve as the consultation contact. Even then, an escalation route should be established so that the matter does not depend solely on one manager’s judgment.
10. Third Mandatory Pillar — Prompt Fact-Finding and Victim Protection Must Be Managed as Separate Workstreams
Once a report is made, the employer must promptly and accurately confirm the relevant facts and respond appropriately. This may involve interviewing the reporting worker, speaking with other workers, reviewing call recordings or video evidence, and, where feasible and necessary, obtaining the alleged actor’s account.
Victim protection should not be postponed until the investigation is complete. Where customer harassment is confirmed, the Guidelines give examples including having a supervisor take over, separating the worker from the actor, changing the responsible staff member, assigning multiple personnel, changing work assignments and arranging mental-health support where needed.
In practice, employers should distinguish final fact-finding from interim safety measures. Even before a legal classification has been finalized, a risk of violence, significant psychological harm or stalking-type contact may justify immediate reassignment, blocking designated contact channels, enhanced security or other interim protective measures.
11. Recording and Video Evidence Can Be Powerful, but Must Be Integrated with Data Governance
The Guidelines expressly identify audio and video recording as possible frontline response tools and also contemplate using recordings as objective evidence during later fact-finding.
In call centers, stores, service counters and field operations, recording can reduce “he said / she said” disputes and protect employees against inaccurate allegations. At the same time, recordings may contain personal information, including voices and images, and therefore must be handled appropriately under Japan’s Act on the Protection of Personal Information and other applicable rules.
Employers should define the purpose, scope, retention period, access controls, external disclosure and deletion procedures for recordings. Where litigation, investigation or police action is reasonably anticipated, a legal-hold process should prevent potentially relevant evidence from being deleted under ordinary retention schedules. Indefinite retention of all recordings, however, is not necessarily appropriate.
For serious incidents, call recordings, CCTV footage, emails, social-media posts, inquiry histories and response logs should be preserved promptly. Original data should be managed in a way that reduces later disputes over editing, alteration or deletion.
12. Fourth Mandatory Pillar — Employers Must Prepare Deterrent Measures for Particularly Serious Cases
A significant feature of the new framework is that employers must not focus exclusively on after-the-fact victim support. They must also determine in advance how to deter and respond to particularly serious customer harassment and establish the organizational capacity to implement those measures.
The Guidelines provide examples such as reporting assault, injury or threats to police, issuing a written warning to the actor, declining to sell goods or provide services to the extent permitted by law, prohibiting entry to stores or facilities, and seeking provisional relief through civil proceedings.
These measures should not remain options that legal counsel improvises only after a crisis. Employers should consider in advance the level of seriousness that triggers a written warning, who has authority to suspend service, the scope of any premises ban, when police consultation, a criminal complaint or accusation should be considered, and when to seek injunctive or other civil relief.
Businesses with multiple locations may also need a process for appropriately sharing information where a person banned from one location appears at another. Such sharing should be limited to what is necessary and designed with data-protection considerations in mind.
13. Refusing Service Is Not a Universal Solution — Consumer Rights, Disability Law and Sector-Specific Duties Must Be Considered
Refusing or terminating service may be an important response to particularly serious misconduct, but businesses do not always have unlimited discretion to refuse any service. The Guidelines specifically note the need to consider consumer rights, the prohibition of unjust discriminatory treatment and the duty to provide reasonable accommodation under Japan’s disability discrimination framework, duties to provide services under sector-specific legislation, and situations where interruption of service may materially affect life or health.
A request for reasonable accommodation by a person with a disability is not customer harassment merely because it requires additional effort. Where communication is affected by dementia, disability characteristics or illness, the employer may need to adapt how it communicates and provides services.
Accordingly, policies should not simply state that “strong demands result in automatic refusal.” Employers need a case-by-case framework that considers the legitimacy of the request, the manner of conduct, sector-specific duties, any need for reasonable accommodation, available alternatives and the need to protect safety. Healthcare, nursing care, public transportation and essential infrastructure require particular care.
14. Fifth Mandatory Pillar — Privacy Protection and Prohibition on Disadvantageous Treatment
Reports of customer harassment may contain sensitive information concerning the worker’s mental or physical condition, sexual orientation, gender identity or other personal matters. The Guidelines require employers to implement measures necessary to protect the privacy of persons who consult or otherwise participate in the process, and to communicate those protections to workers.
Even where information sharing is necessary for response purposes, employers should avoid unnecessarily disseminating details across departments or among large numbers of employees. Access to consultation records should generally be limited to personnel whose involvement is necessary, such as the consultation team, HR, legal, relevant management and occupational-health personnel.
Employers must also not dismiss or otherwise treat workers disadvantageously because they sought consultation, cooperated in fact-finding, requested assistance from a Prefectural Labour Bureau or applied for mediation. Internal policies should expressly state this principle and communicate it to workers.
15. Employers Must Also Manage the Risk That Their Own Personnel Become the Harassers
Customer-harassment compliance is not solely about protecting the employer’s workers as victims. Directors, employees or managers may themselves engage in abusive demands, intimidation or demeaning treatment toward employees of suppliers, contractors or other business partners.
The amended framework and Guidelines expect employers to cooperate where another business requests assistance with fact-finding or similar measures. The Guidelines also indicate that it is undesirable to retaliate — for example, by terminating a business relationship — merely because another company sought cooperation. Where misconduct by the employer’s own personnel is confirmed, appropriate disciplinary or other measures under internal rules may be desirable.
Accordingly, a sound policy should be reciprocal: the company protects its own personnel from customer harassment, and its officers and employees must not engage in customer harassment toward personnel of other businesses. Training is particularly important for departments that exercise commercial leverage, including procurement, sales, principal contractors and major customers.
16. Internal Rules, Operating Manuals and Contracts Must Work Together
A standalone customer-harassment policy will rarely be sufficient. For the framework to operate effectively, employers should align work rules, harassment policies, consultation procedures, complaint-handling manuals, call-center scripts, store and facility manuals, security procedures, data-governance rules and emergency contact protocols.
Businesses that rely on dispatch companies, outsourced call centers, security providers, sales agents, franchisees or facilities-management companies should also clarify, both contractually and operationally, who performs the initial response, who may withdraw workers from the situation, who preserves recordings and video, and who contacts police or counsel.
In B2B transactions, companies may consider contract terms or operating rules requiring mutual non-harassment, investigation cooperation, changes in responsible personnel and recurrence-prevention measures. Contract language alone, however, does not ensure effective operations. The relevant departments should establish real contact points and escalation procedures.
17. What Management Should Verify Before the Effective Date — The Test Is Whether the Organization Can Act, Not Whether a Policy Exists
Before October 1, 2026, senior management should confirm more than the existence of a written policy. Employees should know where to seek help; consultation channels should accept uncertain cases; managers should be authorized to take over interactions; recordings and video should be preservable; police-contact criteria should be understood; responsibility for formal warning letters should be assigned; and authority to suspend service or impose premises bans should be clear.
First, management should issue a clear statement that the company will protect workers from customer harassment. Second, the company should identify realistic scenarios in its own business and create practical criteria distinguishing legitimate complaints from harassment. Third, it should establish consultation and escalation routes. Fourth, it should document immediate-response procedures, evidence preservation, victim protection and coordination with police and counsel. Fifth, it should clarify authority for warnings, termination of interactions, refusal of service and exclusion from premises in serious cases. Sixth, managers and frontline employees should receive scenario-based training.
After implementation, the organization should not judge effectiveness solely by the number of consultations received. A low number may reflect a genuinely safe environment, but it may also indicate a workplace culture in which employees are reluctant to report. Surveys, labor-union or safety-and-health committee input, leave and turnover patterns, and direct frontline interviews can provide additional insight.
18. The Credibility of the Framework Depends on Not Misusing “Customer Harassment” to Suppress Legitimate Complaints
An effective customer-harassment framework depends on the employer continuing to treat legitimate complaints as legitimate. Protecting workers and respecting customers’ lawful rights are not inconsistent objectives.
Where there is an actual product or service defect, failure to perform contractual obligations, insufficient explanation, or a genuine need for reasonable accommodation, the employer should identify and correct the underlying problem. At the same time, the existence of some fault on the employer’s side does not require workers to tolerate violence, threats, attacks on personal dignity or prolonged coercion.
A useful two-step framework is therefore to ask separately whether the substance of the request has merit and whether the manner in which the request is pursued remains within acceptable limits. The company can correct a legitimate underlying issue while still taking appropriate protective action where the customer’s conduct crosses the line.
19. Our Perspective — The Central Issue Is Organizational Ownership of Customer Harassment Risk
One of the most serious failures in customer-harassment management is to tell frontline personnel merely to “remain polite” without explaining how much they are expected to endure, when they may end the interaction, and whom they may call for support.
From October 2026, sound practice requires organizations to take ownership of customer interactions that cross legal and operational boundaries rather than leaving employees to manage them alone. Roles among frontline operations, management, HR, legal, compliance, security, communications and occupational-health functions should be defined, together with criteria for moving a case from individual response to organizational response.
At the same time, the term “customer harassment” should not be used to avoid accountability for genuine service failures or to suppress lawful complaints. The most credible framework protects workers while preserving mechanisms for customers to raise legitimate concerns, and uses criteria tailored to the employer’s industry and service model.
Compliance with the new law should therefore be viewed not merely as a labor-law exercise, but as an integrated management issue involving workforce safety, retention, service quality, standardized customer handling, prevention of serious incidents and protection of corporate reputation.
20. Frequently Asked Questions
Q1. From October 1, 2026, do all companies in Japan need customer-harassment measures?
The statutory obligation is not limited to particular industries or only to large companies. Employers with interactions involving customers or other covered persons must implement necessary measures appropriate to their industry, business model and risk profile.
Q2. If a customer complains loudly, is that automatically customer harassment?
No. The substance of the request, manner of communication, background, frequency, duration, industry context and the worker’s response must be assessed together. Loud or intimidating conduct may constitute customer harassment where it exceeds socially acceptable limits and harms the working environment, but no single factor is always determinative.
Q3. May an employee end a call with a customer who is engaging in customer harassment?
The Guidelines identify ending a call after sufficient explanation where demands continue repeatedly as one possible response. Employers should define internal criteria in advance, taking into account the nature of the service, urgency and the customer’s circumstances.
Q4. May calls or customer interactions be recorded?
The Guidelines identify audio and video recording as potential response and fact-finding measures. Because recordings may contain personal information, employers should appropriately govern purpose, retention, access, disclosure and deletion under data-protection and other applicable laws.
Q5. May a company refuse service to a customer who engages in serious harassment?
The Guidelines identify non-provision of goods or services, to the extent permitted by law, as one possible response to particularly serious conduct. Sector-specific service obligations, consumer-law considerations, disability discrimination and reasonable accommodation obligations may nevertheless require case-by-case analysis.
Q6. May an employee consult the company even if it is unclear whether the conduct legally qualifies as customer harassment?
Yes. The Guidelines require consultation systems to address not only confirmed cases but also situations where there is a risk of occurrence or where classification is uncertain.
Q7. If an employee of a business partner harasses our employee, can we ask the business partner to investigate?
Cooperation may be requested where necessary for fact-finding and recurrence prevention. Conversely, where the company’s own personnel are alleged to have harassed workers of another business, the employer is expected to endeavor to cooperate with reasonable requests for investigation.
Q8. Are freelancers and outsourced personnel protected?
The statutory employment-management obligation centers on workers employed by the employer, but the Guidelines indicate that employers should also seek to protect employees of other companies, independent contractors and other persons working at the workplace and respond appropriately where necessary.
21. About Kenshiro Michishita’s Legal Update Series
SAKURA Law Office publishes the Legal Update series through the profile of Managing Partner Kenshiro Michishita, addressing important legal issues affecting companies and management, including corporate law, M&A, cross-border transactions, AI and technology, data protection, intellectual property, crisis management, employment matters, Web3 and digital assets.
The series is intended not merely to summarize statutes. It examines how legal developments affect operational workflows, contracts, internal policies, board and management processes, employee relations, customer handling and crisis management in actual business practice.
This ninth installment addresses the customer-harassment prevention obligations effective October 1, 2026. Future installments will address the amended Whistleblower Protection Act effective in December 2026, foreign investment and M&A in Japan, cross-border transactions, corporate investigations, defamation and reputation risk, Web3 and other significant areas.
22. How SAKURA Law Office Can Assist with Customer Harassment Compliance
SAKURA Law Office advises companies preparing for the October 1, 2026 reforms, taking into account industry, workforce size, customer touchpoints, existing harassment frameworks and actual frontline operations.
We can assist with drafting or revising customer-harassment policies, internal rules and response manuals; designing consultation channels and escalation flows; training managers and frontline personnel; reviewing warning letters and the legal basis for suspension of services or premises bans; police coordination; provisional relief and other legal proceedings; governance of audio/video recordings and personal information; cooperation with business counterparties; allocation of responsibilities with staffing and outsourcing providers; and response to actual customer-harassment incidents.
Even where a company already has complaint-handling manuals or harassment policies, a specific review against the 2026 amendments and MHLW Guidelines is advisable. Existing materials may not adequately address deterrent measures for serious cases, non-retaliation obligations, investigation cooperation requested by other businesses, or the operational authority needed by frontline staff.
23. Contact
For advice on customer harassment, workplace harassment policies, employee protection, consultation systems, complaints handling, warning letters, police coordination, provisional relief and related employment, crisis-management and corporate-law matters, please contact SAKURA Law Office.
When contacting us, please indicate that your inquiry concerns “customer harassment compliance” so that it can be directed promptly to the appropriate attorney.
SAKURA Law Office
Kenshiro Michishita, Managing Partner
Ark Hills South Tower 4F, 1-4-5 Roppongi, Minato-ku, Tokyo 106-0032, Japan
Tel: +81-3-6910-0692
Written and supervised by
SAKURA Law Office
Kenshiro Michishita, Managing Partner
Principal References
Ministry of Health, Labour and Welfare, “Measures to Prevent Harassment in the Workplace”
This article provides general legal information based on laws, MHLW guidelines and publicly available materials as of September 24, 2026. It does not constitute legal advice or a legal conclusion for any specific matter. Individual cases require assessment in light of the relevant industry, business model, contractual relationships, the conduct of the customer or other person, the condition of affected workers, sector-specific legislation and all other relevant facts.