Executive Summary
Among small businesses with fewer than 50 employees, mental health program adoption rates range from just 55.3% to 69.1%, a stark contrast with the 94.3% rate at workplaces with 50 or more employees (Ministry of Health, Labour and Welfare, 2024). In May 2025, amendments to Japan's Industrial Safety and Health Act were enacted, mandating stress checks for all workplaces by 2028. Meanwhile, options that require little to no budget already exist, including free support from Regional Occupational Health Centers and free educational content from the Ministry of Health, Labour and Welfare. The perception that "we don't have the budget" or "we don't know where to start" is a structural problem caused by information gaps and cognitive overload -- and it can be resolved through a phased approach.
Definition and Current State
Definition: Mental health measures for small businesses refer to the comprehensive set of actions taken by employers at workplaces with fewer than 50 employees to maintain and promote the psychological well-being of their workers. This includes conducting stress checks, establishing harassment consultation desks, fulfilling the duty of care, and coordinating with external specialist organizations.
Common Situations Facing Small Businesses
- You notice something is off with an employee's demeanor, but don't know how to bring it up, so it goes unaddressed
- You got quotes for an Employee Assistance Program (EAP), but the monthly cost of tens of thousands of yen was prohibitive
- Stress checks, harassment hotlines, training programs -- there's too much to do and no way to prioritize
- The small, close-knit environment paradoxically makes it harder for employees to speak honestly
Self-Check (Current Preparedness)
- Have you established a harassment consultation desk? (Mandatory for all businesses since April 2022)
- Have you verified your minimum response framework from a duty-of-care perspective?
- Do you know about your Regional Occupational Health Center and how to contact them?
- Have you informed employees about external consultation resources?
- Do you have a preparation plan for the 2028 stress check mandate?
Data and Evidence
Mental Health Program Adoption Rates
| Workplace Size | Adoption Rate | Source |
|---|---|---|
| 50+ employees | 94.3% | (MHLW, 2024) |
| 30-49 employees | 69.1% | (MHLW, 2024) |
| 10-29 employees | 55.3% | (MHLW, 2024) |
*In the 2021 survey, rates were 94.4% (50+), 70.7% (30-49), and 49.6% (10-29) (MHLW, 2021), indicating the figures have remained largely flat.
Stress Check Implementation Rates
| Workplace Size | Implementation Rate | Source |
|---|---|---|
| 50+ employees | 84.7% | (Doctor Trust, 2026) |
| Under 50 employees | 32.3% | (Doctor Trust, 2026) |
The 14th Occupational Accident Prevention Plan set a target of 50% or higher stress check implementation at small workplaces with fewer than 50 employees by 2027, but this target has not been met (MHLW, 2023).
Why Small Workplaces Under 50 Employees Haven't Adopted Mental Health Programs
| Reason | Percentage | Source |
|---|---|---|
| No employees with relevant issues | 44.0% | (MHLW, 2020) |
| Don't know how to implement measures | 33.8% | (MHLW, 2020) |
| No specialist staff available | 26.3% | (MHLW, 2020) |
Work-Related Mental Health Claims
In fiscal year 2023, work-related mental health claims reached a record 883 cases (MHLW, 2023). 95.9% of all workplaces have fewer than 50 employees, and more than half of all workers are employed at these small workplaces (Ministry of Internal Affairs and Communications / Ministry of Economy, Trade and Industry, 2023).
The Cost of Mental Health Issues and Turnover
| Item | Cost | Source |
|---|---|---|
| Employer cost when an employee earning 6 million yen annually takes a 6-month mental health leave | Approx. 4.22 million yen | (Cabinet Office) |
| Loss from a new hire leaving within 3 months | Approx. 1.875 million yen | (en Japan) |
Worker Stress Levels
68.3% of workers report experiencing significant anxiety, worry, or stress related to their jobs -- more than two out of three (MHLW, 2024).
Cost Estimates for Outsourced Stress Checks
| Cost Item | Range | Source |
|---|---|---|
| Base fee (50-person scale) | 20,000-100,000 yen | (Doctor Trust, 2026) |
| Per-person implementation fee | 300-1,000 yen | (Doctor Trust, 2026) |
| High-stress individual consultation (per person) | 10,000-50,000 yen | (Doctor Trust, 2026) |
| Administrator services | 25,000-50,000 yen | (Doctor Trust, 2026) |
| Group analysis | 0-100,000 yen | (Doctor Trust, 2026) |
All costs must be borne by the employer. Workers cannot be charged (Industrial Safety and Health Act). Three versions of the stress check questionnaire are available: the 57-item version (MHLW recommended), the 80-item version (includes workplace environment and harassment items; becoming standard), and the 120-item version (Doctor Trust, 2026).
Current Legal Requirements (As of 2026)
| Requirement | 50+ Employees | Under 50 Employees | Source |
|---|---|---|---|
| Stress check implementation | **Mandatory** | Best-effort obligation (**Mandatory by 2028**) | (CHR, 2025) |
| Harassment consultation desk | **Mandatory** (since April 2022) | **Mandatory** (since April 2022) | (MHLW) |
| Duty of care | **Mandatory** | **Mandatory** | (Labor Contract Act, Art. 5) |
Stress Check Mandate Timeline
| Date | Milestone | Source |
|---|---|---|
| May 8, 2025 | Amended Industrial Safety and Health Act passed by the House of Representatives | (Doctor Trust, 2026) |
| May 14, 2025 | Amended Act promulgated | (CHR, 2025) |
| FY 2025 | Working group established; implementation manual development begins | (Doctor Trust, 2026) |
| November 2025 | Draft manual for small workplaces submitted for review | (CHR, 2025) |
| Early FY 2026 | Manual publication expected | (Doctor Trust, 2026) |
| FY 2026-2028 | Awareness and preparation period (approx. 2 years) | (Doctor Trust, 2026) |
| FY 2028 (approx. April) | Expected enforcement date | (Doctor Trust, 2026) |
Workplaces with fewer than 50 employees will not be required to report to the Labor Standards Inspection Office, in consideration of reducing the administrative burden (Doctor Trust, 2026).
Free Public Resources
| Resource | Eligibility | Services | Source |
|---|---|---|---|
| Regional Occupational Health Centers | Workplaces under 50 employees | Physician consultations based on health check results, interviews for overworked employees, high-stress individual consultations, health guidance, on-site visits. Approx. 350 locations nationwide. **Free of charge** | (MHLW, 2023) |
| Occupational Health Support Centers | All workplaces | Support for employers and HR/labor management staff. Located in all 47 prefectures | (MHLW, 2023) |
| Kokoro no Mimi (MHLW portal) | All workplaces | E-learning courses: "Understanding Self-Care in 15 Minutes," "Understanding Line Care in 15 Minutes," 5-Minute Training Series, and more | (MHLW, 2023) |
| Group-Based Occupational Health Promotion Subsidy | Small and medium businesses | Covers 4/5 of occupational health service costs (up to 1 million yen). Note: Stress check implementation costs are not eligible | (Doctor Trust, 2026) |
Case Studies from Small Businesses
| Company | Size | Initiative | Outcome | Source |
|---|---|---|---|---|
| Jupitec Co., Ltd. (Hyogo Prefecture) | Approx. 35 employees | Introduced regular counseling sessions for all employees | Reduced recruitment costs through lower turnover | (MHLW, 2023) |
| Ijima Densetsu Co., Ltd. (Fukuoka Prefecture) | Approx. 25 employees | Established a "health promotion liaison" within the general affairs department; mental health education | Organic development of a culture that values new hires | (MHLW, 2023) |
Analysis and Implications
Key Concepts: cognitive overload, learned helplessness, psychological safety, emotional exhaustion, organizational silence, normalcy bias, duty of care, primary prevention, presenteeism
Axis A: Mechanism Analysis -- Why Small Businesses Can't Get Started on Mental Health
The top three reasons for inaction -- "no employees with relevant issues (44.0%)," "don't know how to implement measures (33.8%)," and "no specialist staff available (26.3%)" -- appear to be different problems on the surface, but share a common underlying mechanism.
The danger of "no employees with relevant issues." 44.0% of workplaces report having no employees with mental health concerns. Yet the same body of research shows that 68.3% of all workers experience significant work-related stress. This contradiction reveals a structural problem specific to small workplaces. Precisely because the team is small and everyone is visible to one another, employees feel compelled to say "I'm fine." Because the owner is always nearby, honesty feels impossible. This is a textbook manifestation of organizational silence.
In my experience as an industrial counselor, I have repeatedly observed the same pattern: employers equating "nobody is complaining" with "there are no problems." When employees stay silent, it is because psychological safety has not been established -- not because everything is fine.
There is also the phenomenon of pain desensitization. There are real cases of people working 200 hours of overtime per month who genuinely felt "it wasn't that bad." Whether someone who checks "no issues" on a self-report actually has no issues cannot be determined from the data alone. Self-report surveys have inherent limitations.
Stagnation from cognitive overload. Behind the 33.8% who responded "don't know how to implement measures" lies a problem of cognitive overload from too much information. Stress checks, harassment desks, management training, self-care education, appointing an occupational physician -- the more items you list, the more everything feels half-done, and ultimately nothing gets started. This closely resembles learned helplessness. Having too much information itself becomes a barrier to action.
Axis B: Institutional and Environmental Analysis -- How the 2028 Mandate Changes the Landscape
The essential significance of the mandate. The primary purpose of the stress check system is "primary prevention" -- early detection and early response before conditions worsen (CHR, 2025). This matters regardless of company size, but arguably matters more for smaller organizations. When a company of 18 employees loses one person, that's 5.5% of the workforce. The organizational impact is entirely different from losing one person among a thousand.
An obligation already being overlooked. Many workplaces under 50 employees are focused on the upcoming stress check mandate, but harassment consultation desks have been mandatory for businesses of all sizes since April 2022. This requirement has slipped under the radar at a significant number of small workplaces. There are obligations that require immediate action, not in 2028.
Outsourcing recommendations and cost structure. The MHLW's interim report recommends that workplaces with fewer than 50 employees outsource stress checks to protect employee privacy. Looking at cost estimates, the base fee ranges from 20,000 to 100,000 yen, with a per-person fee of 300 to 1,000 yen. For a workplace of around 50 people, the annual cost might be in the range of tens of thousands to low hundreds of thousands of yen. Meanwhile, high-stress individual consultations through Regional Occupational Health Centers are available free of charge. When the full cost picture is understood accurately, many organizations will find these services are within reach.
Axis C: Impact Analysis -- The Cost of Doing Nothing
When an employee earning 6 million yen annually is unable to work for six months due to mental health issues, the cost to the employer is approximately 4.22 million yen (Cabinet Office). Losing a new hire within three months costs approximately 1.875 million yen (en Japan). These figures cover only direct financial costs and do not account for the increased burden on remaining employees, declining morale, or the cost of rehiring and retraining.
Comparing the annual cost of stress checks (tens of thousands to low hundreds of thousands of yen) against the loss from a single mental health case (millions of yen) makes it clear that "we can't afford to invest in prevention" is actually the most expensive decision a business can make.
Equally important is the cost of presenteeism -- being physically present at work but operating at reduced capacity. Absence and turnover are visible. Presenteeism is not. With 68.3% of workers reporting significant stress, it would be unrealistic to assume that productivity is unaffected.
Recommended Actions
Phase 1: Take Action Now
Verify and establish your harassment consultation desk. This has been mandatory for all businesses since April 2022. If you don't have one, this needs urgent attention. If an internal desk is impractical, start with outsourcing (from a few thousand yen per month) or simply publicizing free public hotlines.
Make external consultation resources visible. Post the following information where employees can easily see it:
- Kokoro no Mimi Worker's Hotline (MHLW): 0120-565-455
- Yorisoi Hotline: 0120-279-338 (24 hours)
Contact your Regional Occupational Health Center. Confirm what free services are available for workplaces under 50 employees. The important thing is to make contact before you need help.
Phase 2: Prepare for 2028 (Within 1-2 Years)
Pilot a stress check program. Use the current best-effort period as a time to "get familiar" with the process. An implementation manual is expected to be published in FY 2026 -- use that as your starting point for preparation.
Evaluate costs and logistics. Obtain quotes from multiple outsourcing providers and select a service that fits your organization's size and budget. Remember that workplaces under 50 employees will not be required to report to the Labor Standards Inspection Office, so the compliance burden will be lighter than for larger organizations.
Phase 3: Build Prevention and Education (Within 2-3 Years)
Training for managers. The MHLW's "Kokoro no Mimi" portal offers free e-learning courses including "Understanding Line Care in 15 Minutes" and a 5-Minute Training Series.
Promote self-care education. Simply making employees aware that the "Understanding Self-Care in 15 Minutes" e-learning course exists can serve as an entry point for self-care practice.
Role-Specific Actions
For business owners: Contact your Regional Occupational Health Center and ask about the free services available to your business. One sentence is all it takes: "I've been thinking about mental health support for our employees -- could you advise us on what's available?"
For HR/general affairs staff: Don't try to handle everything alone. Leverage external resources. Occupational Health Support Centers (in all 47 prefectures) exist to help employers and HR professionals. Ask: "We're a workplace with fewer than 50 employees. Could you advise us on how to approach mental health measures?"
For managers: When you notice something is off with a team member, what's needed is not to "fix" them, but to serve as a bridge to professional help. "You seem a bit tired lately -- are you doing okay?" Don't try to give advice. Just let them know you've noticed and you care.
Resource Guide
Public Consultation Services
| Service | Phone Number | Hours |
|---|---|---|
| Kokoro no Mimi Worker's Hotline (MHLW) | 0120-565-455 | Weekdays 17:00-22:00, Weekends 10:00-16:00 |
| Yorisoi Hotline | 0120-279-338 | 24 hours |
Support Organizations for Businesses
| Organization | Eligibility | Cost |
|---|---|---|
| Regional Occupational Health Centers | Workplaces under 50 employees | Free |
| Occupational Health Support Centers | All workplaces | Free (consultation) |
Free Educational Content
- E-learning: "Understanding Self-Care in 15 Minutes" (Kokoro no Mimi)
- E-learning: "Understanding Line Care in 15 Minutes" (Kokoro no Mimi)
- 5-Minute Training Series: "Self-Care Through Lifestyle and Sleep" (Kokoro no Mimi)
- 5-Minute Training Series: "Workplace Mental Health Measures" (Kokoro no Mimi)
- 5-Minute Training Series: "Day-to-Day Check-Ins with Your Team" (Kokoro no Mimi)
Conclusion
The greatest barrier to mental health measures at small businesses with fewer than 50 employees is not budget or regulations, but cognitive overload -- the feeling of "not knowing where to start." As the data shows, free public resources already exist, and the preparation period leading to the 2028 mandate is built in.
Choosing to "do nothing" means avoiding an annual investment of tens of thousands of yen while continuing to carry a risk of losses in the millions. The smaller the organization, the greater the impact when even one person is affected -- meaning the belief that "a company our size doesn't need this" is actually the reverse of reality.
The first step is to contact your Regional Occupational Health Center. If your workplace has fewer than 50 employees, you can access occupational health services free of charge. This single action can serve as the starting point for building a systematic approach, one step at a time.
Frequently Asked Questions (FAQ)
Q. Is a harassment consultation desk mandatory for businesses with fewer than 50 employees?
Yes. Since April 2022, all businesses are required to have one, regardless of size. "Under 50 employees" does not mean exempt. If setting up an internal desk is impractical, options include outsourcing or publicizing public hotlines.
Q. When does the stress check mandate take effect?
The amended Industrial Safety and Health Act was enacted in May 2025 and will take effect on a date specified by government order within three years of promulgation. Enforcement is currently expected around April 2028 (Doctor Trust, 2026). Workplaces with fewer than 50 employees will not be required to report to the Labor Standards Inspection Office.
Q. How much do stress checks cost?
For outsourced services, the base fee is 20,000-100,000 yen (for a 50-person scale), with a per-person fee of 300-1,000 yen (Doctor Trust, 2026). All costs must be borne by the employer and cannot be passed on to employees.
Q. Are there free mental health support resources for businesses with fewer than 50 employees?
Yes. Regional Occupational Health Centers are dedicated to workplaces with fewer than 50 employees and offer physician consultations based on health check results, high-stress individual interviews, and health guidance -- all free of charge. There are approximately 350 locations nationwide (MHLW, 2023).
Q. What does it cost when an employee's mental health issues go unaddressed?
When an employee earning 6 million yen annually takes a six-month mental health leave, the cost to the employer is approximately 4.22 million yen (Cabinet Office). Losing a new hire within three months costs approximately 1.875 million yen (en Japan). These figures do not include indirect costs such as increased workload for remaining staff, declining morale, or rehiring and retraining expenses.
Sources and References
Government Publications
- Ministry of Health, Labour and Welfare, "2024 Survey on Industrial Safety and Health (Fact-Finding Survey): Summary of Results" (2024) https://www.mhlw.go.jp/toukei/list/dl/r06-46-50_gaikyo.pdf
- Ministry of Health, Labour and Welfare, "Kokoro no Mimi: For Small Business Owners" (2023) https://kokoro.mhlw.go.jp/sme/
- Ministry of Health, Labour and Welfare, "14th Occupational Accident Prevention Plan" (2023)
- Ministry of Health, Labour and Welfare, "Interim Report of the Review Committee on Mental Health Measures Including the Stress Check System" https://www.mhlw.go.jp/content/11201250/001314987.pdf
- Ministry of Health, Labour and Welfare, "Overview of the Bill to Amend the Industrial Safety and Health Act and the Working Environment Measurement Act" (2025) https://www.mhlw.go.jp/content/001449334.pdf
- Ministry of Health, Labour and Welfare, "FY 2023 Workers' Compensation for Mental Health Claims" (2023)
- Ministry of Health, Labour and Welfare, "Stress Check System Q&A"
- Ministry of Internal Affairs and Communications / Ministry of Economy, Trade and Industry, "2021 Economic Census for Business Activity" (2023)
- Cabinet Office, "Survey on Employee Turnover and Separation Costs"
Private and Specialist Publications
- Doctor Trust, "Stress Check Mandate Confirmed for Under 50 Employees! What Small Businesses Need to Prepare" (2026) https://sanpomichi-dt.jp/50-stresscheck-gimuka/
- Doctor Trust, "2026 Edition: Stress Check Cost Guide and Provider Comparison" (2026) https://sanpomichi-dt.jp/stresscheck-hiyou-hutan/
- CHR, "Stress Check Mandate Coming to Small Businesses Under 50 Employees!" (2025) https://chr.co.jp/blog/stresscheck-mandatory/
Related Content and Author Information
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About the Reset Method
The analysis in this briefing note is grounded in the philosophy of the Reset Method: "It's okay to stop. Every time you start walking again, that single step changes your future." Mental health initiatives, too, are not about building a perfect system all at once -- they take shape through the accumulation of small, steady steps.
Author Profile
Kazuhiko Ehara
Certified Industrial Counselor (Japan Industrial Counselors Association). Director, Kazuna Research Institute. Director, MentaHealth Inc.
After approximately 25 years in the IT industry, he founded the Kazuna Research Institute in 2018. He combines the logical thinking honed as an engineer with the interpersonal expertise of an industrial counselor. Having personally experienced 200-250 hours of monthly overtime in his twenties, he speaks from firsthand knowledge of "pain desensitization" and its role in workplace mental health. He practices Brief Coaching grounded in SFBT (Solution-Focused Brief Therapy).