The amended Comprehensive Labor Policy Promotion Act, which obliges employers to take measures against customer harassment (“kasuhara”), came into force on October 1, 2026, and nearly two weeks have already passed. Any business that employs even one worker is covered, and there is no transitional relief for small and medium-sized enterprises or sole proprietors. Some properties finished their preparations before the effective date, but many others are likely still in the position of “the policy is posted, but the consultation desk and record forms are not ready yet” or “we have not decided how to handle cases where staff from our cleaning contractor are targeted.” This article translates the measures required by the Ministry of Health, Labour and Welfare (MHLW) guidelines (MHLW Notification No. 51 of 2026) into four operational scenes in the accommodation business, sorts out how the law relates to the local ordinances that came first, and estimates the annual cost of putting the system in place for model properties of 50, 100 and 200 rooms. The effective date has passed, but once the order of tasks and the scale of the effort are clear, the remaining work is short.

The Framework Now in Force — Definition and Four Pillars, Straight from the Text

Let us first confirm the facts of the system from the legal text. The legal basis is the amended Comprehensive Labor Policy Promotion Act (Act No. 63 of 2025), promulgated on June 11, 2025; the duty to take customer-harassment measures took effect on October 1, 2026. The specific measures are set out in the guidelines promulgated on February 26, 2026 (MHLW Notification No. 51 of 2026), which also apply from the effective date. Every employer that hires workers is covered, and MHLW’s summary of the amendments states plainly that “all companies are covered.” Unlike the power-harassment prevention measures, which gave SMEs a grace period, there is none this time.

The guidelines define customer harassment by three elements: (1) conduct by customers, etc. in the workplace, (2) that exceeds what is socially acceptable in light of the nature of the work performed by the employer’s workers and other circumstances, and (3) that harms the workers’ working environment — and a case qualifies only when all three are met. “Customers, etc.” include potential customers who may use the service in the future, business counterparties, users of the facility and their families, and even residents near the facility. In accommodation terms, the scope runs from callers inquiring before booking, banquet organizers and travel-agency staff arranging transfers, all the way to neighbors complaining about noise from the property. The guidelines also state explicitly that conduct by telephone or on the internet, such as social media, is included alongside face-to-face conduct, so behavior in OTA messaging tools or review posts is not excluded.

At the same time, the guidelines stress that not every complaint from a customer is harassment: complaints made within what is objectively socially acceptable are “legitimate requests.” A person with a disability expressing a wish for the removal of social barriers is not harassment either, and reasonable accommodation must continue to be provided. The line is drawn on two axes — “the content of the conduct” and “the means and manner” — and a case can qualify even if only one of them goes beyond the acceptable range. Typical examples given in the guidelines include demands for services far beyond the contract or for drastic reductions in the contract price (the content side), and violence, forcing someone to kneel, threats hinting at negative posts on social media, and occupying the premises or tying staff up on the phone for long periods (the means-and-manner side).

Source: Compiled by the HotelBank Editorial Team from MHLW “MHLW Notification No. 51 of 2026” and MHLW “Guide to the Key Amendments on Harassment Countermeasures and the Promotion of Women’s Participation”

All four pillars ask about “organizational systems,” not “individual skill.” Examples of the “response content” that the guidelines ask employers to set out alongside communicating the policy include: workers report immediately to a supervisor and seek instructions; workers are not left to deal with a case alone wherever possible; interactions are recorded on audio or video; if the behavior keeps repeating after a full explanation, the customer is asked to leave or the call is ended once a set amount of time has passed; and conduct that may constitute a crime is reported to the police. These form the skeleton of a property’s response flow as they stand.

Translating the Guidelines into Four Hotel Scenes — Front Desk, Housekeeping, Restaurant & Baths, Non-Face-to-Face

Because the guidelines are written without reference to any industry, putting them into practice requires translating them into a property’s own scenes. In accommodation, the load tends to concentrate in four places: the front desk, with late-night solo shifts and check-in queues; housekeeping, where staff are often one-on-one with guests inside a room; restaurants, where alcohol is involved, and large public baths, where guests are undressed and care is needed; and the faceless channels of telephone, OTA messages and review posts. Table 2 sets out, for each pillar of the guidelines, one line on “what to decide first” in each scene. Our previous article, published in August, covered response design for three frontline settings; this article extends the scope to non-face-to-face channels and the line drawn around contractor staff.

Source: Compiled by the HotelBank Editorial Team based on the measures in MHLW Notification No. 51 of 2026

What Table 2 aims for is a design that moves judgment from the individual to the organization. Rules such as “don’t deal with it inside the room,” “call a second person after a set time” and “read the wording from a template” give less experienced staff the reassurance that “I don’t have to decide this myself.” The guidelines likewise ask employers, both in clarifying the policy and in preventing recurrence, to improve the underlying factors in products, services and customer service, and miscommunication with customers. Building the system and raising the baseline of service quality are two sides of the same task.

The line around contractor and dispatched staff should be made clear here. The guidelines state that for dispatched workers, the client company must also take the four-pillar measures in the same way as for its own workers. Adverse treatment, such as refusing a dispatch contract because a worker consulted, is also prohibited for the client company. By contrast, for conduct experienced at the property by workers employed by another employer, or by sole proprietors — such as employees of a cleaning company — the legal duty to take measures lies with the contractor as the employer, and the guidelines place on the property, as “desirable” efforts, “presenting the same policy as well” and “endeavoring to respond appropriately with reference to the four pillars if consulted.” In other words, the party bearing the duty differs, but the incidents on the floor are the same; opening the policy notices and the consultation desk to contractor staff is the setup most in keeping with the spirit of the guidelines. Conversely, where a property’s own employee has engaged in conduct toward an employee of a business partner, the property has a responsibility to endeavor to cooperate if the other employer asks for help with fact-finding.

Relationship with the Local Ordinances That Came First — What Properties in Ordinance Areas Should Add

Ahead of the national law, ordinances in Tokyo, Hokkaido and Gunma took effect simultaneously on April 1, 2025. Aichi (October 2025), Shizuoka and Tochigi (April 2026) and Saitama (July 2026) followed, and including municipal-level ordinances, the list compiled by the Research Institute for Local Government (RILG) reached 14 local governments as of October 2026 (excluding the ordinance of Mugi Town, Tokushima, which covers municipal staff only; HotelBank Editorial Team count). Figure 1 tracks the cumulative count by effective month: four local governments put ordinances into effect at once in April 2026, showing how ordinances had already spread half a year before the national law took effect.

Source: Compiled by the HotelBank Editorial Team from the Research Institute for Local Government, “Ordinances on the Prevention of Customer Harassment” (as listed in October 2026)

The difference in character between the ordinances and the law is clear-cut. None of the ordinances carries penalties; apart from Kuwana City, Mie Prefecture, which provides for warnings to perpetrators and public disclosure of their names, they are declaratory in nature, and the obligations on businesses stop at best-effort duties (“shall endeavor to”). The Tokyo ordinance squarely prohibits conduct on the customer side — “no person shall engage in customer harassment in any setting” — and places on businesses best-effort duties to ensure workers’ safety and to demand that perpetrators stop. The Gunma ordinance similarly asks businesses to promptly ensure workers’ safety and demand a stop, to provide training and post notices, to respond as an organization with multiple people, and to ask perpetrators to leave or contact the police as needed. The Hokkaido ordinance is structured around the prefecture drawing up and publishing guidelines and setting up a consultation and support system, again without penalties. Notably, the protected “workers” are defined in the ordinances as a broad concept not limited to employees, extending to freelancers and public servants — a wider scope than the law.

Source: Compiled by the HotelBank Editorial Team from each local government’s ordinance and explanatory materials, the Research Institute for Local Government and MHLW materials

So what should properties operating in areas where an ordinance is already in effect add now that the law has taken effect? In short, putting the law’s four pillars in place largely satisfies the ordinances’ obligations on businesses, because the safety assurance, demands to stop, training and organizational response the ordinances ask for are all contained in the guidelines’ “response content,” “after-the-fact response” and “deterrent measures.” On top of that, there are three additions specific to ordinance areas. First, customer-facing notices: because the ordinances place responsibilities and prohibitions on customers as well, citing the ordinance by name in lobby notices and booking-site guidance conveys the employee-protection policy as “a local rule” rather than “the property’s own convenience.” Second, making use of the prefectural consultation desk and guidelines: Tokyo, Gunma and others provide guidelines, manuals and consultation desks for businesses, which can be listed as a secondary contact for the property’s own consultation system. Third, the scope of workers: because “workers” under the ordinances include contractor staff and sole proprietors, it is natural in ordinance areas to make the policy disclosure to contractors — which Section 7 of the guidelines calls “desirable” — standard practice. None of these requires additional capital investment; they are handled by adding to documents and notices.

Implementation Cost by Size — Annual Estimates for 50-, 100- and 200-Room Models (Estimate)

How much does it cost to put the system in place? Here we built up four items — setting up a consultation desk, adding to notices and terms and conditions, creating record forms, and training time — for three model properties of different room counts. The assumptions are as follows. Headcount is the room count divided by 2.02 rooms per worker in the accommodation industry (HotelBank Editorial Team estimate), giving about 25 people for 50 rooms, about 50 for 100 rooms and about 100 for 200 rooms. The hourly cost is ¥1,400 — the FY2026 national weighted-average regional minimum wage of ¥1,177 (the MHLW recommendation was published on September 3, 2026) plus the employer’s share of social charges. Training is assumed at 1.5 hours for all staff plus 3 hours for desk staff in the first year, and 1 hour for all staff in subsequent years plus 1.5 hours for new hires (the hiring rate of 21.2% rounded to 21% of headcount). Documentation and record forms are management hours, notices are actual printing costs, and additions to the terms and conditions are estimated outside-expert review fees. All figures are editorial estimates and will move up or down depending on whether the desk is combined with an existing harassment desk and whether work is outsourced.

Source: HotelBank Editorial Team estimate (rooms per worker from MetroEngines Research aggregation; hourly cost set based on MHLW “FY2026 Regional Minimum Wages”)

Source: HotelBank Editorial Team estimate. Hourly cost ¥1,400; headcount calculated as rooms ÷ 2.02. Outsourcing an external consultation desk would add separate costs

The first-year estimate is about ¥120,000 for 50 rooms, ¥220,000 for 100 rooms and ¥380,000 for 200 rooms. Looking at the breakdown, training labor accounts for around half at every size, while equipment and outsourcing are only a small part. In other words, the bulk of the work is “finding the time,” and by using the Customer Harassment Countermeasures Corporate Manual that MHLW revised in September 2026, along with its leaflets and video materials, almost no hours are needed to create training materials. In ongoing years the cost settles at ¥1,650–1,700 per room per year, nearly constant regardless of size, which works out to less than ¥5 per available room-night (365 days). Even assuming 70% year-round occupancy and spreading it over occupied room-nights, it is just under ¥7. Set against housekeeping labor of ¥640 per room, it is clear how small a place an employee-protection system occupies among operating costs.

This estimate moves with the assumed hourly cost and staffing. Table 5 recalculates the ongoing-year cost for the 100-room model on two axes: hourly cost (¥1,400, ¥1,700 and ¥2,000) and rooms per worker (1.5, 2.02 and 3.0 rooms). Even with heavy staffing (1.5 rooms, about 67 people) and a ¥2,000 hourly cost, the figure is ¥2,802 per room per year, or just under ¥8 per available room-night. Conversely, with lean staffing at 3.0 rooms (about 33 people) and ¥1,400 per hour, it drops to ¥1,360 per year. In every combination, the ongoing burden stays within a range of about ¥1,400–2,800 per room per year.

Source: HotelBank Editorial Team estimate. Training (1 hour for all staff + 1.5 hours for new hires equal to 21% of headcount), consultation-desk operation (4 hours per month) and notice updates (¥8,000) built up the same way as Table 4, varying only hourly cost and headcount. 1.5 and 3.0 rooms are assumed values for sensitivity purposes

Note that properties that already have a consultation desk for power harassment and sexual harassment will need almost no spending on a new desk, since the guidelines acknowledge that “it may be set up together with consultation desks for other forms of harassment.” Outsourcing consultation to an outside organization is also accepted under the guidelines as establishing a consultation desk; for small properties with few managers, building consultation handling into an existing retainer with a labor and social security attorney (sharoushi) or similar advisor is likely the realistic option.

Properties Grow to 98,338 While Separation Rates Run 1.4–1.6x the All-Industry Level — The Retention Upside

Why is this an investment rather than “ticking off an obligation”? The background is the expanding supply of accommodation and the high mobility of its workforce. According to the MHLW “Report on Public Health Administration and Services,” the number of properties licensed under the Inns and Hotels Act stood at 98,338 at the end of FY2024 (end of March 2025), up 4,863 (+5.2%) from the previous year. The breakdown is 52,946 ryokan/hotel operations (+1,908), 44,901 simple lodging operations (+2,992) and 491 boarding-house operations — a net increase of more than 9,000 properties in four years from 89,159 at the end of FY2020 (Figure 2). More properties mean more workplaces, and competition in the hiring market widens further.

Source: Compiled by the HotelBank Editorial Team from MHLW “Overview of the FY2024 Report on Public Health Administration and Services” (published October 21, 2025; as of each fiscal year-end)

People move even faster. In the MHLW “Survey on Employment Trends” for calendar 2024, the hiring rate in accommodations and food services was 21.2% for regular workers and 33.3% for part-time workers, and the separation rate was 18.1% for regular workers and 29.9% for part-time workers. With all-industry separation rates of 11.5% for regular workers and 21.4% for part-time workers, staff in accommodations and food services turn over at 1.6x and 1.4x those levels respectively (Figure 3). Because hiring exceeds separations, employment is growing on a net basis, but a structure in which one in five regular workers and one in three part-timers is replaced each year weighs on both training costs and service quality.

Source: Compiled by the HotelBank Editorial Team from MHLW “Overview of the 2024 Survey on Employment Trends” (published August 26, 2025; calendar 2024)

Looking at the reasons for leaving, the Japan Tourism Agency’s FY2024 “Survey on the Status of Securing and Developing Human Resources in the Accommodation Industry,” published in March 2025 (survey of former employees, N=300), found that “handling many complaints was mentally stressful” ranked high among reasons for leaving the industry at 14.0%, above “I was dissatisfied with my pay” at 11.3%. Improving pay requires funding, but the work of lightening the customer-handling burden through systems can begin at around ¥2,000 per room per year, as Table 4 shows. Set against the estimate that cost per hire runs ¥610,000–1.02 million, preventing even a few departures would recover the implementation cost. This is the basis for positioning customer-harassment measures as “a retention investment that acts directly on one of the main reasons people leave.”

What is easily overlooked is that the system also helps with recruiting. The guidelines note that “it is also effective to communicate and raise awareness among customers, etc.” when clarifying the policy, and it becomes visible externally as lobby notices and booking-site guidance. When job seekers compare employers, the information that “this property states a policy of protecting its employees” can be as concrete a deciding factor as a difference of a few dozen yen in hourly pay. Citing the ordinance by name in ordinance areas serves both purposes as well: deterrence for customers and a message for job seekers.

Summary — The Order to Put Things in Place Now That the Law Is in Force

The duty to take measures is already in force. For properties not yet ready, the quickest route to meeting the requirements takes five steps: (1) put the policy of “responding firmly and protecting employees” and the response content into a single document and communicate it to everyone; (2) designate consultation-desk staff and list them on the shift roster (combining with an existing harassment desk is fine); (3) decide the record form, the “criteria for calling a second person” and the “time criteria for ending an exchange”; (4) set out the response policy for egregious cases (police reports, warning letters, refusing future bookings) and who makes the call; and (5) add privacy protection for those who consult and the ban on adverse treatment to the work rules or code of conduct. Treat dispatched staff the same as your own employees, and open the policy and desk to contractor staff. In ordinance areas, add the ordinance name and a reference to the prefectural consultation desk. Keep the question of whether a stay can be refused separate, as an issue under the Inns and Hotels Act and Article 5 of the terms and conditions.

The estimated cost is about ¥120,000 for 50 rooms, ¥220,000 for 100 rooms and ¥380,000 for 200 rooms in the first year, and ¥1,650–1,700 per room per year thereafter — small among operating costs. In an industry where 98,338 properties compete for staff and 18.1% of regular workers and 29.9% of part-timers turn over each year, properties that put employee-protection systems in place first will begin to pull ahead in both retention and recruiting. Even now, past the effective date, there is plenty of value left in getting it done.

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