In December 2025, Japan revised its National Action Plan on Business and Human Rights (2020–2025) (the “NAP”). The revised NAP outlines the government’s future policies and measures across eight priority areas relating to business and human rights. Also set out is the government’s expectation that Japanese companies, regardless of their size or industry, will make every effort to respect internationally recognized human rights, in accordance with the UN Guiding Principles on Business and Human Rights (the “UNGPs”) and other relevant international standards. This article outlines the key points of the revised NAP, focusing on matters relevant to disability welfare.

Background to the Development of the NAP

In October 2020, Japan adopted the National Action Plan on Business and Human Rights (2020–2025) (the “Previous NAP”) in response to growing international awareness of the principles of business and human rights. The Previous NAP aimed to promote understanding of and raise awareness of business and human rights among Japanese companies, as well as to encourage companies to strengthen their efforts in this area, both individually and across business relationships. Since its adoption, the Previous NAP has led to several key developments, including:

• September 2022: Publication of the Guidelines on Respecting Human Rights in Responsible Supply Chains, etc.
• April 2023: Adoption of the government policy on Human Rights Considerations in Public Procurement
• April 2023: Publication of the Practical Reference Materials
• December 2023: Publication of the Guidance for Food Companies on Efforts to Respect Human Rights
• October 2024: Publication of the Business and Human Rights at Work Checklist

In May 2024, the Inter-Ministerial Liaison Committee on the National Action Plan on Business and Human Rights (the “Liaison Committee”) approved the commencement of the revision process. Following dialogue with stakeholders through the Roundtable Meeting for the Promotion of the National Action Plan on Business and Human Rights (the “Roundtable Meeting”) and its Working Group, as well as a public consultation, the revised NAP was approved by the Liaison Committee on December 24, 2025.

Objectives of the NAP

The Previous NAP identified four objectives for the development and implementation of the action plan, all of which have been retained in the revised NAP:

1.　Protecting and promoting human rights throughout society, including in the international community;
2.　Ensuring consistency across policies relating to business and human rights;
3.　Securing and enhancing the international competitiveness and sustainability of Japanese companies; and
4.　Contributing to the achievement of the Sustainable Development Goals (SDGs).

The revised NAP also emphasizes the importance of recognizing corporate efforts to respect human rights as actions that can contribute to companies’ sustainable and stable growth.

Reorganization into Eight Priority Areas

The Previous NAP organized relevant measures under three pillars of the UNGPs: the State duty to protect human rights, the corporate responsibility to respect human rights, and access to remedy. The revised NAP takes a cross-cutting approach, bringing together measures that were previously addressed individually or in connection with one another, and reorganizes them into eight priority areas.

For each area, it sets out the issues identified and measures taken to date, as well as the direction of future efforts and examples of specific measures. The key directions for each priority area are summarized below.

Source: Ministry of Foreign Affairs of Japan, Summary of the National Action Plan on Business and Human Rights (Revised Edition) (December 2025).

Promoting Measures for Persons with Disabilities

One of the eight priority areas is promoting measures to ensure that “no one is left behind.” The direction of efforts in this area calls for the design, implementation and review of systems that take into account the circumstances of rights holders, including persons with disabilities. The key issues identified and measures taken to date, as well as the future direction of efforts and examples of specific measures relating to persons with disabilities, are summarized below.

Issues Identified and Measures Taken to Date

Based on the principles of the Basic Act for Persons with Disabilities, the Japanese government has worked to create an inclusive society in which people can live together regardless of whether they have disabilities. Amendments to the Act for Eliminating Discrimination against Persons with Disabilities, which took effect in April 2024, made the provision of reasonable accommodation mandatory for private businesses as well. However, human rights risks remain, including inadequate access to information and physical environments, discrimination in recruitment and promotion, harassment, and unfair dismissal. Challenges also remain in ensuring understanding of and appropriate accommodation for less visible disabilities, particularly mental and developmental disabilities.

Creating an environment in which persons with disabilities can fully exercise their abilities is important to enabling them to live independently with a high quality of life. The government has therefore been working to secure employment opportunities and train support personnel.

Under the Act on Employment Promotion, etc. of Persons with Disabilities, employers are prohibited from discriminating against persons with disabilities and are required to provide reasonable accommodation. Amendments that took effect in April 2023 also clarified employers’ responsibilities to take measures to develop and improve the vocational skills of employees with disabilities.

Hello Work (public employment security offices) provides consultation services to both employers and workers, while prefectural labor bureaus offer assistance in resolving disputes and provide mediation procedures. These efforts have contributed to an increase in the number of employed persons with disabilities for 22 consecutive years, as well as an increase in the number of small and medium-sized enterprises recognized for their exemplary employment practices.

Direction of Efforts and Examples of Specific Measures

1. Designing, implementing and reviewing systems from a human rights protection perspective to ensure that “no one is left behind”

• Implementing measures in connection with amendments to the Act for Eliminating Discrimination against Persons with Disabilities, the Act on Employment Promotion, etc. of Persons with Disabilities and other relevant legislation;
• Providing continuous employment support before and after hiring through cooperation among relevant local organizations;
• Providing integrated support for both work and daily life by combining employment and welfare measures, including pensions, allowances, tax benefits and other support schemes;
• Promoting “barrier-free minds” initiatives under the Action Plan for Realizing an Inclusive Society Free from Prejudice and Discrimination against Persons with Disabilities;
• Promoting the provision of reasonable accommodation by the Japan Legal Support Center (Houterasu); and
• Providing subsidies to companies for improvements to workplace environments.

2. Providing information and good practices to help identify human rights risks and promote respect for human rights

• Examples of measures include implementing measures in connection with amendments to the Act for Eliminating Discrimination against Persons with Disabilities, the Act on Employment Promotion, etc. of Persons with Disabilities and other relevant legislation.

Government Expectations for Businesses

The revised NAP sets out the government’s expectation that all Japanese companies, regardless of size or industry, will respect internationally recognized human rights and make every effort to implement measures to respect human rights. This expectation takes into account potential gaps between international standards and the laws and regulations of the countries in which Japanese companies operate (governance gaps), and is based on the premise that human rights risks can arise in any business.

Specifically, companies are expected to take the following three steps:

At each step, companies are encouraged to make use of resources developed since the adoption of the Previous NAP, including the relevant guidelines, practical reference materials, sector-specific guidance and collections of good corporate practices.

Schedule and Implementation Framework

The revised NAP took effect at the start of fiscal year 2026 (April 2026). The need for further revision will be assessed approximately five years after its publication. The Liaison Committee will review the implementation status of each ministry and agency annually, with efforts to use objective performance indicators wherever possible. The Roundtable Meeting and its Working Group will also continue to provide opportunities for dialogue with stakeholders.

We will continue to provide updates on further developments in this area through this blog.

Related Resources

• Cabinet Secretariat: [Inter-Ministerial Liaison Committee on the Promotion and Coordination of Measures for Implementing the National Action Plan on Business and Human Rights]
• Ministry of Justice: [National Action Plan on Business and Human Rights]
• Ministry of Foreign Affairs: [Business and Human Rights]
• Ministry of Economy, Trade and Industry: [Business and Human Rights: Toward Responsible Value Chains]
• Ministry of Health, Labour and Welfare: [Business and Human Rights: Toward Responsible Global Supply Chains]
• Ministry of Agriculture, Forestry and Fisheries: [Business and Human Rights]

For more articles in our Disability Welfare blog series, please visit the series index page.