[2026 Latest] Ensuring Objective Records and Compliance with the Industrial Safety and Health Act through Facial Recognition

As work styles continue to diversify, many companies are facing a major hurdle: accurately tracking working hours. Since the amendment of the Industrial Safety and Health Act, it is now mandatory to record the working hours of all employees—including those in managerial and supervisory positions—using objective methods. In our consulting experience, we still see many cases where companies rely on self-reporting, resulting in records that are disconnected from reality. The solution to fundamentally eliminating these compliance risks and driving DX (Digital Transformation) in labor management is facial recognition cloud-based attendance systems. This article explores the latest labor management techniques for achieving both legal compliance and operational efficiency.

A clean, modern office entrance. A small authentication terminal is mounted on the wall, its screen displaying scanning grid lines and a Japanese message reading "Authentication Complete." In the foreground, a reception counter holds a plain visitor slip with no specific proper nouns and a Japanese visitor log with a space for seals. Soft afternoon natural light streams through the window, vividly illuminating the greenery of indoor plants in a realistic business scene.

1. The True Nature of "Objective Records" Required by the Industrial Safety and Health Act

Currently, companies are required to manage working hours based on objective records such as time cards, IC cards, and computer logs, in accordance with the "Guidelines on Measures to be Taken by Employers for the Proper Monitoring of Working Hours." In our consulting practice, we often encounter management teams who mistakenly believe that records are not required for those under discretionary work systems or in managerial positions. However, under the Industrial Safety and Health Act, "all workers" are covered from the perspective of health management.

Figure: Adoption trends of working hour tracking methods among Japanese companies (2026 Forecast)

As statistical data shows, the transition from self-reporting to biometric authentication is accelerating. This is not merely to improve the convenience of clocking in, but primarily to avoid legal risks arising from "impersonation" or "forgetting to clock in." Even in the context of in-house EC development and growth support, facial recognition is proving highly effective for managing the working hours of employees who do not use PCs, such as logistics warehouse and retail store staff.

2. Limitations of Self-Reporting Systems and Why Facial Recognition is Chosen

A common issue in the workplace is "hidden overtime," where employees underreport their hours to minimize overtime pay. With self-reporting systems, companies can no longer get away with claiming they "didn't know the actual situation." By implementing a facial recognition cloud attendance system, clocking in is completed within 0.3 seconds just by standing in front of the device, and the data is stored in the cloud in a tamper-proof format.

A Japanese data analyst in a shared office space, holding a tablet and reviewing an attendance data dashboard. The screen clearly displays a line graph of individual monthly working hour trends and a red warning icon for an Article 36 Agreement violation alert. The analyst is focused intently on the screen in a clean, organized environment featuring plain file boxes without any specific branding.

The greatest advantage of facial recognition is that it is "contactless" and "keyless." With no risk of lost or shared IC cards, even team members busy with proprietary EC site development and growth support projects can maintain accurate records without stress. This frees administrators from end-of-month tallying tasks, allowing them to focus on checking for anomalies.

3. Strengthening Compliance Systems Through Labor DX

The goal of HR/Labor DX is not merely digitization, but "proactive prevention" through the utilization of collected data. Real-time working hour data captured via facial recognition can be configured to automatically notify both the employee and their supervisor the moment a threshold is about to be exceeded. In our actual consulting engagements, we have seen cases where implementing this "predictive management" framework reduced the risk of health issues and legal citations resulting from excessive overtime by more than 80%.

A laptop screen on a table in a bright conference room. Labor management software in Japanese is open, displaying a list of all employees' attendance status. A specific row is highlighted in orange, showing the status "Break Not Taken" in Japanese. In the background, a Japanese manager is seen working intently, cross-referencing a paper shift schedule with the screen.

Furthermore, as a cloud-based solution, it enables centralized management of staff movements across remote locations, satellite offices, and even between different stores. The ability to maintain meticulous management oversight while accommodating diverse work styles is precisely why facial recognition has become indispensable in modern corporate management.

4. Common Challenges and Steps to Resolution at Implementation Sites

Key concerns during implementation include privacy considerations and the preparation of the network environment. In on-site support, we begin by carefully explaining security specifications to employees—for instance, that "facial data is stored as numerical feature values, and the images themselves are discarded." Additionally, it is crucial to design the system to prevent missed records due to connectivity issues by selecting terminals that allow for offline time-stamping. By following these steps diligently, you can minimize resistance on the ground and ensure a smooth transition to full operation.

FAQ

Q. Is authentication possible while wearing a mask?
A. Yes, facial recognition terminals equipped with the latest AI algorithms can identify individuals with high accuracy even when they are wearing masks or glasses.
Q. When the Labor Standards Inspection Office conducts an inspection, can facial recognition data be used as evidence?
A. Yes, it does. Since time recording via facial recognition is recognized as a "record by an objective method," it serves as more reliable evidentiary material than a self-reporting system.
Q. How much are the implementation costs?
A. For cloud-based systems, in addition to initial costs (such as device fees), running costs of around several hundred yen per user per month are typical. These costs can be easily recovered through the savings gained by reducing manual tabulation work.

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Summary

Properly tracking working hours is no longer just a best-effort obligation for companies; it is a management priority directly linked to legal risks. Implementing facial recognition cloud-based attendance systems provides convenience for employees and peace of mind regarding compliance for management. If you are concerned about self-reporting systems becoming a mere formality, you should take the first step toward ensuring thorough objective recording today. By leveraging digital technology, let's shift from defensive labor management to proactive organizational development.

Published: October 9, 2026 / By: Osamu Yasuda

WRITTEN BY
Osamu Yasuda

Osamu Yasuda

Senior Managing Director & COO

Meets Consulting Inc.

Supported 100+ EC operations & logistics projects; specialist in operations and cost optimization

References

  • [1] Ministry of Health, Labour and Welfare: Guidelines on Measures to be Taken by Employers for the Proper Monitoring of Working Hours
  • [2] Industrial Safety and Health Act, Article 66-8-3 (Recording of Working Hours)
Disclaimer: This article is for informational purposes only and is not intended as a substitute for professional legal or labor relations advice. For specific implementation, please consult with a professional such as a certified social insurance and labor consultant.