On October 1, 2026, the amended Labour Policy Comprehensive Promotion Act came into force, making measures against customer harassment mandatory for employers, including companies and other organisations. Workplaces that deal with customers or business partners over the phone are also covered.
Now that the new requirements are in force, how should companies handle customer harassment over the phone, and what role does call recording play?
The basic approach is to first understand the caller’s complaint, then escalate the call to a manager when problematic behaviour occurs, and have procedures in place to end the call when necessary. Call recordings provide a record of what was actually said and how the interaction developed, supporting later fact-finding and decision-making.
Source: Ministry of Health, Labour and Welfare, Prevention of Harassment in the Workplace
What Customer Harassment Measures Became Mandatory in October 2026?
The Ministry of Health, Labour and Welfare guidance groups the main measures employers are required to take into five areas.
- Communicating company policy and response procedures: Establish a clear policy of responding firmly to customer harassment and protecting employees, and make sure employees understand what to do when an incident occurs.
- Establishing a consultation system: Decide in advance where employees can seek advice and ensure that the people receiving consultations can respond appropriately.
- Responding after an incident: Confirm the facts promptly, support affected employees, and take measures to prevent recurrence.
- Preparing for serious cases: Establish policies for particularly serious behaviour and create a system capable of putting those policies into practice.
- Protecting privacy and employees who report incidents: Protect the privacy of those involved and prevent employees from being treated unfavourably because they reported an incident or assisted with fact-finding.
It is not enough simply to publish a policy. Companies also need to decide what happens after an employee reports a problem. In a telephone-based workplace, this means defining how staff contact a manager and how calls are escalated or transferred.
Source: Ministry of Health, Labour and Welfare, Customer Harassment Prevention Guidelines, Section 4
The Difference Between Local Customer Harassment Ordinances and National Law
Separate from national legislation, some local governments have introduced their own customer harassment ordinances. Tokyo’s ordinance took effect on April 1, 2025, while Saitama Prefecture’s took effect on July 1, 2026.
The nationwide obligation to implement preventive measures applies to employers regardless of whether their local government has introduced its own ordinance. Local ordinances may contain their own provisions, including differences in who is covered, so businesses should also check the rules and guidance that apply in the areas where they operate.
What Counts as Customer Harassment Over the Phone? The Difference From a Legitimate Complaint
Not every complaint or strongly worded opinion made over the phone qualifies as customer harassment. Under the Ministry of Health, Labour and Welfare definition, all three of the following conditions must be met:
- The conduct comes from a customer, business partner, facility user, or another person connected with the business.
- Considering the nature of the work and the circumstances, the conduct goes beyond what is socially acceptable.
- The conduct harms the employee’s working environment.
This can include calls from business partners as well as calls from ordinary consumers.
Examples of problematic telephone behaviour can include personal abuse or insults, threats to cause harm, unjustified demands for compensation, and persistent repeat calls. Long calls may also become relevant depending on the content of the discussion, whether the conversation is progressing, how frequently the person contacts the business, and the impact on normal operations.
If there is a genuine problem with a product or service and the customer is asking for an explanation or remedy within reasonable limits, the matter should be handled as a legitimate complaint.
However, even where the underlying request itself is reasonable, the way it is made may amount to customer harassment if it involves conduct such as threats or severe personal abuse.
Similarly, asking for reasonable accommodation related to a disability is not in itself customer harassment. Businesses should not make decisions based solely on a person’s tone of voice or the length of a call. The content of the request, the way the person behaves, and the circumstances leading up to the interaction all need to be considered.
Source: Ministry of Health, Labour and Welfare, Customer Harassment Prevention Guidelines, Section 2
If employees currently use their personal mobile numbers for customer calls, it’s also worth reviewing the risks of using personal phone numbers for business and considering keeping business and personal calls separate.
How Should Companies Handle Customer Harassment Calls? Response Procedures and What to Say
The following is an example of how a company can turn its overall policy into a practical telephone response procedure.
If a caller makes threats or engages in other behavior that creates a significant safety concern, completing the normal process should not take priority. The employee should move directly to contacting a manager and protecting their safety.
Confirm the Facts and What the Caller Wants
First, establish what happened and what the caller is asking the company to do.
Check previous interactions, order information, contracts, or other relevant records. If the company made an error, acknowledge that specific issue and explain how it will be addressed.
Example:
“Let me confirm the issue. Your order has not arrived, and you would like us to check the delivery status. Is that correct?”
If the caller changes their request during the conversation, summarise the issue again. If something cannot be confirmed immediately, explain that it needs to be investigated.
Explain What the Company Can Do and Why
Based on the facts available, explain what the company can do and why certain requests cannot be accepted.
Employees should avoid promising compensation beyond their authority or giving deadlines that have not yet been confirmed.
Example:
“We can arrange a replacement. However, I cannot promise the compensation you have requested at this stage. We will confirm the details and get back to you.”
If the company needs to respond later, establish who will follow up, how they will contact the customer, and a realistic timeframe.
Report Problematic Behavior to a Manager
If abusive language or unreasonable demands continue, the employee should follow the company’s reporting criteria and consult a manager.
When escalating the call, staff should share the caller’s request, what has already been explained, and the behaviour or statements that caused concern. This reduces the need for both the caller and employee to repeat the entire conversation.
Example wording when transferring the matter:
“I will share the situation with the manager responsible and transfer the matter to them. Please hold for a moment.”
Companies should also establish what employees should do when a manager is unavailable and under what circumstances an employee may end a call.
The next section explains criteria for ending a call and sample warning language.
When reviewing how staff escalate difficult calls, explore CIRCLE Mobile’s hold and transfer features. An attended transfer lets employees explain the situation to a manager before passing the call over.
Record the Incident After the Call and Support the Employee
Record the date and time, information about the caller, the problematic conduct, how the company responded, and any decisions made by a manager.
If a recording exists, include enough information to identify the relevant call and decide who will handle any future contact from the same person.
The company should also check on the affected employee. Depending on the circumstances, appropriate action may include temporarily removing them from phone duties, changing the contact person for future communication, or providing access to consultation and mental or physical health support.
Even where no call recording exists, fact-finding can continue using the employee’s account, notes, and information from other staff members who were involved.
Can You Terminate a Customer Harassment Call? Criteria for Ending the Conversation
Employees are not required to remain on a customer harassment call indefinitely.
The Ministry of Health, Labour and Welfare guidance gives ending a telephone call after a certain period as one possible response where the company has provided sufficient explanation but the same demands continue to be repeated.
However, there is no nationwide rule saying that a company may automatically end a call after a specific number of minutes.
Businesses should establish their own escalation and call termination criteria based on situations such as:
- Abusive or personally insulting comments continue even after the caller has been warned.
- Unreasonable demands continue even after the company has explained why they cannot be accepted.
- The company has provided sufficient explanation, the conversation is no longer progressing, and the length of the call is interfering with normal operations.
If a company uses a time threshold, it should function as a prompt to review the situation rather than an automatic cutoff.
For example, a long call caused by the company asking the customer to wait while information is being checked should not be treated the same way as a prolonged call involving repeated unreasonable demands.
How to Respond: Warnings and Ending the Call
During normal handling, identify the behaviour that needs to stop and explain that the call will be ended if it continues.
The following examples should be adjusted to match the company’s own policy and the circumstances of the call.
| Situation | What to Say |
|---|---|
| Abusive language continues | "We will continue to address your enquiry, but please refrain from making insulting comments about our staff. If this continues, we will end this call." |
| A request that has already been addressed keeps being repeated | "We have already explained why we cannot meet that request. If the same discussion continues, we will end today's call." |
| Abusive language continues after a warning | "We previously asked you to stop making those comments. As the same behaviour has continued, we are now ending this call." |
Where a caller makes threats of harm or engages in other conduct that may constitute a criminal offence, the company should prioritise employee safety rather than rigidly following its normal warning procedure or call-duration criteria. The matter should be escalated to a manager or the police where appropriate.
If legal action may be required, the company should also involve its legal department or an external lawyer.
Businesses operating in sectors with specific legal duties to provide services, or where interruption could affect life or health, should also take those obligations into account when establishing their response procedures.
Benefits of Using Call Recording for Customer Harassment Measures
The October 2026 customer harassment requirements do not make call recording mandatory for every company.
Recording is one practical tool that businesses can use to establish what happened during a telephone interaction.
If a recording exists, the company can review the exact words used, the caller’s tone, repeated demands, and the explanations provided by the employee.
This provides information beyond the employee’s own account. It also allows the company to examine the customer’s claims and its own response, giving managers a clearer basis for assessing both sides of the incident.
Managers can use the recording when deciding how to respond to the customer, whether future contact should be handled by a different person or department, and whether external advice or escalation is required.
Recordings can also be used when reviewing an incident internally. The business can consider whether explanations were sufficient, whether the call should have been escalated earlier, and whether procedures or training should be improved.
The Ministry of Health, Labour and Welfare guidance also identifies recordings and video as forms of objective evidence that can be checked when establishing the facts of an incident.
When introducing recording, businesses should therefore decide not only which calls will be recorded, but also who will review problematic calls and who has authority to make decisions after an incident.
Find the Right Call Recording Solution for Your Business
Do You Need to Tell Callers That Calls Are Being Recorded? Purpose of Use and Recording Management
According to Japan’s Personal Information Protection Commission, if the content of a telephone conversation can identify a particular individual, that content constitutes personal information.
In such cases, the Act on the Protection of Personal Information requires the company to notify the individual of the purpose of use or publicly disclose that purpose.
However, the Act does not itself require a business to tell the caller during every telephone conversation that the call is being recorded.
Source: Personal Information Protection Commission, Q&A on Recording Telephone Conversations, Q1-10
Include Customer Harassment Fact-Finding in the Stated Purpose of Use
If recordings are used not only to improve service quality but also to establish the facts of disputes or customer harassment incidents, the stated purpose of use should make that clear.
MHLW guidance gives publication in a privacy policy as one example. It notes that the information can be made available on a page that users can reach from the company’s homepage with approximately one click.
Example wording for an announcement at the beginning of a call:
“This call will be recorded for the purpose of improving customer service quality and confirming the facts in the event of a dispute.”
The wording used in recorded announcements and privacy policies should reflect how the business actually intends to use the recordings.
Establish Rules for Access, Retention and Sharing
When operating a call recording system, businesses should define rules covering the following areas.
- Access permissions: Decide who may play, download or delete recordings, and review those permissions when employees change roles or leave the company.
- Retention periods: Establish retention and deletion periods based on the purpose for which recordings are used, and check the system’s automatic deletion settings.
- Preservation of recordings related to active incidents: If an investigation or response is still ongoing, determine whether the recording needs to be preserved before normal deletion occurs and manage the subsequent retention period.
- Sharing: Establish who can approve internal or external sharing, how recordings may be shared, and limit access to what is necessary after confirming that the sharing is lawful.
A service provider’s standard retention period will not necessarily match the period an individual company needs.
Businesses should therefore consider not only how long recordings can be retained, but also whether important recordings can be preserved when necessary and whether information that is no longer needed can be deleted appropriately.
Telephone Customer Harassment Checklist
Use the following checklist to confirm whether the systems your company has introduced can actually be used by employees in day-to-day operations.
| Check | Checklist Item |
|---|---|
| Employees understand the company's basic customer harassment policy and assessment criteria. | |
| Consultation channels and methods for contacting managers have been defined, including what to do when the manager is unavailable. | |
| Staff have been given criteria and sample wording for warnings, escalation and ending a call. | |
| Internal and external escalation contacts have been established for serious cases such as threats. | |
| Call content and response history can be recorded and reviewed when necessary. | |
| Where calls are recorded, rules have been established covering the purpose of use, access permissions, retention and deletion. | |
| The company can provide support for affected employees and decide who will handle subsequent contact with the customer. | |
| The privacy of people who report incidents is protected and employees are not treated unfavourably because they raised a concern. | |
| Incidents are reviewed and used to improve response procedures and training. |
To review call volumes, response rates, and staffing needs, explore CIRCLE Call Reporting (CCR) for a clearer view of your team’s workload.
Support Telephone Customer Harassment Measures With CIRCLE Call Recording
CIRCLE offers CVR Call Recording as a paid option for its cloud PBX service.
Incoming and outgoing calls can be recorded automatically and reviewed through a dedicated cloud portal.
| Feature | How it can be used for customer harassment response |
|---|---|
| Automatic recording and configurable recording targets | Record calls for selected numbers or departments without relying on employees to manually start recording. |
| Search by date and phone number | Locate the relevant call using the reported date, time or caller's telephone number. |
| Playback and download | Review what was actually said and preserve recordings relating to ongoing cases in accordance with company rules. |
| Organisational access control | Manage which employees or administrators are authorised to review recordings. |
There is no limit on recording duration and recordings are retained for 180 days. (See: Pricing)
Under the basic fee, one administrator can review recordings through a browser. Companies should confirm the appropriate setup and cost based on the number of users who need access and their internal review procedures.
If you are considering call recording as part of your telephone customer harassment measures, contact CIRCLE to discuss your current telephone environment, which numbers or departments should be recorded, and who needs access to recordings.
