On June 19, 2024, Japan enacted the Act on Measures to Prevent Child‑Targeted Sexual Violence by School Operators and Private Education/Childcare Providers, commonly referred to as the "Japanese DBS Act" or the "Child Sexual Violence Prevention Act." The "DBS" shorthand is used to describe a Japan‑specific screening and safeguarding framework that is inspired by the United Kingdom’s Disclosure and Barring Service ("DBS") regime.

The Japanese DBS Act requires (1) school operators (both public and private), and (2) private education/childcare providers that voluntarily obtain government certification, to implement enhanced safeguarding measures. These measures include screening for specified sexual‑offence convictions through a centralized criminal‑record confirmation process. Under the Act, the competent authority issues a confirmation certificate covering prescribed look‑back periods (up to 20 years in certain cases) and provides procedural protections for the individual, including advance notice and an opportunity to request corrections.

The Japanese DBS Act will come into effect on December 25, 2026, and the relevant guidelines have already been published. Organizations potentially within its scope should therefore assess, as part of their compliance and risk planning, whether to pursue certification and how to prepare for operational implementation.

A key consideration for many clients is the breadth of businesses that may fall within the voluntary certification regime. In addition to cram schools ("juku"), "private education/childcare providers" can encompass a wide range of lesson‑based services that teach children skills or knowledge through in‑person instruction, e.g., preparatory schools, children’s swimming and gymnastic clubs, and other training academies. In practice, this may capture international schools, English conversation classes ("eikaiwa"), and many extracurricular programs. Although certification is not mandatory, it can function as an externally verifiable signal of child‑safety and may offer commercial advantages, including public listing and the ability to state certification status in advertising. Over time, certification may become a meaningful differentiator in the education and childcare market.

From an operational perspective, certified organizations (and schools) will need end‑to‑end procedures for (i) screening at the hiring stage, (ii) periodic re‑screening, and (iii) screening of existing staff within statutory transitional timeframes, together with strict data‑governance and information‑security controls for highly sensitive information. Where a conviction and/or other risk indicators are identified, organizations must be prepared to take "necessary measures" to protect children, steps that can raise sensitive employment‑law issues, including reassignment, role restrictions, disciplinary action, and, in some cases, termination of employment.

With reports that many major operators are considering certification, organizations that choose not to apply should also consider whether that decision could lead to a material competitive disadvantage. Upon the Japanese DBS Act coming into effect, incidents of sexual violence against children by employees may present heightened legal, operational, and reputational risks. In particular, a decision not to obtain certification, or a failure to comply with applicable obligations, may attract increased public scrutiny. At the same time, any mishandling or leakages of highly sensitive information, such as criminal‑record data, could itself cause serious legal and reputational harm. Organizations should therefore weigh the trust and marketing benefits of certification against the burdens of obtaining and maintaining it, and make a deliberate decision on whether to pursue certification.