September 15, 2025
TOKYO – The government’s new system to protect children from sex crimes is expected to regulate up to 230,000 organizations, including kids cafeterias, talent agencies and schools, according to a draft from the Children and Families Agency.
It remains to be seen how widely the system will be adopted, given concerns about its requirements for strictly managing sensitive information and the risk of lawsuits.
The system — called the Japanese version of Britain’s Disclosure and Barring Service (DBS) — allows education-related groups to refer to a Justice Ministry database and check the sex crime history of people working in jobs that involve children.
Japan’s version of DBS was included in a law to protect children from sexual predators, which was enacted in June 2024.
Peace of mind
“Just doing interviews, it’s hard to determine that someone has a history of sexual offenses,” said a 60-year-old man who represents a group running a kids cafeteria in Sagamihara, Kanagawa Prefecture. “DBS would be big for us.”
At his cafeteria, locals and university students register as volunteers, providing free meals to elementary and junior high school students while also helping them with their studies.
He plans to adopt the DBS system as it will “provide parents and guardians with feelings of trust and security.”
At its meeting on Friday, the Children and Families Agency presented an interim summary outlining the guidelines for implementing the system.
The system will be mandatory for schools and childcare facilities overseen by municipalities, while private businesses can decide if they want join (they will need to get certified by the government first). According to the agency’s draft, private organizations that may join include cram schools, swimming clubs, kids cafeterias that provide study support, talent agencies offering dance lessons and operators of overnight summer or winter ski camps.
The agency decided on who would be covered by the system based on three criteria: dominance, continuity and opaqueness. Dominance refers to positions of power, such as in instructing children. Continuity indexes the length of time that organizations maintain close relationships with children. Opaqueness measures how difficult it is for parents and guardians to monitor the situation. The agency estimates that the number of organizations covered, including schools that must use the system, could reach 230,000.
“We want to cast as wide a net as possible, so that we can block people who have a history of sex crimes from ending up in these places,” an agency official said.
Handling sensitive information
But adoption could be hampered by the strict information management required and the risk of lawsuits.
Organizations will need to handle sensitive information like histories of sexual offenses. This will require strict data management, and misuse of the data could lead to criminal penalties.
“I think we should use DBS, but I’m not sure if we can handle criminal records appropriately,” said an official from a Tokyo-based talent agency. “The barrier is especially high for businesses with few staff.”
Then there is the question of what organizations should do if they discover that they are employing a past offender. Dismissals “lacking reasonable grounds and not socially acceptable” are considered rights abuses and are invalid under the Labor Contract Law.
The agency’s draft says that organizations should reassign employees with criminal records to jobs not involving children or consider dismissing them if that proves difficult. It adds that a criminal record would be a “significant factor” in determining the validity of a dismissal if there is a lawsuit, but it ultimately leaves the final judgment to the courts. This leaves room for organizations to be sued.
Certification mark
The DBS system is set to launch on Dec. 25, 2026. To promote its adoption, the agency plans to create a certification mark for participating organizations so that their efforts will be publicly recognized. A consultation window will be established where small organizations can seek advice from lawyers about firing employees.
“It means a great deal that the country is tackling sexual violence against children,” said Nihon University Prof. Kaori Suetomi, an expert on DBS. “In the United Kingdom, where this was pioneered, it took over ten years from the system’s launch to build a meticulously detailed framework. Japan must also refine its approach, such as by making the system easier for organizations to adopt.”