Japan's Comprehensive Support Act for Persons with Disabilities — Two Years into the Operational Phase
Two years after the April 2024 enforcement of revisions to Japan's Comprehensive Support Act for Persons with Disabilities and Employment Promotion Act. A structural analysis of the gap between policy design and field implementation across service fee revisions, self-reliance medical care, employment quotas, and home-based care benefits.
TL;DR
- The April 2024 revised Comprehensive Support Act made community living support hubs a municipal responsibility, introduced employment-choice support, and strengthened the role of base consultation support centers, presenting a formally comprehensive reform
- Two years into operation, however, the closure of 329 Type-A continuous employment support offices (with roughly 5,000 layoffs in five months), functional disparities at community living support hubs, and group home supply-demand mismatches have become visible
- The fragmentation of welfare services into more than 30 categories, the time lag between deinstitutionalization-centered policy design and infrastructure readiness, and the intergenerational gaps embedded in the "Article 65 problem" and "8050 problem" remain outside the scope of the revision
- The legal employment quota was raised to 2.5% for private companies in April 2024, but the share of compliant companies dropped to 46.0% (down 4.1 points year-on-year), widening the gap between quota targets and field response
What Is Happening
Five operational distortions visible two years after the April 2024 enforcement
The revised Comprehensive Support Act for Persons with Disabilities (formally the Act Partially Amending the Act for Comprehensive Support for the Daily and Social Lives of Persons with Disabilities and Other Laws), enacted in December 2022 and brought into force in April 2024, has reached the two-year mark of operation. As of April 2026, multiple operational distortions have become visible.
The revision rests on six pillars: (1) strengthening community living support for persons with disabilities, (2) improving the quality of employment support and disability employment, (3) developing support systems for persons with mental disabilities, (4) supporting medical and recuperative life for persons with intractable diseases, (5) developing databases on persons with disabilities and intractable diseases, and (6) other measures. The policy framework that MHLW's disability welfare department publishes is comprehensive on paper. What the operational phase has revealed, however, is a different picture.
Mass closure of Type-A continuous employment support offices. Between March and September 2024, in just five months, 329 Type-A offices closed, and approximately 5,000 people with disabilities experienced layoffs or forced departures. Of the 9,312 disability-related layoffs Hello Work tracked in FY2024, 7,292 (approximately 80%) were Type-A users. The cause was the FY2024 fee revision, which tightened the scoring of productive activity revenue. Previously, some offices supplemented wages from self-reliance subsidies even when productive activities ran at a loss; the revision targeted this practice, but the result was that weaker offices were eliminated at once. The "quality improvement" framed in the revised law paradoxically arrived alongside the layoffs of the very people it was meant to support.
The suspended operational design of employment-choice support. Employment-choice support, which was to be enacted by cabinet order within three years of promulgation, came into force on October 1, 2025. It targets people newly seeking work-related disability welfare services (employment transition support and Type-A/B continuous employment support) as well as existing users. The program conducts an employment assessment lasting one month (up to two months) in principle. Provider offices must meet the requirement of "having placed three or more users in regular employment within the past three years."
The intent is to "match employment to the individual's wishes and capacity." But three operational issues have emerged: (a) the training of assessors has not kept pace with demand, (b) one month is effectively insufficient for matching judgments, and (c) small rural offices that cannot meet the "track record requirement" cannot implement the program, widening regional disparities.
Uneven progress in establishing community living support hubs. The revised law made community living support hubs a municipal responsibility (effort-based obligation) from April 2024. Of the 1,741 municipalities nationwide, 1,425 (including joint establishments) plan to complete establishment within the 6th Disability Welfare Plan period. The 82% figure looks high, but the substance of "established" varies widely. Among the five required functions (coordinator placement, 24-hour emergency response, short-stay reception, group home and trial-use opportunities, consultation support network), the number of municipalities with multiple functions actually operating is limited, as training materials from the National Rehabilitation Center's FY2025 training materials have noted.
The government target of completing nationwide establishment by the end of FY2026 cannot be met unless formal establishment is distinguished from functional reality. The gap between "numerical clearance" and "functional substance" becomes the next point of debate.
Structural distortions in group home supply. A survey of 47 prefectures and 696 municipalities by NHK revealed that the total waitlist for residential facilities and group homes reaches approximately 22,000 people. Meanwhile, "daytime service support" group homes have grown rapidly (56.8% increase from 2021 to 2022, 37.8% from 2022 to 2023), and MHLW indicated in December 2025 that it would add group homes to the targets of total-quantity regulation.
The supply-demand mismatch has a dual structure. Group homes for persons with severe physical, intellectual, or psychiatric disabilities, strong behavioral disorders, or those requiring medical care are chronically undersupplied, while "for-profit" group homes for mild-to-moderate cases are oversupplied in some regions. The "community living enhancement" of the revised law, left to market forces, has revealed a familiar pattern: "where it pays, they gather; where it does not, they do not reach."
The gap between UN recommendations and domestic implementation. In September 2022, the UN Committee on the Rights of Persons with Disabilities issued concluding observations from its first review of the Japanese government. Approximately 90 recommendations were made, including deinstitutionalization, review of forced psychiatric hospitalization, ending segregated education, and budget allocation for equal community living. The April 2024 revised law, however, continues to position group homes as the "receiving channel for community transition," which is structurally at odds with the UN recommendation that "persons with disabilities should not be obligated to live in particular living arrangements, including group homes" (the safeguarding of self-determination).
Largest segment but declining
Steady +5% annual growth
~6x increase in 10 years; retention is the challenge
Employment of persons with psychiatric disabilities has surged, yet the 1-year job retention rate is only 49.3% — compared to 60.8% for physical and 68.0% for intellectual disabilities. Rising numbers do not necessarily mean quality employment.
Background & Context
From the 2006 Self-Reliance Act to the 2013 Comprehensive Support Act and 2022 revision, with CRPD and UN concluding observations.
Policy History: From Self-Reliance Support to Comprehensive Support, and the 2022 Revision
Understanding the revised Comprehensive Support Act requires acknowledging three layers of policy history.
The first layer is the Self-Reliance Support Act. Enacted in 2005 and brought into force in 2006, this law unified the previously separate support-fee systems organized by disability type and introduced benefit-based cost-sharing (10% co-payment based on services used). This drew strong opposition from disability advocacy groups: "Are we to be charged for the fact of disability itself?" became a fundamental critique. Constitutional challenges were also filed.
The second layer is the Comprehensive Support Act. Enacted in 2012 and brought into force in April 2013, this law renamed the "Self-Reliance Support Act" and added (1) intractable diseases to the scope of disabilities, (2) expanded the scope of severe-disability home care, and (3) unified group homes (cohabitation support). A philosophical provision was codified: "the realization of a community society where individuals respect each other's personality and individuality, regardless of disability, and can live with peace of mind."
The third layer is the 2022 revision, enforced from 2024. Where the first and second layers emphasized "how to deliver services broadly and equitably" (quantity and fairness), the 2022 revision shifts emphasis toward "quality and individuality": improving employment support quality, building community living support systems, and providing wish-aligned support for persons with mental disabilities.
Yet the structural problems left unaddressed by the first and second layers — the "Article 65 problem" (the long-term care insurance priority principle that strips persons with disabilities of welfare services upon turning 65, established by Supreme Court precedent), the "what happens after parents die" problem, the life infrastructure for children and adults requiring medical care, and the regional unevenness of support for severe behavioral disorders — remain essentially unresolved even in the 2024 revision.
A Parallel Issue: Raising the Employment Quota and the Decline in Compliance
The legal employment quota for private companies under the Employment Promotion Act for Persons with Disabilities was raised from 2.3% to 2.5% in April 2024 and is scheduled to reach 2.7% in July 2026. The 2024 survey shows an actual employment rate of 2.41% (a record high), but the share of compliant companies dropped to 46.0% (down 4.1 points year-on-year). Even as levy revenues rise, the quota hike has produced a widening gap between numerical targets and field response. The employment-choice support introduced in the revised Comprehensive Support Act was designed in part to mitigate this mismatch on the employer side, but its effects have yet to be evaluated.
For deeper analysis on the employment side, see The Structure and Limitations of Japan's Disability Employment Quota System.
International Context: The CRPD and the "Social Model"
The Convention on the Rights of Persons with Disabilities (CRPD), ratified by Japan in 2014, rests on the social model: disability is understood not as an individual functional impairment but as a barrier produced by society. The 2022 UN concluding observations recommended deinstitutionalization, the abolition of forced psychiatric hospitalization, and the ending of segregated education precisely because Japan's system still retains vestiges of the medical model (treating persons with disabilities as objects of treatment and protection).
The revised Comprehensive Support Act mixes elements of social-model advancement (legal codification of reasonable accommodation, extended to private businesses from April 2024) and medical-model residue (the persistence of forced psychiatric hospitalization). The JDF published a Japanese provisional translation of the concluding observations in October 2023 and reaffirmed at its December 2024 national forum the commitment to "realize the society envisioned by the Convention," but domestic policy design remains within the service-supply model.
Reading the Structure
Service fragmentation, deinstitutionalization gaps, Article 65 and 8050 problems, and fee distortions — with seeds of social design.
The distortions revealed by the operational phase of the revised Comprehensive Support Act can be structured through the lens of "social security gaps in an inclusive society."
Fragmented Service Categories Produce "Falling Through the Cracks"
Disability welfare services have now branched into more than 30 categories (care benefits, training benefits, self-reliance medical care, assistive devices, community living support — each with multiple subcategories). The design intent is "precise response to individual needs," but the operational reality moves in the opposite direction.
Municipal staff cannot grasp the full picture of the system and therefore cannot route applicants appropriately. Coordinating multiple services takes time, delaying urgent responses. The gray zone — strong behavioral disorders combined with medical care needs and psychiatric symptoms, or young-onset dementia combined with intellectual disability — expands.
The fragmentation of service categories, framed abstractly as "pursuit of fairness," operates in practice as "classification for the sake of classification," producing individuals who fall through the cracks of the very services meant to support them.
"Community Transition" Dominates the Policy Premise
The revised law is grounded in "transition to community living." This direction aligns with UN recommendations, but its operational premise tacitly assumes that "the community has the capacity to receive." The reality is the inverse: as noted, group homes face simultaneous undersupply, quality disparities, and total-quantity regulation debates, while base consultation support centers, made an effort-based obligation in 2024, are not yet established in all municipalities.
The gap arises not from the direction of community transition itself but from the time lag between the rush of policy design and the slow pace of infrastructure readiness. People discharged from institutions are not received by the community: they are pushed back onto family self-help or forced to seek another institution.
The Article 65 Problem and the Residual "Long-Term Care Insurance Priority Principle"
Article 7 of the Comprehensive Support Act stipulates that when an equivalent long-term care insurance service exists, long-term care insurance takes priority. This has been confirmed by Supreme Court precedent and was not repealed in the 2024 revision.
The consequences for individuals are severe. The care content received under disability welfare services until age 64 drops in quality and quantity when switched to long-term care insurance at 65. A new co-payment (typically 10%) emerges under long-term care insurance. Continuity of support is broken when transitioning to long-term care providers with shallower understanding of disability-specific needs.
A mitigation measure (the "New High-Cost Disability Welfare Service Benefit," which refunds co-payments within certain ranges) exists, but the underlying inter-system gap remains. The contradiction is that the philosophy of an inclusive society tolerates a system-to-system gap drawn by age.
The 8050 Problem and the Unreachability of Disability Welfare Services
The "8050 problem" (parents in their 80s living with children in their 50s, characterized by social isolation and economic hardship) involves an estimated 613,000 socially withdrawn individuals aged 40–64, with over 70% being male. Among them are individuals with intellectual disabilities, developmental disabilities, or psychiatric conditions who are not connected to disability welfare services.
Why do they remain disconnected? Parents have historically chosen to "manage within the family" (driven by the older norm of treating disability as a "family shame"). Many reach middle age without receiving a disability certification, missing the timing for obtaining intellectual disability handbooks or mental health handbooks. Municipal staff, divided between elderly welfare and disability welfare silos, cannot reach individual households.
The revised Comprehensive Support Act incorporated emergency response for "after parents die" through community living support hubs, but its design for "reaching out while parents are still alive" is weak. The 8050 problem is deepening into the "9060 problem," and the social security gaps of an inclusive society become locked in across generations.
Fee Revisions Distort Operational Incentives
The FY2024 fee revision involved (a) consolidation of treatment improvement add-ons (a 2.5% base increase in FY2024 and 2.0% in FY2025), (b) restructuring the base fee for living care toward evaluation by service hours, and (c) tightening of productive activity revenue scoring for Type-A offices.
The result is widening operational disparities between offices that can secure additional incentives and small offices that cannot. Accepting short-time users becomes disadvantageous under the base fee, making it difficult to use the system for family respite. Type-A office closures eliminate employment opportunities.
Fee revisions are powerful instruments for reshaping the "incentive design on the provider side," but they can damage the "fairness of service access on the user side." Tension between the ideal of an inclusive society and the economic engineering of fee schedules is structural.
Seeds of Social Design: Redefining the Inclusive Society
Several transitions emerge from these distortions.
The integration and simplification of service categories is one. To correct the structure where fragmentation into more than 30 categories causes individuals to fall through the cracks, a shift toward needs-based integrated benefit models (personal budgets, direct payments) should be examined. The UK's Personal Budget and Germany's Persönliches Budget offer reference precedents.
The integrated development of community living support infrastructure is another. Rather than developing base consultation support centers, community living support hubs, group homes, short-stay services, and emergency response separately, a model that integrates these as "disability welfare complex facilities" is needed. The disability welfare complex initiative pursued by ISVD with Role for All and Correlate Design, using PPP/PFI/small concession schemes, fits within this direction.
The repair of intergenerational gaps remains. The Article 65 problem and the 8050 problem both arise from inter-system and intergenerational silos. Redesigning disability welfare and long-term care insurance as "lifelong support across the life course" is the kind of policy redesign that an inclusive society deserves to bear that name.
The revised Comprehensive Support Act is, on paper, a comprehensive policy renewal, and the operational phase has generated many new debates: employment-choice support, the effort-based obligation for base consultation support centers, total-quantity regulation of group homes. What has become visible two years into operation, however, is the structure of "people who fall through the cracks of the services the system provides," the thinness of the premise that "community transition can proceed without a receiving infrastructure," and the reality that "the walls of age 65 and age 80 betray the ideal of an inclusive society."
The 2022 concluding observations of the UN Committee on the Rights of Persons with Disabilities asked: "Are persons with disabilities given the opportunity to choose where and with whom they live in the community?" The operational phase of the revised law has brought this question back to the surface. The question runs beneath the detailed design of welfare systems, returning to a deeper one: Is Japanese society truly prepared to live together with persons with disabilities?
Beyond the volume and fairness of service supply, the operational phase calls for making visible those who fall through the cracks, integrating the fragmentation of service categories, developing community living support infrastructure as an integrated whole, and repairing intergenerational gaps. The revised Comprehensive Support Act is a starting point, not a destination.
Related Columns
- The Structure and Limitations of Japan's Disability Employment Quota System — What Happens Inside the Legal Rate of 2.5% (Structural analysis of the employment side, including special subsidiary companies and the 49.3% retention rate for persons with mental disabilities)
- Disability Pension's Invisible Barriers: The Structure of Regional Recognition Gaps and Non-Award Rates (Income-support side evaluation)
- Japan's April 2026 Welfare Reform: What Changed, and What Didn't (Adjacent debate on social security gaps)
Reference Books
障害者総合支援法事業者ハンドブック : 報酬告示と留意事項通知. 2024年版 報酬編 第1巻 (Service Provider Handbook for the Comprehensive Support Act for Persons with Disabilities: Fee Edition) (Chuohoki Publishing, 2024) is a practitioner's handbook covering the FY2024 fee revision in detail. It is indispensable for analyzing the operational phase, including the changes to Type-A scoring evaluation.
Self-Determination by Those Concerned (Shoji Nakanishi and Chizuko Ueno, Iwanami Shinsho, 2003) is a foundational text presenting the theoretical basis of the disability self-advocacy movement. It is essential reading for understanding the philosophical source of the revised law's emphasis on self-determination, and the concept of "tojisha-shuken" (self-determination by those concerned) remains valid as an evaluation axis for disability welfare policy.
Bodies That Cannot Be Mastered: Sickness, Disability, and Society (Shinya Tateiwa, Seidosha, 2018) is a representative work in disability studies. It theoretically organizes the "coexistence of medical and social models" embedded in the revised Comprehensive Support Act.
References
On the Revision of the Comprehensive Support Act for Persons with Disabilities — MHLW, Department of Health and Welfare for Persons with Disabilities. MHLW
Functionalization of Community Living Support Hubs (FY2025 Consultation Support Worker Instructor Training) — National Rehabilitation Center for Persons with Disabilities. National Rehabilitation Center
FY2024 Disability Employment Status Survey Results — Ministry of Health, Labour and Welfare. MHLW
Concluding Observations on the First Japanese Government Report on the Convention on the Rights of Persons with Disabilities — UN Committee on the Rights of Persons with Disabilities. Ministry of Foreign Affairs
FY2024 White Paper on Persons with Disabilities — Cabinet Office. Cabinet Office
MHLW Proposes Total-Quantity Regulation for Disability Welfare Group Homes — Joint Kaigo News. Joint
Toward Clarifying the Reality of Disability Facility Waitlists: MHLW to Investigate Definitions — Fukushi Shimbun. Fukushi Shimbun
329 Type-A Offices Closed, 5,000 Laid Off: How the Business-ization of Welfare Strips Dignity from Persons with Disabilities — Elfaro Social Insurance and Labor Office. Elfaro
UN Committee on the Rights of Persons with Disabilities: Concluding Observations (Japanese Provisional Translation) — Japan Disability Forum (JDF). JDF
