Individuals will have started to receive their My Number ID at their home address. In a meantime, the respective government offices have only recently released information about how to treat My Number ID in the Japanese year end W2 (Gensen Choshu Hyo), and unemployment insurance administration.
On October 2nd, the Ordinance for Enforcement of the Income Tax Act was revised. The revised Act states that My Number ID will no longer be required on the Gensen Choshu Hyo or the payment report (Shiharai Chosho) for himself/herself. However, My Number ID is still required to be included on the Gensen Choshu Hyo submitted to the tax office.For further information, please refer to the site below (only available in Japanese).https://www.nta.go.jp/mynumberinfo/FAQ/kokuzeikankeifaq.htm
For unemployment insurance administration, My Number ID will be required to be included from January 1 2016. However, no official administration formats have yet been decided even at this point in time. The Q&A issued by the Ministry of Health, Labor and Welfare on September 15 has an additional minor clause that says “reporting My Number ID in the unemployment insurance administration is on ‘an obligation to make an effort’ basis, and even if there is no My Number ID reported or the reported numbers are incorrect, there shall be no penalty”.http://www.mhlw.go.jp/file/06-Seisakujouhou-11600000-Shokugyouanteikyoku/0000093276.pdf
Having said that, we should continue with the system implementation. Companies that are still in process of preparing for the January 2016 kick off should not feel under pressure but should continue implementation with strong focus on a risk management plan for the organization.
We hear that many companies plan to collect My Number IDs from their employees in November this year. When a company collects IDs, there will always be the associated risk of managing such sensitive information. We recommend that this risk is taken into consideration when companies are planning the timing of their information collection.
No matter what, My Number system will be implemented soon. Even at this late stage, it’s clear that there are still many matters requiring further clarification, therefore it would be wrong for any company to believe that they are fully prepared for the impending implementation of the My Number system. Any information obtained by attending a My Number seminar will only be current as of the seminar and not reflective of any future clarifications and or changes.
For now, we recommend you to focus on My Number IDs only where it is critical, and continue to monitor related information released by the respective government offices. PMP will continue to highlight important updates on My Number in future News Letters.
We think being flexible is the most realistic approach that we can take for now.
※Should you have questions or concerns regarding the above please do not hesitate to contact PMP at info@pmp.co.jp