The Netherlands introduced the Gatekeeper Act in the 1990s, establishing a system under which companies and employees jointly develop and review return-to-work plans from the leave stage. Reports indicate that the system prevents long-term leave from becoming prolonged and reduces repeat leave after returning to work, highlighting the differences from Japan.
In recent years, extended leave due to mental health problems has become a broader social issue in developed countries, including Japan. Because return-to-work support affects not only individual recovery but also corporate productivity, institutional frameworks are being developed overseas.
The Netherlands introduced a system known as the Gatekeeper Act, requiring the employee, employer and occupational physician to work together to create a return-to-work plan when leave begins and review it regularly. If returning to the original position is difficult, the plan may consider reassignment, job redesign and, in some cases, support for finding employment with another company.
A feature of the system is that employers are subject to a duty to make reasonable efforts toward the employee's return to work, with intervention by the employer emphasized alongside medical care. Reports indicate that this has reduced prolonged leave and helped curb transitions to disability pensions and repeat leave.
In Japan, companies tend to wait for a doctor's decision during leave, delaying their full-scale involvement in return-to-work support. A major difference identified is the contrast in perception: in the Netherlands, return-to-work support is regarded not as benevolent employee welfare but as return-to-work infrastructure.