[Applies to existing real estate specified joint ventures] Stricter screening and points to note when submitting change notifications and business reports
Posted: May 2026, 2
In recent years, particularly in Tokyo, screening of real estate specified joint ventures (FUTOKYO SPECIFIC JOINT ENTERPRISES) has become stricter not only when obtaining new licenses, but also when examining the operating status of existing businesses.
The background to this trend is that the checks on outsourcing and legal compliance systems are being strengthened in the new license examination.[Tighter approval screening for real estate specified joint ventures in Tokyo]This is explained in detail in.
Existing real estate specified joint ventures will also be affected by the "stricter screening"
The scope of the stricter screening process for real estate specified joint ventures is as follows:This does not just apply to businesses seeking to obtain new licenses.
For businesses that have already obtained permission for non-special business,
- Annual business report
- Change notification
- Application for approval of changes to add terms and conditions, etc.
In such a procedure,Are the contents of the outsourcing and daily business operations being conducted legally?More detailed checks are now being carried out than ever before.
Key points to check when submitting change notifications and business reports
Is the operation in accordance with laws and regulations and supervisory points of attention?
The review will check whether operations are being carried out in accordance with the Real Estate Specified Joint Venture Act, related laws and regulations, and supervisory considerations.
It's not just about whether the written system is in place,Are actual business operations conducted in accordance with the law?is an important point.
Are operations being carried out in compliance with business procedures and company regulations?
Regarding the business procedures and internal regulations established by the business operator,
- Is it being operated as per the content?
- Has it become a mere formality?
The following points will be confirmed.
Were there any inappropriate aspects in the business operations after obtaining the license?
In operation after obtaining permission,
- Are prohibited operations being outsourced?
- Is there actually any involvement of a third party in the monopoly business of the real estate brokerage business?
These points may also be retroactively reviewed.
If improper business practices are confirmed,There is a possibility that you may be subject to administrative guidance or administrative sanctions.Points need attention.
Responding to the "Stricter Screening" of Real Estate Specified Joint Ventures
In the case of real estate specified joint ventures, since the business is subject to continuous supervision even after obtaining permission,Establishing a legal compliance system and internal controls is more important than everHas become.
In particular, it is essential to organize and confirm the following points in advance:
- Whether the content of the outsourcing work falls under the category of work prohibited under non-special business
- Are operations actually being carried out in accordance with the business manual and internal regulations?
- Are there any "risk areas" that may be pointed out by the government?
Furthermore, these checks have much in common with the standards required for new licenses.
About our internal audit support (compliance check)
In response to the trend toward stricter screening for real estate specified joint ventures, Support Administrative Scriveners Corporation offers the following services to existing real estate specified joint ventures:Support for internal audits and legal compliance checksOffers.
Specifically, we provide the following support:
- Identifying risks both before and after obtaining permission
- Internal audit support for existing real estate specified joint ventures
- Advance measures based on points that are likely to be pointed out in the Tokyo Metropolitan Government's inspection
- Legality checks regarding outsourcing contracts and actual operational status
It is expected that the review and supervision of real estate specified joint ventures will continue to become stricter in the future.
Advance preparation and regular checks are directly linked to maintaining licenses and stable business operations.
If you have any concerns about running your existing business, submitting change notifications, applying for change approval, or reporting your business, please contact us first.
(Author: Hiromasa Suzuki, Consultant in charge of real estate specified joint ventures)
