[Important] Prevention of violations of the Administrative Scrivener Act in fire safety procedures and amendments to the law
Posted: May 2026, 3
In light of the "Act Partially Amending the Administrative Scrivener Act" (Act No. 65 of 2025), which came into effect on January 1, 2026, and the notification from the Fire and Disaster Management Agency of the Ministry of Internal Affairs and Communications, we would like to inform you about the proper implementation of various procedures based on fire safety laws and regulations.
1. Regarding the enforcement of the revised Certified Administrative Procedures Specialist Act and notifications/applications related to fire safety regulations.
The revised Administrative Scrivener Act came into effect on January 1st of this year (Reiwa 8). In accordance with this revision, Article 1-2 of the previous Administrative Scrivener Act has been amended to Article 1-3.
2. Purpose of the Fire and Disaster Management Agency's Warning | Proper Procedures for Documents and Notifications Regarding Fire Protection Equipment
The Fire and Disaster Management Agency of the Ministry of Internal Affairs and Communications has issued a notice (dated February 25, 2025) to each prefecture and fire department with the following content:
- Prevention of illegal activities:
In various procedures based on fire safety regulations, we must ensure that there are no "violations of the Administrative Scrivener Act," such as when individuals without administrative scrivener qualifications are involved in preparing documents for submission. - Proper document preparation:
The preparation of documents to be submitted to government offices is, with the exception of legally defined cases, the exclusive domain of certified administrative scriveners.
Risks and penalties associated with requesting document preparation from unqualified individuals.
Entrusting the preparation of documents related to fire safety regulations to a non-certified administrative scrivener may constitute a violation of the Administrative Scrivener Act.
Serious violations may result in penalties (imprisonment or fines) based on Article 21-2 of the Administrative Scrivener Act, and under the dual liability provision, the client corporation itself may also be held liable.
Even if it's formally presented as a service like writing on someone's behalf or data entry by an agent, it may be considered illegal, so caution is advised.
Furthermore, delays in processing due to incomplete documentation are also a concern.
When choosing an agency, do not judge solely on the low application fees or project costs; always confirm whether they are qualified administrative scrivener.
Regarding the prevention of violations of the Administrative Scrivener Act in various procedures based on fire safety regulations,Preventing violations of the Administrative Scrivener Act in various procedures based on fire safety laws" for a detailed introduction.
The importance of appropriate division of roles with fire protection equipment technicians, etc.
In fire safety management and equipment installation, an appropriate division of roles among specialists is required.
For example, technical tasks such as creating drawings for fire extinguishing systems, construction, and maintenance inspections are handled by specialized companies such as certified fire protection technicians.
On the other hand, the preparation and submission of legal documents such as installation notifications and fire safety plans to government offices are the exclusive domain of certified administrative scriveners.
Thus, it is necessary to clearly distinguish between the roles of technical and legal aspects and to entrust tasks to specialists in each field.
By establishing an appropriate system, you can complete accurate and smooth application procedures while adhering to compliance requirements.
For specialized knowledge regarding fire prevention and disaster preparedness, see "Fire prevention and disaster prevention" for a detailed introduction.
3. Our response and cooperation in raising awareness | Properly supporting the filing and planning of fire safety regulations.
At the request of the Japan Federation of Certified Administrative Procedures Specialists Associations (JFCRC), our company (Support Certified Administrative Procedures Specialists Corporation) is also disseminating information about the purpose of the legal amendments and the appropriate procedures to fire equipment associations in each prefecture.
If you have any questions regarding the preparation of documents such as applications and notifications based on fire safety regulations, please consult with our company, which employs nationally certified personnel.
Junpei Tsukamoto
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