【Major Reform of Japan’s Subsidy System in 2026】

yoshimi06
Dec 10, 2025
4 min read

Why Professional Support by an Administrative Scrivener × Certified Public Accountant Is Now Essential for Subsidy Applications— Why Tokyo Advisory Is Your Strongest Partner —

From January 1, 2026 (Reiwa 8), the amended Administrative Scrivener Act will significantly change the landscape of subsidy applications in Japan.The previously ambiguous question of “who is legally allowed to prepare subsidy application documents” will be clarified, and unlicensed consultants providing subsidy application services will become completely illegal.

At the same time, however, the core essence of subsidy screening remains unchanged:Whether the reviewers can see that:

the business plan is truly feasible,
the financial assumptions are sound, and
the return on investment is reasonable.

These evaluation criteria will continue to be the key focus in the screening process.

1. Key Points of the Amended Administrative Scrivener Act

Under the amended Act, it is illegal to perform the following services for compensation unless you are a licensed administrative scrivener:

Preparation of subsidy application documents
Preparation of subsidy project plans
Electronic submission (including proxy applications)
Preparation of performance/implementation reports

In other words, going forward:

👉 It is completely prohibited for consultants without an administrative scrivener qualification to take on subsidy application work for a fee.

As a result, we can expect a rapid increase in “administrative scrivener firms specializing in subsidies” in the market—but there is a critical pitfall here.

2. The Reality: Administrative Scriveners Alone Cannot Truly Raise the Approval Rate

In subsidy screening, the following points are especially important:

Financial backing and consistency of the plan
Alignment between management issues and business strategy
Realistic and achievable numerical projections
Reasonable return on investment

These areas are not the core specialty of administrative scriveners.They are precisely where Certified Public Accountants (CPAs)—experts in financial and business analysis—bring the most value.

Therefore, firms that only “prepare documents” as administrative scriveners face structural limitations:

▶ They cannot design a “business plan that will be approved.”▶ Numerical assumptions tend to lack solid backing, resulting in point deductions during screening.▶ They are unable to provide support for execution after approval.

3. Why Tokyo Advisory Is the Strongest Choice

Tokyo Advisory brings together all the elements necessary for effective subsidy support.

✔ Certified Public Accountant (CPA)

Financial analysis
Business analysis
Design of profit and investment plans

✔ Administrative Scrivener

Preparation and proxy submission of subsidy application documents
Full compliance with the amended Administrative Scrivener Act

✔ Licensed Tax Accountant

Accounting treatment after subsidy receipt
Tax compliance and filings, handled seamlessly

✔ In addition, the Representative Is a Multi-Company Manager

mocomoco Inc.
DigLab Inc.
Tokyo Advisory Inc.

→ This enables “management-level” perspectives in business planning and subsidy strategy.→ Practical and management realities that other firms cannot replicate are directly reflected in the plans.

4. A Two-Layer Support Structure That Dramatically Improves Approval Rates

Tokyo Advisory’s distinctive feature is its two-layer support structure:

[Layer 1: Management Consulting (CPA)]

Analyze the revenue and cost structure of the business
Visualize issues using quantitative data
Calculate return on investment
Formulate growth strategies utilizing subsidies

[Layer 2: Documentation & Application Execution (Administrative Scrivener)]

Prepare documents in full compliance with the public application guidelines
Check consistency across all application materials
Handle electronic submissions and proxy applications
Provide end-to-end support through to performance reporting

This structure enables us not only to ensure:

the formal correctness of documents, but also
the substantive strength of the content — plans that reviewers can genuinely accept and trust.

It is a unique framework that guarantees both.

5. Support Extending All the Way to Post-Approval Management Improvement

Simply being approved for a subsidy is not the end goal.

Tokyo Advisory takes responsibility for the entire process:“Approval → Execution → Performance Reporting → Management Improvement.”

Our services include:

Measuring the actual effect of the investment
Cash flow management
Handling of properties subject to disposal restrictions
Determining whether profit refunds (revenue repayments) are required
Designing structures that convert subsidies into sustainable profits

This is an area that firms composed solely of administrative scriveners cannot cover.

6. Why Clients Choose Tokyo Advisory

Key characteristics of our Representative, Mamiko Yamamoto:

✔ Japanese Certified Public Accountant
✔ Licensed Tax Accountant
✔ Licensed Administrative Scrivener
✔ USCPA (United States Certified Public Accountant)
✔ Broad experience ranging from statutory audits of listed companies and system development to overseas business practice
✔ Track record supporting startups, foreign-owned companies, and long-established Japanese businesses
✔ Real-world insight as an active manager of multiple companies

She is one of the few professionals who can create “plans that are not just theoretical, but actually executable in real business.”

7. Comparison with Other Types of Firms (Simplified)

Comparison Item	Unlicensed Consultant	Admin. Scrivener Only	Tax Accountant	Tokyo Advisory
Legally allowed to prepare application docs	✗ Illegal	◎ Yes	△ Limited	◎◎◎ Fully permitted
Financial analysis capability	×	△	◎	◎◎◎
Quality of business planning	△	△	◎	◎◎◎
Post-approval follow-up	×	×	○	◎◎◎
Overseas business support	×	×	△	◎◎◎
Approval likelihood	Low	Medium	High	Highest

8. Why “Subsidy Support with Real Management Understanding” Is Needed Now

Due to the amended Administrative Scrivener Act,we are entering an era in which “administrative scriveners who only prepare documents” will increase rapidly.

However, what is truly required in subsidy screening is:

“A business plan that actually increases the likelihood of business success.”

Tokyo Advisory—whose representative is simultaneously a business owner, Certified Public Accountant, and Administrative Scrivener—is therefore the optimal partner in the new subsidy regime.