We've brought in freee HR. So what does a retained shakai hoken roumushi actually do?

In short: freee HR (freee人事労務) prepares the documents and can file them electronically through Mynaportal or e-Gov. As long as your company files its own procedures for itself, no licence is required. A shakai hoken roumushi (Certified Social Insurance and Labor Consultant) becomes necessary when someone prepares or files them on another person's behalf, for a fee, at that person's request (Certified Social Insurance and Labor Consultant Act, Article 27).

This page is for owners and back-office staff of small and medium-sized companies that have adopted freee HR, or are thinking about it. The software and the consultant are not substitutes for each other; the line between them simply runs in a different place. We trace that line along the statute.

How far can freee HR alone take you?

According to freee's official help pages (updated 10 April 2026, viewed 14 August 2026), electronic filing from freee HR runs through two routes — Mynaportal and e-Gov — and requires a gBizID Prime account (corporate accounts only; the free tier is not covered).

Route	Documents that can be filed electronically (examples)
Mynaportal	The monthly standard remuneration revision notification (月額変更届), the annual standard remuneration calculation report (算定基礎届), the bonus payment notification (賞与支払届), acquisition and loss of insured status notifications for health insurance and employees' pension (資格取得届・喪失届), employment insurance acquisition and loss notifications (with or without the separation certificate), and application forms for childcare-leave benefits and continued-employment benefits for older workers, among others
e-Gov	The annual renewal of labour insurance (年度更新), the periodic health checkup results report, and the stress-check results report

In other words, filing your own company's procedures for yourself — the social and employment insurance filings that come with hiring and departures, the annual calculation report, the annual renewal — is something the software can do.

Two cautions. First, freee's features and the list of supported documents change. The table above reflects published materials as of August 2026; check the official help pages for the current scope. Second, the same help page states plainly: "agent filing by a shakai hoken roumushi is not currently supported." Electronic filing in freee HR is designed as a tool for an employer to file its own procedures itself.

If the software exists, why would we need a shakai hoken roumushi?

The Certified Social Insurance and Labor Consultant Act defines three types of work concerning labour and social insurance procedures (Article 2, paragraph 1).

Item	Work	What it means
Item 1	Preparing applications and other documents	Drawing up the applications, notifications and reports submitted to public agencies
Item 1-2	Filing on another's behalf	Carrying out the submission procedures for those documents in another's place
Item 1-3	Representation in procedures	Acting as agent in applications, and in statements and assertions made to the agency in investigations and dispositions

There is a phrase here that is easy to miss. The statutory definition of "applications and other documents" in item 1 expressly includes electronic or magnetic records (電磁的記録) created in place of paper documents. That is: not only the paper notification, but the data you build in cloud software and file electronically falls squarely within the statute.

Article 27 then draws the line.

No person other than a shakai hoken roumushi or a shakai hoken roumushi corporation may, at the request of another person and for a fee, carry out as a business the affairs listed in Article 2, paragraph 1, items 1 through 2. (Certified Social Insurance and Labor Consultant Act, Article 27)

Read in reverse: a company handling its own procedures for itself is outside this provision. You need no licence to prepare and file your own annual calculation report in freee. The licence is needed when someone does it for another company, for a fee. What the software removes is the labour of filing your own paperwork — not the legal character of having someone do it for you.

Article 27 has a proviso: work performed incidentally to business designated by cabinet order is exempt. The order (Order for Enforcement of the Certified Social Insurance and Labor Consultant Act, Article 2) designates two cases — work performed by a certified public accountant as part of CPA practice, and work performed by a tax accountant or tax accountant corporation incidentally to tax practice. Where exactly "incidental" ends is a case-by-case judgement, so this article goes no further than presenting the provision.

Accounting and labour: who do you ask for which?

In a company running freee, accounting and HR sit side by side on the same screen, so the question "can't we just ask one person to handle everything?" arises naturally. But the licensing lines are drawn somewhere other than the software's menus.

Software / situation	Doing it yourself	Whom to engage, for a fee, to do it for you
freee Accounting (bookkeeping, closing, tax returns)	No licence needed	A tax accountant
freee HR (social and labour insurance procedures)	No licence needed	A shakai hoken roumushi
freee HR's year-end adjustment feature	No licence needed	A tax accountant (the year-end adjustment is tax work)
Licences and permits after freee Company Formation	No licence needed	A gyoseishoshi (Certified Administrative Procedures Legal Specialist)

In Yotsuba's case, labour and social insurance procedures are handled by 四葉社会保険労務士事務所, and permits, residence status and subsidies by 四葉行政書士事務所. They are independent businesses, with separate contracts and separate invoices. For tax we point you to a tax accountant, whom you engage directly; no referral fees change hands.

What exactly is the retainer paying for, then?

Once the software takes over the typing and the filing, the consultant's work shifts away from "writing documents" to what comes before and after them.

• Whether the procedure is needed at all, and by when (a judgement arises with every hire, departure and leave)
• Whether the requirements for a benefit are met, and which benefits are available
• Handling investigations and inquiries from the agencies (the representation in item 1-3 is the work for this situation)
• The labour management underneath the procedures — working hours, wages, work rules

For a company that has adopted the software, the retained consultant looks less like an outsourced typist and more like the place you take judgement calls. At Yotsuba we have carried this thinking into the fees themselves: support for building a setup to process payroll and other monthly work in-house on freee is included in the retainer fee (what the in-house option involves). How payroll pricing works, and where a shakai hoken roumushi fits, is set out in How much does it cost to have a shakai hoken roumushi run payroll?, and our own thinking on fees in the fee schedule. If the fees are not visible, there is nothing to compare — we take that view too.

What can 四葉社会保険労務士事務所 do?

四葉社会保険労務士事務所, in Kohinata, Bunkyo City, handles the preparation, agent filing and procedural representation of labour and social insurance filings (Certified Social Insurance and Labor Consultant Act, Article 2, paragraph 1, items 1 through 1-3), together with labour consultation and the drafting and revision of work rules. If your company uses freee HR, there is no need to switch software. You keep filing what you can file yourselves, and hand over only the parts that need judgement or agent filing. For companies adopting freee from now on, we provide support for building a setup to run payroll and other monthly work in-house, included in the retainer fee — from designing the initial settings through consulting on each month's close and checking the months when premium rates are revised.

Consultation is free of charge. Bring your freee settings screen, or the list of procedures you are about to file, and we will start by sorting them into "things you can file yourselves" and "things better handed over". The questions we are asked most often are collected on the FAQ page.

Whom to consult

Bookkeeping, closing, tax returns and the year-end adjustment are work for a tax accountant; registration for a judicial scrivener; matters already in dispute for an attorney. Residence-status applications, subsidies and company-formation documents are handled by 四葉行政書士事務所 (a separate business from this office, engaged under a separate contract). In every case, no referral fees change hands.

Frequently asked questions

Q. If freee can file electronically, is there any point in engaging a shakai hoken roumushi?
A. The work of filing your own procedures can be done by the software. What you engage a shakai hoken roumushi for is the judgement — whether a procedure is needed, by when, and which benefits apply — and the preparation, agent filing and procedural representation that only a licence-holder may perform for a fee (Certified Social Insurance and Labor Consultant Act, Article 2, paragraph 1, items 1 through 1-3). The work and the judgement are different things. At Yotsuba, support for building the setup to process the work in-house on freee is itself included in the retainer fee.

Q. What does electronic filing from freee require?
A. According to the official help pages (viewed 14 August 2026), a gBizID Prime account, and corporate accounts only. The routes divide into Mynaportal and e-Gov. Features and supported documents change, so check freee's official help for the current scope.

Q. Will a retained shakai hoken roumushi file as our agent from inside freee?
A. freee's official help states that "agent filing by a shakai hoken roumushi is not currently supported" (updated 10 April 2026). Agent filings are made through the consultant's own systems. You can stay on freee HR while engaging us — no need to switch software.

Q. Can we also ask a shakai hoken roumushi to do the year-end adjustment?
A. freee HR has a year-end adjustment feature, but performing it for another person for a fee is tax work — the province of a tax accountant. This office does not handle it; we point you to a tax accountant, whom you engage directly. No referral fees change hands.

Sources for this article

• Certified Social Insurance and Labor Consultant Act (社会保険労務士法, Act No. 89 of 1968), Article 2, paragraph 1, items 1, 1-2 and 1-3; Article 27 — current text confirmed on e-Gov on 14 August 2026
• Order for Enforcement of the Certified Social Insurance and Labor Consultant Act (社会保険労務士法施行令, Cabinet Order No. 327 of 1968), Article 2 — current text confirmed on e-Gov the same day
• The scope of electronic filing in freee HR, the gBizID Prime requirement, and the non-support of agent filing by a shakai hoken roumushi — freee Help Center, "Filing various documents electronically from freee HR" (updated 10 April 2026, viewed 14 August 2026)

freee's features and supported documents change. When considering adoption or operation, check freee's official help pages for the latest information. This article is based on materials published as of August 2026.

How far freee's AI features have come is set out in How far has the AI integration between freee HR and freee Accounting actually come?. Our fees are in the fee schedule, and the path from consultation to engagement in How an engagement proceeds.

This article is general information. Judgments that fit your particular circumstances are made by a qualified professional after a meeting. Written by Joji Uramatsu (Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist).