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Licensing and Business Start-up Procedures (From the Practice of an Administrative Scrivener)

Registration, Deemed Registration and Notification for an Electrical Construction Business, and the Chief Electrician for Each Office

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浦松 丈二

浦松 丈二

行政書士・宅地建物取引士(四葉行政書士事務所/四葉不動産株式会社)

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To run an electrical construction business, you generally need registration under the Act on the Proper Operation of Electrical Construction Businesses (Act No. 96 of 1970): a registered electrical contractor (Article 3) for work on general electrical installations, or a notifying electrical contractor (Article 17-2) where you handle only self-use installations. A construction operator with a construction-business licence is treated as a deemed registered or deemed notifying contractor (Article 34). An office doing general electrical work must have a chief electrician (Article 19). This article explains, as general information, the division of roles for the permit (administrative scrivener), commercial registration (judicial scrivener) and premises (real estate), each a separate engagement.

In short: to undertake and run an electrical construction business, you generally need registration under the Act on the Proper Operation of Electrical Construction Businesses (Act No. 96 of 1970). If you do electrical work on general electrical installations (general electrical work), you become a registered electrical contractor (Article 3 of the Act); if you do only work on self-use electrical installations, you become a notifying electrical contractor who notifies by 10 days before starting the business (Article 17-2). Where a construction operator with a construction-business licence under Article 3, paragraph 1 of the Construction Business Act runs an electrical construction business, the registration provisions do not apply and the operator is treated as a deemed registered electrical contractor (by notification) or a deemed notifying electrical contractor (by notification) (Article 34). An office that does general electrical work must place, as a chief electrician, a first-class electrician or a person who, after receiving a second-class electrician's licence, has three or more years of practical experience in electrical work (Article 19). This article is general information and does not judge or guarantee whether a given business falls under registration or notification, or whether it meets the qualification requirements. Support for the application (registration, deemed registration, notification) is handled by the administrative scrivener of the Yotsuba group as an independent business; commercial registration for company formation and officer changes is for a judicial scrivener; securing the office premises (office and storage for materials and equipment) is for a real-estate agent, a separate business; and tax is for a tax accountant. The judgment of a worker's qualification under the Electricians Act is within the jurisdiction of the Ministry of Economy, Trade and Industry and the Industrial Safety and Inspection Department, each contracted separately.

What is the difference between "registration", "deemed registration" and "notification" for an electrical construction business?

The starting point is "which electrical installations you handle". The Act on the Proper Operation of Electrical Construction Businesses (the "Electrical Construction Business Act") requires registration of a business doing general electrical work on general electrical installations such as those in ordinary homes and small shops (Article 3), and notification of a business handling only self-use electrical installations such as high-voltage factories and buildings (Article 17-2). For a construction operator with a construction-business licence, a special rule (deemed registration / deemed notification) replaces registration and notification (Article 34).

CategoryInstallations handledProcedure (basis)Chief electrician
Registered electrical contractorDoes general electrical work (self-use also allowed)Registration; 5-year term (Article 3)Required
Notifying electrical contractorOnly self-use electrical workNotify by 10 days before starting (Article 17-2)Not required
Deemed registered electrical contractorLicensed construction operator doing general electrical workNotification (Article 34, paragraph 4)Required
Deemed notifying electrical contractorLicensed construction operator doing only self-use electrical workNotification (Article 34, paragraph 5)Not required

The destination for registration and notification is the governor of the prefecture where the office is located if you set up an office in only one prefecture, and the Minister of Economy, Trade and Industry (the head of the Industrial Safety and Inspection Department) if you set up offices spanning two or more prefectures. Because the procedure splits by which installations you handle and where your offices are, confirming with the authority for the office location at an early stage is essential. Note that "registration" and "the qualification to do the work" differ: to work on site you need an Electricians Act qualification such as a first-class or second-class electrician.

How do the procedures change if you hold a construction-business licence?

Where a construction operator with a licence under Article 3, paragraph 1 of the Construction Business Act runs an electrical construction business, the special rule in Article 34 of the Electrical Construction Business Act applies and the registration provisions (Chapter 2) do not apply. A licensed construction operator is treated as a registered electrical contractor if it does general electrical work (paragraph 2), and as a notifying electrical contractor if it does only self-use electrical work (paragraph 3). Being "treated as" is not enough on its own: a notification is required when the electrical construction business starts, changes or ends (paragraph 4) or, for self-use only, a notification under paragraph 5.

SituationRequired procedure
Licensed operator starts an electrical business including general workNotification as a deemed registered electrical contractor (Article 34, paragraph 4)
Licensed operator starts a self-use-only electrical businessNotification as a deemed notifying electrical contractor (Article 34, paragraph 5)
The licence number/date changes on construction-licence renewalNotification of change
An existing registered contractor obtains a construction-business licenceThe former registration loses effect (Article 34, paragraph 6) = switch to deemed status

What to watch is that even under deemed registration, the duty to place a chief electrician applies to an office doing general electrical work. Also, the construction-business licence itself (needed, for example, where the contract price of a single electrical work is 5 million yen or more, tax included) is a separate system from registration under the Electrical Construction Business Act. This is work the same administrative scrivener handles, but it is a different issue, so please also see the requirements for a construction-business licence (managing responsible person, full-time engineer, financial basis). Where demolition is involved, the difference between demolition-business registration and a construction-business licence is also a separate procedure.

What qualifications and experience does the chief electrician placed at each office need?

Article 19, paragraph 1 of the Electrical Construction Business Act requires a registered electrical contractor to place a chief electrician at each office (a specified office) that does general electrical work. A chief electrician must be a first-class electrician, or a person who, after receiving a second-class electrician's licence, has three or more years of practical experience in electrical work.

ItemContent (basis)
Where placedEach office doing general electrical work (Article 19, paragraph 1)
QualificationFirst-class electrician / second-class electrician with 3+ years of practical experience after the licence
Exception when self-engagedAn office where the representative, etc. meets the requirements and mainly engages themselves is treated differently (Article 19, paragraph 2)
When vacantAppoint a new one within two weeks of the vacancy (Article 19, paragraph 3)

Because the chief electrician manages the general electrical work, concurrently serving at multiple offices or at another electrical contractor is, in principle, not allowed. Whether someone holds the qualification and how practical experience is counted are judgments under the Electricians Act; an administrative scrivener does not make that judgment on your behalf as an exclusive matter. Whether the licence and experience can be substantiated is a point to confirm before applying.

How far are the measuring instruments and safety setup at an office required?

Article 24 of the Electrical Construction Business Act requires an electrical contractor to keep at each office an insulation-resistance meter and other instruments prescribed by Ministry of Economy, Trade and Industry ordinance. The required instruments change with the installations handled.

Type of officeInstruments to keep (METI ordinance)
Office doing general electrical workInsulation-resistance meter, earth-resistance meter, circuit tester (able to measure resistance and AC voltage)
Office doing self-use electrical workThe above plus a low-voltage voltage detector, high-voltage voltage detector, relay test device and dielectric-strength test device

Have a question about your situation?

Tell us about your residency, permit or administrative procedure enquiry.

In addition, there is a duty to display a sign stating the name and registration number at each office and work site (Article 25), and a duty to keep and retain a ledger at each office (Article 26). The specific items and forms of the instruments are set by METI ordinance and local guides, and the final conformity of the model number or quantity is judged by the authority. The fact that "it was like this in another prefecture" does not apply directly is a point often at issue in registration practice.

What happens if you forget the registration's term, renewal or change notification?

The term of a registered electrical contractor's registration is five years (Article 3, paragraph 2 of the Electrical Construction Business Act). If you wish to continue the electrical construction business after the term expires, you must obtain a renewal registration (paragraph 3). If you forget to renew and the term lapses, the registration loses effect, and you cannot continue to operate without registration.

ProcedureDeadline/content (basis)
Term of registrationFive years (Article 3, paragraph 2)
Renewal registrationRequired to continue after the term (Article 3, paragraph 3)
Notification of change to registered mattersWithin 30 days of the change (Article 10)
Notification of discontinuanceWhen the electrical construction business is discontinued

When there is a change to registered matters such as the name, office or chief electrician, you must notify within 30 days of the change (Article 10). Operating without registration, operating while neglecting notification, and operating with a lapsed renewal are subject to penalties. The names, forms and deadlines of the procedures differ in detail by local government, so managing the expiry date and notifying promptly when a change arises is the key in practice.

Who do you ask for what in permits, registration, premises and tax (division of roles)?

Because the professionals involved differ, the basis is that you contract with each as an independent business, separately. The administrative scrivener of the Yotsuba group handles, as an independent business, the preparation of the application documents for registration, deemed registration (notification) and notification of the electrical construction business, and guidance on prior consultation with the Industrial Safety and Inspection Department and the prefecture.

Who to askMain role
Administrative scrivener (our office)Support for registration/deemed registration/notification of the electrical business, and construction-licence applications (a separate issue)
Judicial scrivenerCommercial registration such as company formation and officer changes
Industrial Safety and Inspection Department / prefectureReception of registration/notification; jurisdiction over electricians' qualifications and work scope
Real-estate agent (our company, a separate business)Selection and brokerage of premises for the office and material storage
Tax accountantTax after opening

Please also see our Services, Engagement Flow and Fee Schedule. You contract with each professional as an independent business, and we receive no referral fee from one another.

FAQ

Q. Which should I obtain, the electrical-business registration or the construction-business licence?
A. They serve different purposes. Registration (or notification/deemed status) under the Electrical Construction Business Act is the procedure needed to run an electrical construction business. The construction-business licence is a separate system needed, for example, where the contract price of a single electrical work is 5 million yen or more (tax included), and holding it does not remove the need for notification under the Electrical Construction Business Act. Judge by both the installations handled and the contract amount.

Q. Can I register with only a second-class electrician?
A. An office doing general electrical work needs a chief electrician, and for a second-class electrician this requires three or more years of practical experience in electrical work after the licence (Article 19 of the Electrical Construction Business Act). An office without someone who meets the requirement cannot place a chief electrician and lacks the premise for registration. How practical experience is counted is a judgment under the Electricians Act.

Q. Do I need registration even if I only undertake electrical work for high-voltage buildings and factories?
A. If you do only electrical work on self-use electrical installations, you become a notifying electrical contractor rather than registering, and you notify by 10 days before starting the business (Article 17-2 of the Electrical Construction Business Act). In that case there is no duty to place a chief electrician, but on-site work requires an Electricians Act qualification (such as a certified electrical worker or a special-type electrical worker).

Q. What happens if I forget to renew and the term lapses?
A. The registration's term is five years, and continuing requires renewal (Article 3 of the Electrical Construction Business Act). If you forget to renew, the registration lapses and you cannot continue to operate without registration. Managing the expiry date and renewing with time to spare is important. When registered matters change, a notification within 30 days is also required (Article 10).

Sources (Primary Information)

  • e-Gov Law Search / Ministry of Economy, Trade and Industry, "Act on the Proper Operation of Electrical Construction Businesses" (Act No. 96 of 1970), Article 2 (definitions), Article 3 (registration; paragraph 2 = 5-year term, paragraph 3 = renewal registration), Article 10 (notification of change to registered matters; within 30 days of the change), Article 17-2 (notification of the start of a self-use-only electrical construction business; by 10 days before the start), Article 19 (placement of a chief electrician; first-class electrician or second-class electrician with 3+ years of practical experience after the licence, the exception in paragraph 2, the two-week appointment in paragraph 3), Article 24 (keeping of instruments), Article 25 (display of signs), Article 26 (keeping of ledgers) and Article 34 (special rules for construction operators; paragraph 2 deemed registration, paragraph 3 deemed notification, paragraph 4 notification, paragraph 5 notification, paragraph 6 lapse of the former registration) (accessed 2026-10-07)
  • e-Gov Law Search / Ministry of Economy, Trade and Industry, "Electricians Act" (qualifications of first-class and second-class electricians; definition of electrical work) (accessed 2026-10-07)
  • e-Gov Law Search / Ministry of Land, Infrastructure, Transport and Tourism, "Construction Business Act", Article 3, paragraph 1 (construction-business licence) (accessed 2026-10-07)
  • Ministry of Economy, Trade and Industry / guides on electrical-business registration, notification and deemed registration of each Industrial Safety and Inspection Department and prefecture (instruments, signs and ledgers per office; notification by 10 days before starting; notification of change on construction-licence renewal; concrete forms, attached documents and destinations differ by authority) (accessed 2026-10-07)

This article is general information and does not judge or guarantee whether a given business falls under registration, notification or deemed registration under the Electrical Construction Business Act, whether the chief-electrician qualification or the keeping of instruments is met, or whether a construction-business licence is required. Reception of registration, notification and deemed registration is by the Minister of Economy, Trade and Industry (the head of the Industrial Safety and Inspection Department) or the prefectural governor, and the concrete forms, fees and attached documents are set by the authority. The preparation of the application documents for registration, deemed registration (notification) and notification of the electrical construction business and guidance on prior consultation are handled by the administrative scrivener of the Yotsuba group as an independent business; commercial registration for company formation and officer changes is by a judicial scrivener; the selection and brokerage of premises for the office and material storage is by Yotsuba Real Estate Co., Ltd., a separate business; tax after opening is by a tax accountant; and the judgment of electricians' qualifications and work scope is by the Ministry of Economy, Trade and Industry and the Industrial Safety and Inspection Department, each contracted separately. Our office receives no referral fee. Individual judgements are made by a qualified professional after a meeting. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.

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