Certification for automobile specified maintenance (formerly dismantling maintenance): requirements and how to proceed

In short: to carry out automobile specified maintenance (the former dismantling maintenance plus electronic-control-device maintenance) as a business, you need certification from the District Transport Bureau Director under Article 78 of the Road Transport Vehicle Act, for each business site. The certification standard is in Article 80: you must meet the scale of the work area and vehicle yard (Appended Table 4 of the Enforcement Regulations of the Road Transport Vehicle Act), the personnel such as the maintenance supervisor (Article 62-2-2 of the same Enforcement Regulations), and equipment such as work machines, tools and a scan tool. You apply through the Transport Branch Office with jurisdiction over the site (addressed to the District Transport Bureau Director). The reform effective 1 April 2020 expanded the former "dismantling maintenance" into "specified maintenance," newly adding electronic-control-device maintenance relating to automated driving devices and driver-assistance. This article is general information organising the scope of maintenance that requires certification, the personnel and equipment requirements, the 2020 reform, the application flow, and who to hand the property, registration and tax matters to. The grant of any individual certification and the required documents are a matter for the Transport Branch Office with jurisdiction.

When does specified-maintenance certification become necessary?

Specified maintenance is defined in Article 3 of the Enforcement Regulations of the Road Transport Vehicle Act. Items 1 to 7 correspond to the former "dismantling maintenance," covering maintenance and modification that involves removing the engine, power-transmission device, running gear, steering device, braking device, suspension device and coupling device. Items 8 and 9 are the "electronic-control-device maintenance" added in 2020, covering the removal and adjustment (so-called aiming) of cameras, radar and other sensors used for automated driving devices and driver-assistance such as collision-damage-mitigation braking and lane-departure warning.

Where you carry out this specified maintenance as a business, for consideration and repeatedly in response to others' demand, Article 78, paragraph 1 of the Road Transport Vehicle Act requires certification from the District Transport Bureau Director. Certification is obtained for each business site, specifying the type of specified-maintenance business (dismantling maintenance or electronic-control-device maintenance) and the type of vehicle covered (ordinary, small, light, large, etc.). Carrying out specified maintenance as a business without certification is a legal violation subject to penalties.

Item	Content
Basis	Road Transport Vehicle Act, Article 78, paragraph 1 (certification of automobile specified maintenance business)
Scope	Dismantling maintenance (Enforcement Regulations Article 3, items 1–7) / electronic-control-device maintenance (items 8–9)
Unit	Per business site, specifying the type of business and the type of vehicle covered
Where to apply	Transport Branch Office with jurisdiction over the site (addressed to the District Transport Bureau Director)

Whether the maintenance done at your own workshop falls under dismantling maintenance or electronic-control-device maintenance depends on the content of the work. If in doubt, consulting the Transport Branch Office with jurisdiction in advance, against your business plan, is the reliable course.

What are the personnel (maintenance supervisor, staff) and equipment requirements?

Article 80 of the Road Transport Vehicle Act sets the standard the District Transport Bureau Director applies when examining an application, providing that certification must not be granted where the equipment, employees and work-management status of the site do not meet the standards prescribed by ministry ordinance. In practice the requirements divide broadly into personnel requirements and equipment/work-area requirements.

Category	Main requirements
Maintenance supervisor	Appointed under Article 62-2-2 of the Enforcement Regulations. A Class 1 or Class 2 automobile mechanic qualification is required. For electronic-control-device maintenance, completion of the maintenance-supervisor qualification training conducted by the Transport Branch Office Director is in principle required (Class 1 large and Class 1 small mechanics are exempt from the training)
Staff	Secure the number of workers appropriate to the type of vehicle covered and the work
Equipment	Work machines and tools needed for the work. Electronic-control-device maintenance requires a scan tool meeting the performance and function requirements, a level and the like
Work area and vehicle yard	An indoor work area and vehicle yard of the scale listed in Appended Table 4 of the Enforcement Regulations (the figures differ by the type of vehicle covered)

The scan tool, which has been required for electronic-control-device maintenance, is being extended by the ordinance amendment of 8 July 2025 so that sites performing dismantling maintenance of engines and the like must also equip one. The specific frontage, depth and area of the work area and vehicle yard follow Appended Table 4 of the Enforcement Regulations, but differ by type of vehicle, so checking against the Transport Branch Office's standards before deciding on a property helps avoid a return of the papers. For the property-side requirements of the work area and vehicle yard, also see Property requirements for an automobile maintenance workshop (certified workshop), compiled by Yotsuba Real Estate Co., Ltd., a separate business.

What changed for electronic-control-device maintenance in the 2020 reform from dismantling maintenance?

With the spread of automated-driving and driver-assistance technology, the Enforcement Regulations of the Road Transport Vehicle Act were amended, and from 1 April 2020 the former "dismantling maintenance" was expanded into "specified maintenance." This reform newly brought electronic-control-device maintenance within certification, alongside dismantling maintenance that removes mechanical parts.

Item	Content
Effective date	1 April 2020
Change	Expanded "dismantling maintenance" into "specified maintenance" and added electronic-control-device maintenance
Scope of electronic-control-device maintenance	Removal and adjustment (aiming) of cameras, radar and other sensors relating to automated driving devices and driver-assistance
Transitional measure	Operators performing electronic-control-device maintenance by 31 March 2020 could continue without certification until 31 March 2024, but this transitional measure has already ended

Because the transitional measure ended on 31 March 2024, aiming and other electronic-control-device maintenance can no longer be performed without certification. Even a workshop already certified for dismantling maintenance needs a separate certification (a change or addition application) to add electronic-control-device maintenance.

What documents does the certification application need, and what is the flow at the Transport Branch Office?

Under Article 79 of the Road Transport Vehicle Act, you apply to the District Transport Bureau Director through the Transport Branch Office with jurisdiction over the site. The main flow and documents are as follows.

Stage	Content
Prior consultation	Organise the work-area drawings, equipment and personnel, and consult the Transport Branch Office with jurisdiction in advance
Document preparation	Certification application; maintenance-supervisor appointment notification; a staff list and documents proving mechanic qualifications; layout drawings and photographs of the work area and vehicle yard; a certificate of registered matters for the land and building or the lease; for a company, a certificate of registered matters, etc.
Application and examination	Apply at the Transport Branch Office. A document examination and, as needed, an on-site inspection of the work area and equipment
Certification and display	After certification, display the certification sign and keep a specified-maintenance record book to record work

Preparation of the certification application and its attachments is, as preparation of documents submitted to public offices, something an administrative scrivener can support within the scope of the work. Within the scope of administrative-scrivener work, Yotsuba Administrative Scrivener Office supports preparing the certification application, the maintenance-supervisor appointment notification and the like. The specific required documents and the necessity of an on-site inspection are a matter for the Transport Branch Office with jurisdiction.

Note that a certified workshop (Article 78) and a designated workshop under the designated automobile maintenance business (Article 94-2, a so-called private inspection workshop) are separate schemes. A designated workshop conducts the completion inspection in-house and can issue a certificate of conformity to safety standards, whereas a certified workshop is inspected at the Transport Branch Office. The designation application for a designated workshop can also be supported by an administrative scrivener as preparation of documents submitted to public offices.

Who should I ask about the property requirements, company incorporation and tax?

Obtaining specified-maintenance certification involves not only document preparation but property, registration, labour and tax. The roles divide as follows.

• Preparing the certification application for the specified-maintenance business (dismantling maintenance / electronic-control-device maintenance), the designation application for a designated workshop, and the maintenance-supervisor appointment notification → Yotsuba Administrative Scrivener Office (administrative scrivener)
• Searching for the work-area and vehicle-yard property, checking the zoning and title to use, and the lease → Yotsuba Real Estate Co., Ltd. (licensed real estate broker)
• Registration such as company incorporation and change of officers, and registration of ownership of land and buildings → a judicial scrivener (registration of description such as building description and subdivision is by a land and house surveyor)
• Employees' labour and social insurance enrolment, work rules and the Article 36 agreement → a certified social insurance labour consultant
• Consultation and filing for corporate tax, income tax, consumption tax and other tax matters → a tax accountant

Yotsuba Administrative Scrivener Office and Yotsuba Real Estate Co., Ltd. are separate businesses. Each field is on the premise that you contract separately with each qualified professional as an independent business, and our office receives no referral fee. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for the whole picture, see Permits and Applications. Where you also run a transport business, also see Office and garage requirements for general freight motor vehicle transport and Notification for light-vehicle freight transport (black number plates).

FAQ

Q. What is the difference between a certified workshop and a designated workshop (private inspection workshop)?
A. A certified workshop is one that can perform specified maintenance under Article 78 of the Road Transport Vehicle Act, and the completion inspection for the continuous inspection (shaken) is done at the Transport Branch Office. A designated workshop is a designated automobile maintenance business under Article 94-2 of the same Act, a so-called private inspection workshop that conducts the completion inspection in-house and can issue a certificate of conformity to safety standards. To obtain the designation, you must, on the premise of certification, meet stricter standards for equipment, personnel and inspection systems. An administrative scrivener can support the application documents for either, as preparation of documents submitted to public offices.

Q. Is certification needed even if I only do aiming (adjusting cameras and radar)?
A. Removal and adjustment (aiming) of cameras, radar and other sensors relating to automated driving devices and driver-assistance is electronic-control-device maintenance under Article 3 of the Enforcement Regulations of the Road Transport Vehicle Act, and performing it as a business requires certification under Article 78. The transitional measure granted to operators performing it by 31 March 2020 ended on 31 March 2024, and it can no longer be performed without certification.

Q. Can certification be obtained for a leased property?
A. If you have title to use the work area and vehicle yard, a leased property can also be the subject of certification. In the application you show the title to use with the lease for the land and building. However, the scale of the work area and vehicle yard (Appended Table 4 of the Enforcement Regulations) and the use must be satisfied, so checking the property-side requirements before signing is the reliable course. It is safer to check the property-side requirements with a licensed real estate broker.

Q. Who can prepare the certification application documents?
A. The certification application and its attachments are documents submitted to public offices, and their preparation can be supported by an administrative scrivener within the scope of the work. The lease of the work-area and vehicle-yard property is by a licensed real estate broker; registration such as company incorporation is by a judicial scrivener; labour is by a certified social insurance labour consultant; and tax is by a tax accountant, each as an independent business under a separate contract. Our office receives no referral fee.

Sources (Primary Information)

• e-Gov Law Search, "Road Transport Vehicle Act" (Act No. 185 of 1951), Articles 78, 79, 80 and 94-2 (accessed 2026-08-31)
• e-Gov Law Search, "Enforcement Regulations of the Road Transport Vehicle Act" (Ministry of Transport Ordinance No. 74 of 1951), Article 3 (definition of specified maintenance), Article 62-2-2 (maintenance supervisor) and Appended Table 4 (scale of the work area and vehicle yard) (accessed 2026-08-31)
• Ministry of Land, Infrastructure, Transport and Tourism, "On the automobile specified maintenance business" (expansion from dismantling maintenance to specified maintenance, addition of electronic-control-device maintenance, effective 1 April 2020, transitional measure ended 31 March 2024) (accessed 2026-08-31)
• Ministry of Land, Infrastructure, Transport and Tourism and the District Transport Bureaus, "Explanatory materials for obtaining automobile specified maintenance certification" (work area and vehicle yard, maintenance-supervisor qualification training, equipment such as the scan tool, certification application documents) (accessed 2026-08-31)

This article is general information and does not guarantee the grant of any individual certification, the required documents, the scale of the work area or vehicle yard, or the necessity of an on-site inspection. The certification standards and forms, and the schedule and fee of the maintenance-supervisor training, differ by Transport Branch Office and registered training body, so check the latest guidance of the authority to which you apply. Searching for and leasing the work-area and vehicle-yard property is handled by Yotsuba Real Estate Co., Ltd. (licensed real estate broker); company incorporation and ownership registration by a judicial scrivener; employees' labour and social insurance by a certified social insurance labour consultant; and tax by a tax accountant, each as an independent business under a separate contract. 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.