The 2025 tightening of safety rules for light-cargo delivery: the duty to appoint a safety manager and keep operating records

In short: light-cargo delivery (light motor-truck transport) had its safety rules tightened by the 2024 amendment (the Act Partially Amending the Act on Comprehensive Promotion of Distribution Business and the Motor Truck Transport Business Act = Act No. 23 of 2024), which obliges operators to appoint a "light motor-truck safety manager." The basis is Article 36-2 of the Motor Truck Transport Business Act. The rules on operators take effect on 1 April 2025, and an operator carrying cargo with a four-wheel or larger light vehicle must appoint one safety manager per business office, have them complete the registered training provider's light motor-truck safety manager training, and notify the Minister of Land, Infrastructure, Transport and Tourism of the appointment. Together with this, the preparation and retention of operating records and accident records, and accident reporting, became duties under ministerial ordinance. We (an administrative scrivener) handle the business notification and the preparation and filing of the appointment notification. The management of working hours and compliance with the Improvement Standards Notice (Standards for Improving the Working Hours, etc. of Motor Vehicle Drivers) after appointment are for a labor and social security attorney; matters involving driver's licences or administrative dispositions are for the competent Public Safety Commission or a lawyer — each on the premise that you contract with each as an independent business. The lease of premises such as a business office or garage is handled by Yotsuba Real Estate Co., Ltd., a separate business. This article is general information and does not guarantee individual appointment requirements or acceptance of a notification. Because the fine detail may change with how the system is run after it takes effect, confirm with the competent Transport Branch Office and official materials immediately before filing. Our office receives no referral fee.

What changed in the safety rules for light cargo from April 2025?

Light-cargo delivery (light motor-truck transport), whose vehicle numbers have surged as a backbone of home delivery and last-mile work, had its safety measures tightened against a background of rising accidents. The amending act is Act No. 23 of 2024 (promulgated on 15 May 2024), and the related ordinances (the amendment of the Safety of Transport Regulations for the Motor Truck Transport Business, and the ordinance partially amending the Motor Vehicle Accident Report Regulations, etc.) were promulgated on 1 October 2024. Enforcement is phased: the part on the registration of training providers took effect on 1 November 2024, and the part regulating light motor-truck transport operators (the appointment of a safety manager, operating records, and so on) took effect on 1 April 2025.

The main new duties for operators are as follows. Because the ordinances set the fine detail, confirm the forms and place of retention in official materials immediately before filing.

New duty	Content	Example excluded from scope
Appointing a light motor-truck safety manager	Appoint one per business office and have them complete the training (Article 36-2 of the Motor Truck Transport Business Act)	An operator transporting only with two-wheel vehicles (so-called motorcycle courier)
Preparing and retaining operating records	Record each day's start/end points and the distance driven, and retain for one year	A two-wheel-only operator
Preparing and retaining accident records	Record the outline, cause, and recurrence-prevention measures of accidents, and retain	—
Accident reporting	Report accidents of a certain scale or larger to the Minister through the Transport Branch Office	—
Guidance and aptitude tests for drivers	Special guidance and aptitude tests for accident-causing, newly hired, and elderly drivers, and keeping a driver ledger	A two-wheel-only operator

What is covered here is the safety rules newly added by the 2024 amendment. The business notification to start light cargo itself is organised in The business notification for light cargo (light motor-truck transport), and if your fleet grows and you move to a general motor-truck transport business (green plates), in The licence and the business-office and garage requirements for a general motor-truck transport business. For the registration and licensing of consigned-freight forwarding undertaken from shippers, see also Freight forwarding business (first and second class) registration and licence.

Whom do you appoint as the light motor-truck safety manager, and by when must you notify?

Article 36-2 of the Motor Truck Transport Business Act requires a light motor-truck transport operator carrying cargo with a four-wheel or larger light vehicle to appoint one light motor-truck safety manager per business office promptly after making the business notification. Even an operator working alone must appoint someone who meets the requirements — namely that person themselves (a two-wheel-only motorcycle courier is outside the scope).

Who may be appointed is one of the following.

Who may be appointed	Requirement
A training graduate	A person who completed the light motor-truck safety manager training run by a registered training provider within two years before the appointment date
A person who also completed the periodic training	A person who completed the above training and, in addition, the light motor-truck safety manager periodic training within two years before the appointment date
An operation manager	Where the operator also runs a general or specified motor-truck transport business, a person appointed as the operation manager at that business office

When you appoint (and when you dismiss), you notify the Minister of the safety manager's name and so on without delay, as prescribed by ministerial ordinance. In practice the window is the competent Transport Branch Office, and the appointment notification is accompanied by a certificate of completion of training completed within two years before the appointment date. After appointment, except for a person who doubles as the operation manager, you must have them take periodic training every two years. Confirm the fees, payment deadlines, and training schedule in the official guidance of the training provider and the Transport Branch Office.

What records and reports become newly necessary?

Along with appointing a safety manager, records and reports on daily operations and accidents became duties. Because ordinances such as the Safety of Transport Regulations for the Motor Truck Transport Business set the fine detail, confirm the forms and retention methods in official materials.

• Operating records: record each day's start point, end point, and the distance driven, and retain them for one year.
• Accident records: record the outline, cause, and recurrence-prevention measures of an accident, and retain them (the retention period follows the ordinance; the Ministry's guidance states three years for accident records).
• Accident reporting: report accidents of a certain scale or larger, such as those causing casualties, to the Minister through the Transport Branch Office.
• Guidance and aptitude tests for drivers: provide special guidance and aptitude tests for accident-causing, newly hired, and elderly drivers, and prepare a light motor-truck driver ledger kept at the business office.

Records are not "make them and be done"; the aim of the system is that the safety manager uses them to secure the safety of operations. Operating records relate to the management of working hours as well, but the preparation and retention of records is a duty on the safety-rules side of the transport business, while the management of working hours themselves is, as below, a matter of the labor framework.

What should an operator already in business do?

For an operator already running light cargo, there is a transitional measure (grace period) for appointing a safety manager. An operator that had made the business notification for light motor-truck transport by the end of March 2025 is given a grace of two years after enforcement and need only appoint a safety manager by March 2027. An operator that makes the business notification on or after April 2025 has no grace and appoints one promptly before starting the business. For guidance and aptitude tests for drivers and for maintaining the driver ledger, a grace of three years after enforcement is provided.

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Category of operator	Deadline to appoint a safety manager
An existing operator that notified by the end of March 2025	Appoint by March 2027
An operator that notifies on or after April 2025	Appoint promptly by the start of business

Even with a grace period, since completion of training must be within two years before the appointment date, putting training off can leave you unable to appoint in time if it coincides with a period when bookings are hard to get. An existing operator, too, is safer to secure a training date early and to prepare the form of operating records in advance. For the whole picture of each procedure and the scope we handle, see Services; for the flow of engagement, see Engagement Flow.

Who handles the notification and the labor framework?

Responding to the tightened safety rules for light cargo overlaps two things: "notification to the authorities" and "the in-house labor framework." Because the fields differ, they are divided and handed off on the premise that you contract with each as an independent business.

• The business notification, the notification of changes, and the preparation and filing of the notification of the light motor-truck safety manager's appointment → an administrative scrivener (us; Article 1-3 of the Administrative Scrivener Act)
• The management of working hours, designing a duty roster and restraint/rest hours in line with the Improvement Standards Notice (Standards for Improving the Working Hours, etc. of Motor Vehicle Drivers), work rules, and social and labor insurance procedures → a labor and social security attorney (a separate business)
• Individual judgements or disputes involving the class and aptitude of driver's licences, and administrative dispositions (suspension or revocation of a licence) → the competent Public Safety Commission or a lawyer
• The lease of business premises such as a business office or garage → a real estate broker (Yotsuba Real Estate Co., Ltd., a separate business)

What the administrative scrivener handles is preparing and filing the notification documents and organising materials to pass to each professional. We do not make definitive judgements on compliance with working hours or the Improvement Standards Notice, or on an individual legal outlook. Where you receive foreign drivers for trucks, buses, or taxis, the labor side and the status of residence overlap with the fields of a labor and social security attorney and an administrative scrivener qualified to file applications. For fees, see Fee Schedule. We can receive your consultation at one window and organise and pass materials to each professional, but the engagements are separate. Our office receives no referral fee.

FAQ

Q. Even if I run light cargo alone, must I appoint a safety manager?
A. Yes. An operator carrying cargo with a four-wheel or larger light vehicle must, even when working alone, have that person themselves complete the training and be appointed as the safety manager per business office. What is outside the scope is an operator transporting only with two-wheel vehicles (a so-called motorcycle courier). Confirm the detail in the Transport Branch Office's guidance immediately before filing.

Q. By when must I appoint a safety manager?
A. An existing operator that had made the business notification by the end of March 2025 has a two-year grace after enforcement and need only appoint one by March 2027. An operator that notifies on or after April 2025 has no grace and appoints one promptly by the start of business. Because completion of training must be within two years before the appointment date, we recommend taking the training early.

Q. How long must operating records and accident records be kept?
A. Operating records of each day's start/end points and the distance driven are retained for one year. Accident records of the outline, cause, and recurrence-prevention measures of an accident are retained (the Ministry's guidance states three years). The forms and retention methods are set by ordinances such as the Safety of Transport Regulations for the Motor Truck Transport Business, so confirm them in official materials.

Q. Can I ask one office to handle everything from the notification to the management of working hours?
A. The business notification and the notification of the safety manager's appointment are for an administrative scrivener (us), while the management of working hours and the duty roster, work rules, and social-insurance procedures in line with the Improvement Standards Notice are for a labor and social security attorney — each contracted separately as an independent business. We can receive your consultation at one window and organise and pass materials to each professional, but the engagements are separate. Our office receives no referral fee.

Sources (Primary Information)

• e-Gov Law Search, "Motor Truck Transport Business Act," Article 36-2 (appointment of a light motor-truck safety manager = a duty for a four-wheel-or-larger light-vehicle operator to appoint one per business office; the persons eligible in paragraph 1 [training graduate, periodic-training graduate, operation manager]; the notification of appointment/dismissal in paragraph 2; the periodic training in paragraph 3) (accessed 2026-10-22)
• Ministry of Land, Infrastructure, Transport and Tourism, "On the system reform of safety measures in the light motor-truck transport business" (the amending act = the Act Partially Amending the Act on Comprehensive Promotion of Distribution Business and the Motor Truck Transport Business Act [Act No. 23 of 2024; promulgated 15 May 2024]; the ordinances promulgated 1 October 2024; enforcement = the training-provider registration part on 1 November 2024 and the operator-regulation part on 1 April 2025; preparation and one-year retention of operating records; preparation and retention of accident records [three years]; accident reporting; guidance and aptitude tests for drivers and the driver ledger; the exclusion of two-wheel motorcycle couriers) (accessed 2026-10-22)
• Ministry of Land, Infrastructure, Transport and Tourism and the regional Transport Bureaus, "Appointment, etc. of a light motor-truck safety manager" guidance (the attachment to the appointment notification = a certificate of completion of training completed within two years before the appointment date; the filing window is the competent Transport Branch Office; an operator working alone is in scope; the transitional measure = an existing operator that notified by the end of March 2025 appoints by March 2027, and the driver ledger etc. have a three-year grace after enforcement) (accessed 2026-10-22)
• Ministry of Health, Labour and Welfare, "Standards for Improving the Working Hours, etc. of Motor Vehicle Drivers" (the Improvement Standards Notice; the review of restraint and rest hours applied on 1 April 2024; the maintenance of the labor framework is the field of a labor and social security attorney) (accessed 2026-10-22)

This article is general information and does not guarantee individual appointment requirements, acceptance of a notification, whether an accident must be reported, or the specifics of a record-retention period. Because the fine detail may change with how the system is run or with ordinance amendments, confirm with the competent Transport Branch Office and official materials immediately before filing. The business notification and the notification of the safety manager's appointment are for an administrative scrivener (us), and the management of working hours and the maintenance of a framework in line with the Improvement Standards Notice are for a labor and social security attorney — each as an independent business under a separate contract. The lease of premises such as a business office or garage is handled by Yotsuba Real Estate Co., Ltd., a separate business, and our office receives no referral fee. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.