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Administrative Procedures (From the Practice of an Administrative Scrivener)

Designation for employment continuation support (Type A / Type B): requirements and procedure

Watercolor illustration of a small building model set on a floor plan
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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Employment continuation support is a disability welfare service under the Comprehensive Support for Persons with Disabilities Act; Type A provides work under an employment contract, Type B without one. This article organises how the two differ, the staffing, facility and operation standards, the application flow, and who to ask for premises, building, labour, registration and tax.

In short: employment continuation support is a disability welfare service defined in Article 5, paragraph 15 of the Comprehensive Support for Persons with Disabilities Act (Act No. 123 of 2005), offering, to persons with disabilities for whom employment at an ordinary workplace is difficult, work opportunities and productive activity to improve the knowledge and ability needed to work. The biggest difference is that Type A provides work under an employment contract, while Type B provides productive activity without one. To start, you obtain designation as a designated disability welfare service provider (Article 36) from the prefectural governor (in designated cities and core cities, the mayor), per office. The staffing, facility and operation standards are set under Article 43 and given concrete form by the national standard, Ordinance of the Ministry of Health, Labour and Welfare No. 171 of 2006, and by each municipality's ordinance. Eligibility and conformity with the standards are decided by the designating authority's review, and our office does not guarantee designation.

How do Type A and Type B differ in designation requirements?

Employment continuation support is defined in Article 5, paragraph 15 of the Comprehensive Support for Persons with Disabilities Act, providing work opportunities and, through opportunities for productive and other activities, the training and other benefits needed to improve the knowledge and ability to work. The Type A / Type B distinction is not in the Act's definition itself but is set in Ordinance No. 171 of 2006 (on the staffing, facilities and operation of designated disability welfare service businesses). The biggest difference is "whether an employment contract is concluded with the user".

ItemType AType B
Relationship with the userAn employment contract is concludedNo employment contract
PaymentWages (the Minimum Wage Act applies)Piece-rate reward (paid by results)
Main targetThose who can work continuously with a degree of supportThose for whom work under an employment contract is difficult
Balance of productive activityThe revenue of the productive-activity business, less necessary expenses, should be at least the total of wagesThe average monthly reward should in principle be no less than 3,000 yen

Because Type A concludes an employment contract with users, the Labour Standards Act and the Minimum Wage Act apply. Whether the work amounts to that of a worker, and how to design working hours, wages and work rules, are the field of a certified social insurance and labour consultant, who contracts with you separately as an independent business. Type B does not use an employment contract; it pays a piece-rate reward according to the results of productive activity, and the average is set by the operation standard so as not to fall in principle below 3,000 yen a month (Ordinance No. 171 of 2006).

On 1 October 2025 (Reiwa 7), "employment selection support" (Article 5, paragraph 13 of the Act) was newly established, and those newly seeking to use Type B are, in principle, moving in stages to a scheme of using employment selection support before applying. Confirm the scope and timing with the municipality's practice.

How many staff (service manager, vocational instructor, life-support worker) does designation require?

The staffing standard is set in Ordinance No. 171 of 2006 and given concrete form by municipal ordinances. The basic placement common to Type A and Type B is as follows.

RoleApproach to placement
Vocational instructor / life-support workerThe total, on a full-time-equivalent basis, is at least the number of users divided by 10 (10 to 1); at least one vocational instructor, at least one life-support worker, and at least one of them full-time
Service managerOne or more for up to 60 users; for 61 or more, one added per 40 users (including any fraction); at least one full-time
ManagerIn principle one dedicated full-time person (may hold a concurrent post if there is no hindrance)

The total of vocational instructors and life-support workers is set at "at least the number of users divided by 10, on a full-time-equivalent basis" in Article 186 for Type A and Article 199 for Type B. In Type B there is a category, under certain requirements, of a richer placement (7.5 to 1) that changes the reward evaluation, but that is a matter of the reward notification; the minimum standard required for designation is 10 to 1. The employment contracts, working-hour design, work rules and social-insurance application that meet the staffing standards are the field of a certified social insurance and labour consultant, who contracts with you separately as an independent business.

What documents and structure do the facility and operation standards require?

The facility standard (Ordinance No. 171 of 2006) requires a training/work room, a consultation room, washbasins, toilets, a multi-purpose room and other facilities needed for operation. Designation in principle requires a capacity of 20 or more users (the approach differs for multi-function offices, which combine several services). The points premises most often fall short on are as follows.

Facility / structureMain requirement
Training/work roomAn area that does not hinder training and work; equipped with necessary machinery and tools
Consultation roomAble to protect privacy, e.g. by partitions
Washbasins / toiletsNumber and specification suited to users' characteristics
Operation rulesSet out the purpose and policy, roles and numbers of workers, business days and hours, and capacity
Individual support planPrepared by the service manager and reviewed regularly

When you turn an existing building such as an office or shop into an office, it may require a change of use under the Building Standards Act, or additional fire-protection equipment under the Fire Service Act. Whether a change-of-use confirmation application is required and its design are for a licensed architect (the designer); the need for fire-protection equipment and the fire consent are for the fire department. The first-line check of use zone and area is handled by the real estate company; our company provides the property information and does not make the building-confirmation or fire judgement. For related types of designation, see also Designation for daily-life care and the premises requirements and The flow of the designation application for after-school day service and child development support.

Where and in what order do you file the designation application?

Designation is made per office by the prefectural governor (in designated cities and core cities, the mayor) (Article 36, paragraph 1). The general flow is as follows; because things are easily sent back if the order is reversed, start the prior consultation early.

  1. Fix the business plan and funding plan, and establish a corporation (add disability welfare services to the purpose in the articles of incorporation).
  2. Choose premises and confirm conformity with the facility standards, the Building Standards Act and the Fire Service Act.
  3. Hold a prior consultation with the designating authority.
  4. Secure a service manager, vocational instructors and life-support workers.
  5. Prepare the application and attached documents and submit them by the deadline.
  6. Document examination and, as necessary, on-site confirmation.
  7. Designation (in many municipalities, as of the first day of a month).

Many municipalities grant designation as of the first of the month, and the submission deadline is generally set in the month or two months before the desired date. Deadlines differ by designating authority and may be brought forward at the change of fiscal year, so always confirm on the relevant municipality's official page. Typical documents are the designation application and appendix, the corporation's certificate of registered matters and articles of incorporation, the office floor plan, photographs and lease, the operation rules, the workers' forms-of-duty list with certificates of qualification and proof of practical experience, the completion certificate of service-manager training, the income and expenditure budget and various written pledges.

Have a question about your situation?

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

Within the scope of administrative-scrivener work, Yotsuba Administrative Scrivener Office supports the preparation of the application, appendix and attached documents, the organisation of prior-consultation materials, and the drafting of the operation rules. The final judgement of conformity and eligibility for designation is made by the designating authority's review.

After designation, what should you grasp first about operation guidance and reward claims?

After designation, records and a structure in line with the operation standards must be maintained, and you become subject to the municipality's operation guidance. Keeping service records, individual support plans, duty records and management of rewards/wages ready day to day is the shortest way to reduce findings during guidance.

Rewards (training-etc. benefits) are set by the "notification on disability welfare service etc. rewards" and are in principle claimed from the National Health Insurance Federation. Type A uses a score method that scores each office's initiatives, and Type B has basic-reward categories according to figures such as the average monthly reward (both under the notification as at the reference date 2026-09-23; categories and add-ons change with revisions, so confirm the latest notification). In particular, for Type A, the revenue of the productive-activity business less necessary expenses must be at least the total of wages; where this is not met, submission of a management-improvement plan is required. The calculation and clerical work of reward claims and tax are not our office's work; consult a tax accountant for accounting and tax and the operator or a specialist billing agent for the claim practice.

Who should you ask for premises, building, labour, registration and tax?

The designation application crosses several fields of expertise. The roles are divided as follows.

  • Preparation of the application, appendix and attached documents, and support for prior consultation → Yotsuba Administrative Scrivener Office (administrative scrivener)
  • Selection, lease and important-matters explanation of business premises, and the first-line check of use zone and area → Yotsuba Real Estate Co., Ltd.
  • The change-of-use confirmation application and design, and checking existing non-conformity and the inspection certificate → a licensed architect (the designer)
  • Judgement on whether fire-protection equipment is required, and fire consent → the fire department
  • Employment contracts, work rules, working-hour management and social-insurance application that meet the staffing standards, and the worker status and minimum wage of Type A users → a certified social insurance and labour consultant
  • Corporate establishment and change registration → a judicial scrivener
  • Corporate accounting, tax and tax calculation, and the bookkeeping accompanying reward claims → a tax accountant
  • Individual legal judgement on rights, obligations and disputes → an attorney

Yotsuba Administrative Scrivener Office and Yotsuba Real Estate Co., Ltd. are separate businesses. Our office handles only support for the designation application as an independent business, and premises, building, fire, labour, registration and tax are contracted separately with each qualified professional or counter. Our office receives no referral fee. For the whole picture, see Licensing of Disability Welfare Services; for the flow of engagement, see Engagement Flow; and for fees, see Fee Schedule.

FAQ

Q. Can one office be designated for both Type A and Type B?
A. There is a way to be designated as a multi-function office combining Type A and Type B in one office. Because the approach to staffing, facilities and capacity differs from the single type, confirm with the relevant municipality's ordinance and guide. Employment contracts and labour management meeting the staffing standards are the field of a certified social insurance and labour consultant, who contracts with you separately as an independent business.

Q. Is what a Type A office pays users a salary or a piece-rate reward?
A. Because Type A concludes an employment contract, what is paid is wages, to which the Minimum Wage Act applies. A piece-rate reward is what is paid in Type B, which does not use an employment contract. The worker status and minimum wage of Type A users are the field of a certified social insurance and labour consultant, contracted separately as a separate business.

Q. Can I use an office or shop as it is for the business?
A. Besides area and facilities, existing buildings may need a change-of-use confirmation application or additional fire-protection equipment. The change-of-use judgement is confirmed with a licensed architect (the designer) and the need for fire-protection equipment with the fire department. Premises are with the real estate company and building confirmation with the architect, each contracted separately as a separate business.

Q. How far does the administrative scrivener go?
A. Within the scope of administrative-scrivener work, we support the preparation of the application, appendix and attached documents, the organisation of prior-consultation materials, and the drafting of the operation rules. The final judgement of conformity and eligibility for designation is made by the designating authority's review. Labour, registration, tax and reward claims are each with the respective qualified professional or counter, contracted separately as an independent business.

Sources (Primary Information)

  • e-Gov Law Search, "Act on Comprehensively Supporting the Daily and Social Lives of Persons with Disabilities" (Act No. 123 of 2005), Article 5, paragraphs 13 and 15, Article 36, paragraph 1, and Article 43 (accessed 2026-09-23)
  • e-Gov Law Search / Ministry of Health, Labour and Welfare, "Standards concerning the staffing, facilities and operation of designated disability welfare service businesses" (Ordinance of the Ministry of Health, Labour and Welfare No. 171 of 2006), Article 186 (Type A workers) and Article 199 (Type B workers), etc. (accessed 2026-09-23)
  • Ministry of Health, Labour and Welfare, awareness materials on "employment selection support" (effective 1 October 2025) (accessed 2026-09-23)
  • Ministry of Health, Labour and Welfare, "notification on disability welfare service etc. rewards" (basic rewards for employment continuation support Type A and Type B) (accessed 2026-09-23)
  • The designation-application guides and ordinances of each municipality (prefecture, designated city or core city) (accessed 2026-09-23)

This article is general information and does not guarantee individual eligibility for designation, conformity with the staffing, facility and operation standards, the need for a change-of-use confirmation application or fire-protection equipment, the application schedule, or the applicable reward category. The final review of designation is made by the designating authority (prefecture, designated city or core city). Confirm whether a change-of-use confirmation application is required and its design with a licensed architect (the designer), the need for fire-protection equipment and fire consent with the fire department, and the deadlines, forms and required documents on the relevant municipality's official page. Selection, lease and important-matters explanation of business premises are handled by Yotsuba Real Estate Co., Ltd.; employment contracts, working-hour management and social-insurance application meeting the staffing standards and the minimum wage of Type A users by a certified social insurance and labour consultant; corporate establishment and change registration by a judicial scrivener; accounting and tax by a tax accountant; and individual legal judgement on rights, obligations and disputes by an attorney, 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.

Let's start by sorting out your situation.

Yotsuba Gyoseishoshi Office (Kohinata, Bunkyo-ku; a 5-minute walk from Myogadani Station on the Tokyo Metro Marunouchi Line) supports you from organizing the requirements through document preparation and application.

LINE connects you directly to our representative, Joji Uramatsu. Messages are accepted 24/7 and answered in order.

5 min walk from Myogadani Sta. (Tokyo Metro Marunouchi Line)|Tue & Wed 10:00–19:00 / Mon, Thu–Sun 18:00–19:00