Does the Toritekihou apply to your deal?
From the transaction type, each side's capital and regular employee count, the tool checks whether the Toritekihou covers the deal, using the tests of Article 2 of the Act. It does not replace the JFTC's own diagnosis tool. Everything is worked out in this browser; nothing is sent.
This tool needs JavaScript. The rules it applies are listed below.
- This tool works from the text of the Act and JFTC documents. It is information, not legal advice. For your own case ask the JFTC or a lawyer.
The JFTC's own diagnosis tool (about 1 minute): For buyers: are you a 委託事業者 (entrusting business)? / For suppliers: which buyers count as 委託事業者 for you
The tests applied
- Transactions fall in Group A or Group B. Group A: manufacturing, repair and specified-transport orders, plus orders for programs and for the services named by the cabinet order (carriage, warehouse storage, data processing). Group B: all other information-product and service orders (Act Art. 2(8) and 2(9); the cabinet order).
- Capital test, Group A: buyer's capital over ¥300 million and the supplier an individual or at ¥300 million or less; or buyer over ¥10 million up to ¥300 million and the supplier an individual or at ¥10 million or less (Art. 2(8)(i) and (ii), 2(9)(i) and (ii)).
- Capital test, Group B: buyer's capital over ¥50 million and the supplier an individual or at ¥50 million or less; or buyer over ¥10 million up to ¥50 million and the supplier an individual or at ¥10 million or less (Art. 2(8)(iii) and (iv), 2(9)(iii) and (iv)).
- Employee test: used only where the capital test does not apply. Group A: buyer over 300 employees and supplier at 300 or fewer. Group B: buyer over 100 and supplier at 100 or fewer (Art. 2(8)(v) and (vi), 2(9)(v) and (vi); JFTC operating standard, part 2, 2(3)).
- The buyer's tests say "over" and the supplier's say "at most". A buyer with exactly ¥300 million of capital falls in the ¥10 million to ¥300 million row, not the row above. The buyer must be a corporation.
- Capital means paid-in capital or total contributions. Employees are the regular employees on the wage ledger (regular staff, contract staff, part-timers, day labourers kept on for more than a month); group companies are not added together. The count is the number at the time of the order (JFTC Q&A Q7 to Q12).
- What the tool does not decide: whether the deal is an order to the buyer's specification at all, whether a service is for the buyer's own use or is construction, the test for bodies with no capital account (designated net assets), avoidance through subsidiaries (tunnel companies, Art. 2(10)), trades between a parent and a subsidiary of over 50%, trading companies, and deals with foreign parties.
- Orders before 1 January 2026 stay under the old Subcontract Act. Buyers covered only by the employee test, specified-transport orders and orders for the newly added moulds and tools other than dies are not covered for acts before 1 January 2026 (Supplementary Provisions Art. 2).
Read on 9 November 2026: the Act, the cabinet order, the JFTC rule on Article 4 terms, the rule setting the rates under Art. 6(1) and (2), and the rule on Article 7 records, on e-Gov 法令検索; the JFTC operating standard, Q&A, textbook (November 2025) and diagnosis tools; and the Cabinet Office list of national holidays.