Survey Research on Miscellaneous School and Quasi-Incorporated Educational Institution Accreditation of Schools for Foreign Nationals

1. Purpose of the Survey

    There are a large number of educational institutions responsible for the education of children of foreign nationals residing in Japan (schools for foreign nationals) which have been accredited by the prefectural governments as “miscellaneous schools” pursuant to Article 134 of the School Education Act and as quasi-incorporated educational institutions pursuant to Article 64 of the Private Schools Act.  There are some which have not been accredited.

    “Policy Relating to Regulatory and System Reform,” approved by the Cabinet in April 2011, (see Document 1) works from a perspective of building and maintaining a domestic framework that makes it easy for foreigners to work in jobs of needed expertise and as researchers as stipulated in the Cabinet decision of Feb. 6, 1990.  The document notes that it is indispensible to improve the educational environment of children, a factor that high-level foreign personnel consider important when choosing a country for work.,  Measures should be taken to “encourage flexible handling of the accreditation of so-called miscellaneous schools.” to improve the educational system of  international schools.

    Under these circumstances, this survey research is to be implemented in order to understand the realities and issues relating to the accreditation of schools for foreign nationals as miscellaneous schools and quasi-incorporated educational institutions and to ensure the stability of school management and the appropriate studies of the children of foreign nationals residing in Japan.


2.1  Current situation of international schools and schools for Brazilian nationals

    With regard to international schools, 32 schools were accredited as of November 2011 as miscellaneous schools and there are some schools which have been accredited by such international accreditation organizations as the International Baccalaureate, WASC (Western Association of Schools and Colleges), ACSI (Association of Christian Schools International) and the CIS (Council of International Schools).  26 schools are members of the JCIS (Japan Council of International Schools). (see Document 2)

    A large number of schools for Brazilian nationals have been established after the amendment of the Immigration Control and Refugee Recognition Act in 1990 and the number of Japanese-Brazilians settling in Japan has increased. Initially there were only educational facilities which were not accredited as miscellaneous schools, but MEXT came to encourage support for the accreditation of schools for Brazilian nationals as miscellaneous schools and quasi-incorporated educational institutions in order to improve the educational environment and administration of such schools. In March 2010, a manual for specific support for acquisition of accreditation as a quasi-incorporated educational institution or miscellaneous school in the MEXT “Research Survey Relating to the Education of Foreign Nationals” was prepared in Japanese and Portuguese, and the number of schools for Brazilian nationals accredited as miscellaneous schools increased and as of November 2011 there are 12 schools. MEXT implements a fact-finding survey every year which includes non-accredited schools for Brazilian nationals and as of May 2011 there were 72 schools.

    In addition to international schools and Brazilian schools, also included are North Korean schools, French schools and German schools.  As of May 2011 there were 127 foreigner schools accredited as “miscellaneous schools” pursuant to Article 134.


2.2  Current situation of accreditation standards about miscellaneous school and quasi-incorporated educational institution and their relaxation based on the guideline from MEXT

    The national government sets Miscellaneous School Regulation to stipulate terms, class hours, number of students, teachers and facility in general.  Prefectures make accreditation of miscellaneous schools and each prefecture sets accreditation standards uniquely.

    MEXT promotes relaxation of accreditation standards to follow the trend of regulation reform.  In June 2004, MEXT revised Miscellaneous School Regulation to relax the standard of school ground size and permit use of other school facilities under designated condition ( See "June 21, 2004" for the enforcement of ministerial ordinances that amend standards for establishing specialized training colleges and those that amend regulations for so-called "miscellaneous schools."  ).  In December 2007, Director of Lifelong Learning Bureau, MEXT announced that the following cases shall be included in approving accreditation of miscellaneous schools and quasi-incorporated educational institutions in special cases and with guarantees of having no obstacle to provide education (See "December 25, 2007," for nationwide efforts to establish specialized training colleges that do not require ownership of school grounds or buildings."  ):

(1)   Schoolhouse and school grounds are of long term rental.  It includes not only rental from national or local government but also private rental.

(2)   Schoolhouse and school grounds can be of short term rental if they have special reasons to accomplish educational goal of schools.

    Following such trend, some prefectures enact miscellaneous school accreditation standards for foreign schools and relax standards.  In these prefectures, the borrowing of school grounds and buildings was permitted based on certain conditions such as borrowing from the national government or local governments, or ensuring long-term, stable use. In addition, with regard to holding funds, the operating expenses had to be a minimum of between 2 and 8 months of the first year’s worth of operating expenditures depending on the particular prefecture, and if the municipality took measures necessary for deteriorating financial conditions, it was possible to establish a school with even a smaller amount of holding funds.

    Seven prefectures that relaxed standards cite the following as reasons: 1) the necessity to guarantee opportunities to learn for the increasing number of children of foreign nationals and enact criteria for miscellaneous schools in accordance with the tough financial circumstances of the schools for the children of foreign nationals; 2) the fact that the Ministry of Internal Affairs and Communications came out with a policy asking prefectures to relax criteria for foreigner schools to be accredited as miscellaneous schools as part of its promotion of a multicultural society; 3) the importance to prepare an educational environment for their children to aim as a prefecture to become an international exchange metropolitan area and to enable foreign residents to participate safely in regional community development; and 4) the financial difficulty of schools for Brazilian nationals to conduct stable school administration.

    Prefectures expected the following impacts from relaxing standards: 1) to secure learning opportunities for the children of foreign nationals, improve educational conditions; 2) to promote school incorporation; 3) the elimination of non-school attendance and support for school attendance; 4) to receive preferential tax breaks, receive public support, achieve the stabilization of school administration reduce the economic burden of the parents, and prepare an educational environment for the children of foreign nationals; and 5) to contribute to the realization of a multicultural society.

    In terms of advantages of being accredited as a miscellaneous school or a quasi-incorporated educational institution, schools point out: 1) the provision of subsidies in accordance with the number of students; 2) the use of student discount commuter passes such as for the JR line; 3) exemption of consumption tax for tuition fees; 4) more chances to visit the town or city council and local assembly for observation tours and to visit and hold exchanges with public elementary and secondary schools; 5) having a role in realizing a multicultural society in the community; 6) increased external credibility; and 7) contribution to continuity of school administration.   

    According to the response from target prefectures of this survey, no particular problems arose to do with the education or administration of the schools for foreign nationals after the implementation of more flexible criteria.

    Owing to such, in the prefectures which implemented flexibility in the criteria, there were the advantages that there was an improvement in the educational environment of the children of foreign nationals and it was confirmed that no problems emerged in the education or administration of the schools for foreign nationals.


2. 3  Opinion about accreditation standards of miscellaneous school and quasi-incorporated educational institution

<Opinion from schools for Brazilian nationals and International schools>

    In the research on schools for Brazilian nationals accredited as miscellaneous schools, schools point out some difficulties to do with being accredited as a miscellaneous school or quasi-incorporated educational institution.  1) They suggest that a long-term lease contract was required for the school grounds; 2) it was difficult to understand the application process since there were a large number of documents; 3) and it was difficult to secure the number of teaching faculty required by the guidelines.  In the future, they suggest that: 1) it would be better to ease the criteria for the school grounds and buildings further: 2) they wish the accounting year would be consistent with the commencement of the business period of schools for Brazilian nationals from February 1 to January 31; and 3) the accreditation criteria should be uniform for each prefecture.  

    In the research on International schools, reasons for not being accredited as miscellaneous schools are: 1) debt asset ratio requirements; 2) insufficient  cash reserves; too expensive to acquire land and buildings; and 4) not having a long-term lease which is preventing school from applying for miscellaneous school status.  


<Opinion from prefectures>

    In the research on prefectures where international schools which have not been accredited as miscellaneous schools or quasi-incorporated educational institutions are located, they answered that they do not plan to relax accreditation standards in terms of schoolhouse and school grounds requirements, operating asset holding requirements and enact standards for foreign schools. The reasons they pointed out are that there were some fears that if the financial base or the organizational structure were to be easily deregulated then it would become difficult to make such guarantees as securing the permanent administration of the schools and the quality of education, and flexible criteria that would enable the stable operation of the schools were unclear.


3. Proposal

    This survey revealed that some believe that establishing schools attended by foreigners as “miscellaneous schools” and “quasi-school corporations” increased the schools’ external credibility by making them more community-oriented, in addition to financial benefits such as subsidies and tax breaks.  The survey thus confirms that such establishment improves the educational environment.     Miscellaneous school accreditation, however, the asset holdings, schoolhouse and school grounds requirements as well as the trouble of making application documents and following procedures all pose a big problem for many foreigner schools, some of which believe they were able to obtain miscellaneous school status thanks to an easing of accreditation standards for foreigner schools on the prefectural level.  Some prefectures are reluctant to ease requirements on schoolhouses, grounds and assets in order to preserve stable school management and education quality.     Prefectures that have already relaxed standards for accreditation screening of such schools and corporations responded that the deregulation has not caused any educational or administrative problems at foreign schools (see Attachment “Survey result of the inquiries to relating agencies and schools for foreign nationals in Japan”).  

    With globalization advancing as it is today, more foreigners will be living right alongside Japanese in Japan and we need to strengthen the education of their children.  These results make clear that relaxation of accreditation standards for “miscellaneous schools” is necessary to improve foreign schools’ educational environment and stabilize their administration with a view to improve the educational environment of children that high-level personnel  consider important when they choose a country for work.  It is necessary to improve the education environment for foreign children, by pursuing accreditation as a miscellaneous school and as a quasi-incorporated educational institution.     In addition to the above points, we can believe it is important to consider Western foreigner schools and Indian schools in addition to the international schools surveyed.  Following measures can be raised:

  • Relaxation of schoolhouse and school grounds requirements

    The national government permits private and short-term rental of schoolhouses and school grounds, but prefectures usually regulate that school should own their houses and grounds, and some prefectures stipulate periods of rental from the central government or local public bodies of 20 years or more.  On the other hand, some prefectures that promote relaxation of schoolhouse and school grounds requirements in order to encourage miscellaneous school certification and improve the educational environment allow private rental or short-term rental of 10 years or more in the condition that local municipality request establishment of schools for foreign nationals to have miscellaneous schools status.  Other conditions are that it is a rental from the government or a local public organization; and that the rental rights are registered as per legal regulations.  These criteria are set by each prefecture based on the standards in other prefectures and on the assets of schools for foreigners inside the prefecture.  MEXT should encourage prefectures to take a more flexible approach to allow private rental or short term rental of schoolhouse and school grounds by providing information to those prefectures.


  • Relaxation of operating asset holding requirements

    Regarding schools’ operating assets, the national government stipulates only that “each fiscal year’s current expenditures be compatible with a balanced budget” and has no regulation about schools’ operating assets.  Prefectures, however, often require that schools have, at the time of accreditation application, cash holdings of between 3 and 12 months of the first year’s worth of operating expenditures.  Some prefectures require 2 months of the first year’s worth of operating expenditures or even zero (in the case of Shiga Prefecture) if the prefecture (for example: Nagano, Aichi, Mie, and Shiga Prefectures) has a clear policy that the municipality where the school for foreigners is located will help students transfer to other schools when the schools is in serious trouble or in serious danger, in order to maintain appropriate attendance rates of students attending schools for foreigners.  The purpose is to promote the miscellaneous school accreditation of schools for foreigners and to improve the educational environment.  However, two months worth of operating expenses is required for the establishment of a quasi-corporate education institution.  These criteria are set by each prefecture based on the standards in other prefectures and on the assets of schools for foreigners inside the prefecture.    The central government encourages prefectures to take a more flexible approach to set lower requirements of schools’ operating expenditures to establish miscellaneous school if local municipality takes necessary measure when the school has a financial difficulty by providing information of those prefectures.  


  • Enacting standards for foreign schools

    Saitama, Nagano, Gifu, Aichi, Shizuoka, Mie and Shiga Prefectures have enacted more flexibility in terms of grounds, school house and operating asset holdings of schools for foreigners, against a backdrop of a growing number of foreigners in Japan, financial trouble facing many such schools, promoting multi-ethnic society and foreigner participation in community building.

    Prefectures with no standards for foreigner schools should enact similar standards while referring to prefectures that already have standards, if they are deemed necessary to build and maintain an educational environment conducive to raising high-level foreign personnel.


    In addition, some schools point out that many complicated documents are required when establishing miscellaneous schools and quasi-school corporations.  Although the application procedure manual is already in Japanese and Portuguese, it would be effective if MEXT produces guidelines of administrative procedure which include good practices of prefectures in several languages to enhance smooth application to get accreditation.

    Those measures will lead to the increased support from local community to schools attended by foreigners, better communication and relationship between schools and local government, and stronger relation between Japanese and foreigners in the society.   


(Other reference opinion from international schools)

 This research is about accreditation standards of miscellaneous school and quasi-incorporated educational institution, but there were opinions from schools for Brazilian nationals and International schools about school system in Japan.  

 1) International schools running internationally recognized curriculum (such as IB) and/or are accredited by internationally recognized accreditation organizations (such as WASC, NEASC, CIS) should be recognized legally as a "school" in a form different from miscellaneous school.

 2)School requires student safety and other relevant information from the local education board.

 3) We request multilingual rather than only Japanese language  services in terms of administrative documents and announcements.


    For international schools, information we are asked to provide annually to the government, the format and kind of questions asked are often inappropriate for the kind of school we are, since we have an academic year (mid-August to mid-June), making it burdensome to follow Japan’s financial year.  The financial year for miscellaneous schools should be considered.

    I believe that international schools have an important role to play in creating human resources to work actively on a global scale. I think that it would be beneficial to Japan to recognize the contributions that international schools make to their communities.

    Japan’s policies do little to encourage or support international schools.  This short sighted approach fails recognize the contributions our schools make in providing an environment conducive to foreign business investment in Japan.  

    The survey committee gave opinions from a perspective of ensuring the quality of schools for foreign nationals on issues such as making clear teacher certification standards for foreigner schools; how to treat teacher certification obtained abroad; course credit for matriculation to ordinary Article 1 public schools; health checks, disaster mutual aid and other ways to improve the environment for children’s health and safety.  Some of these criticisms relate to the legal position of foreigner schools and touch upon the core of our country’s school education system.  It will require long-term deliberation.





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