Positioning and Overview of the Revision
Placing the 2025 revision in the flow from the 2022 PFI Act amendment and the 2024 guideline revision
Cumulative PFI projects (as of March 31, 2025)
1,154 projects
Of which concession projects
71 projects
Cumulative contract value (end of FY2023)
¥9.25 trillion
Priority Review adoption rate (309/1,788, end of March 2024)
17.3%
On June 4, 2025, the Private Finance Initiative Promotion Council (chaired by the Prime Minister) adopted partial revisions to the Process Guideline (regarding PFI project implementation processes), the Contract Guideline (concerning PFI project contracts), and the Priority Review Guideline (for the introduction of diverse PPP/PFI methods). The PFI Standard Contract 1 (for public-use facility development with service-purchase models) was revised slightly earlier, on May 16, 2025.
The Cabinet Office summarized the intent of the revision as follows.
This article serves as a continuation of our earlier piece on the PFI Act amendments. While the earlier piece addressed the legal layer and Action Plan revision, this article focuses on the guideline-layer differences introduced by the June 4, 2025 revision.
Timeline of the Revision
| Date | Event |
|---|---|
| December 2022 (promulgation) / 2023 (phased enforcement) | PFI Act amendment (target facility expansion, concession simplification, designated administrator coordination) |
| June 3, 2024 | 2024 guideline revision (in coordination with the 2024 Action Plan revision) |
| July 3, 2024 | Cabinet Office administrative notice on "responding to price fluctuations" |
| February 12, 2025 | Price-fluctuation policy proposal presented at the 14th PFI Promotion Committee Project Subcommittee |
| March 12, 2025 | Follow-up report on the 2024 Action Plan revision |
| May 10, 2025 | Public comment period opens |
| ★ June 4, 2025 | ★ Official publication of the revision (Private Finance Initiative Promotion Council decision) |
| September 16, 2025 / corrected October 1, 2025 | Publication of FY2024 PFI project implementation status |
Three Pillars of the Revision
Organizing the changes along price adjustment response, private-sector proposal promotion, and fair return assurance
Pillar 1: Response to Price Fluctuation
The most consequential point is the operational treatment of the basis date and the price index for service-fee adjustment.
(a) Basis Date for Service-Fee Adjustment
The 2024 revision of the Contract Guideline (section 4-4.3) stated that, in light of the spirit of the PFI Act, the basis date for adjustment could be "the contract execution date, or a date prior to it such as the bid notice date." The Japan Federation of Construction Contractors proposed narrowing this operation to "the bid notice date" only, and the policy proposal of February 12, 2025 reflected this direction.
The same policy proposal also noted dissenting views opposing fixing the planned price to the bid notice date. The exact wording in the final guideline text requires direct review of the published Cabinet Office PDFs.
(b) Price Index Selection
The "Real Wage Index" and "Construction Work Deflator," previously cited as examples in the older Contract Guideline, were removed in the July 3, 2024 administrative notice because of their divergence from market prices. The 2025 revision debate compared the following three indices.
| Index | Producer | Frequency | Character |
|---|---|---|---|
| Construction Work Deflator | MLIT, Construction Economy Statistics Office | Monthly | Nominal-to-real conversion |
| Building Cost Index | Construction Price Research Center (CPRC) | Monthly | Time-period and regional comparison |
| NSBPI | Nikken Sekkei Inc. | Quarterly | Private-sector actual construction cost comparison |
The Nikkenren proposal and the Promotion Committee's draft point to the CPRC Building Cost Index as the default reference.
(c) Yokohama City: A Precedent
Yokohama City revised its own PFI guidelines in November 2024, adding "(5) Maximizing private creativity and ensuring an environment in which fair returns are realized" to Chapter 1, Section 3, and explicitly defining the basis date for service-fee adjustment as "the bid notice date prior to the contract date". The example demonstrates that municipalities can move ahead of national policy revisions and offers a reference point for other large cities.
Pillar 2: Private-Sector Proposal Promotion
The revision frames "private-sector proposal promotion" as a response to four structural challenges in PPP/PFI.
| Challenge | Content |
|---|---|
| Challenge 1 | Lack of PPP/PFI knowledge, experience, and know-how |
| Challenge 2 | Procedures are complex, review periods are long, and PPP/PFI is avoided |
| Challenge 3 | Small-scale PPP/PFI projects do not attract private interest |
| Challenge 4 | Limited contact points with private operators |
The revision responds with the following measures.
- Strengthened hands-on support by the PFI Promotion Organization (Public Finance Initiative Promotion Corporation)
- Shortened review-to-contract periods and reduced burdens for PFI projects
- Encouragement of cross-sector and wide-area PPP/PFI
- Promotion of small concession projects
- Awareness-building for LABV (Local Asset Backed Vehicle), in which a municipality contributes real assets to a joint vehicle combining public and private financing
LABV is a UK-originated scheme with limited Japanese precedent. The revision's signal toward awareness-building opens new opportunities for mid-tier operators.
Pillar 3: Fair-Return Assurance
The unifying principle for Pillars 1 and 2 is articulated in the Cabinet Office's official statement: "to build an environment in which private operators can earn fair returns." This translates the "fair returns" principle, first introduced in the 2024 Action Plan revision, into specific contract-level operations.
In a rising price environment, contracts that force fixed prices onto private operators tend to depress entry interest and lead to unsuccessful tenders. The reorganization of basis dates and indices effectively re-designs risk sharing, with mid-tier and smaller operators standing to benefit most.
Reading the Current State from Statistical Data
Latest PFI project counts, contract values, Priority Review adoption rates, and population-scale gaps
PFI Implementation Status (end of FY2024)
As of the end of FY2024, cumulative PFI projects total 1,154, of which 71 are concession projects. New projects in FY2024 numbered 94, of which 14 used the concession method (one project missing from the initial report was added in the October 1, 2025 correction).
Implementation Gaps by Population Scale
PFI implementation varies sharply with population scale.
| Entity Type | Total | Implementing Entities | Implementation Ratio |
|---|---|---|---|
| Prefectures | 47 | 41 | 87.2% (41/47) |
| Designated Cities | 20 | 20 | 100% (20/20) |
| Cities with 200K+ population | 112 | 73 | 65.2% (73/112) |
| Cities/towns with 100-200K population | 148 | 69 | 46.6% (69/148) |
| Municipalities under 100K population | 1,461 | 215 | 14.7% (215/1,461) |
| [Total] | 1,788 | 418 | 23.4% (418/1,788) |
Unimplementation rates are particularly severe at smaller scales. Of municipalities with 50-100K population (237 entities), 70.0% have not implemented PFI; for 10-50K population (692 entities), the rate rises to 84.0%; and for those under 10K population (532 entities), it reaches 93.8% (499/532 entities).
Priority Review Adoption
| Category | Total Entities | Adopted | Adoption Rate |
|---|---|---|---|
| National government | 13 | 13 | 100.0% (13/13) |
| Prefectures | 47 | 47 | 100.0% (47/47) |
| Designated Cities | 20 | 20 | 100.0% (20/20) |
| Cities with 200K+ population | 112 | 90 | 80.4% (90/112) |
| Cities/towns with 100-200K population | 148 | 83 | 56.1% (83/148) |
| Municipalities under 100K population | 1,461 | 69 | 4.7% (69/1,461) |
| [Total] | 1,788 | 309 | 17.3% (309/1,788) |
The 2025 guideline revision of 4 June 2025 widened the Priority Review threshold from 100,000 population to 50,000, yet adoption among municipalities under 100,000 stands at just 4.7%. Beyond refining the guidelines themselves lies a more fundamental layer — more than 90% of small municipalities lack any review framework at all.
Local Company Participation
Of 49 contracts concluded in FY2023 (excluding nationally-led projects, concession-method projects, and projects in major metropolitan designated cities), local companies participated in 96% (47/49) and served as prime contractors in 49% (24/49). Mid-tier local operators have institutionally secured space for participation, though the dynamics differ in major-city and concession-method projects.
Action Plan Progress
The 2024 Action Plan revision set a ten-year target of 650 projects and 30 trillion yen in project volume. The 2026 revision later raised the project volume target to 40 trillion yen over the ten years from FY2022 to FY2031. The priority-sector progress reached 209 projects in three years (209/650 = 32.2%), roughly tracking a linear pace (approximately 65 projects per year). To meet the target, the second half of the decade requires acceleration to roughly 100 projects per year.
On the same day as this guideline revision — June 4, 2025 — the Council also decided the 2025 revision of the PPP/PFI Promotion Action Plan. The progress figures in this article rely on the follow-up report on the 2024 revision (published March 12, 2025); the specific targets in the 2025 revision require separate confirmation.
Implications for Municipal Practice
Operational unification around the bid notice date, accountability for price index selection, and the small-municipality penetration gap
Unit costs and amounts in financial examples without a cited source are illustrative assumptions, not statistically established market rates. Use estimates and comparable records appropriate to the target facility, location and business when preparing a project plan. Distinguish these assumptions from cited statistics and case expenditure.
Pressure Toward Bid-Notice-Date Operation
With the guideline direction pointing to the bid notice date as the basis date, municipalities are likely to standardize on explicitly stating the basis date at the implementation policy stage. Yokohama's precedent shows that municipalities can move ahead, and similar moves at other designated and mid-sized cities are likely.
Accountability for Price Index Selection
The responsibility for selecting "price indices with high sensitivity to market prices" — by work type, cost item, and region — falls on the procuring entity. This signals a departure from sole reliance on the deflator and demands a structured approach to in-contract revision mechanisms.
The Penetration Gap for Small Municipalities
The figures of 93.8% non-implementation among sub-10K municipalities and 4.7% Priority Review adoption for sub-100K municipalities sit at a different layer from guideline refinement. Strengthening PFI Promotion Organization support and leveraging the regional platforms (now established in 91.5% of prefectures — 43/47 as of end of February 2025) will be key to penetration at this layer.
Implications for Private Operators
Institutional grounding for fair returns, prime-contractor requirements, and expanded private-proposal channels
Institutional Grounding for Fair Returns
The reorganization of risk sharing in a rising price environment offers larger benefits to mid-tier and smaller operators. For small operators unable to absorb the risk of fixed-price contracts, the cleaner basis-date and index structure lowers entry hurdles.
Expanded Private-Proposal Channels
Pillar 2's "private-sector proposal promotion" and strengthened PFI Promotion Organization support translate into expanded inbound proposal channels. Institutionalizing private-side proposals before the municipal review begins is favorable for proposal-driven mid-tier businesses.
LABV and Small Concession
Implementation of new schemes remains in its early stage. The FY2025 Small Concession Formation Program selected 7 municipalities (covering closed schools, traditional houses, mixed-use facilities, and former government offices), with expert dispatch underway. Accumulation of precedent cases is only now beginning.
Outlook and Open Questions
The remaining task of reading the revised text directly, implementation of small concession and LABV, and capability gaps by scale
Remaining Task: Reading the Revised Text
The exact phrasing of the revised Process Guideline and Contract Guideline requires direct review of the Cabinet Office PDFs. In particular, the extent to which "the contract execution date, or a date prior to it such as the bid notice date" has been narrowed in the final text is central to contract practice.
Capability Gaps by Scale
The municipal capabilities needed to implement new schemes such as small concession and LABV — internal organization, expert access, and ordinance preparation — pose significant barriers for sub-50K municipalities. Operational support frameworks must advance in parallel with guideline refinement.
Redesigning Performance Metrics
Alongside refined price-fluctuation response, the operation of PFI performance metrics (KPIs) enters a redesign phase. Maintaining fixed cost targets under rising prices risks undermining operator continuity; outcome-based flexible design is required.
Related Articles
PFI Act Amendments — Key Points of the 2024 Revision and Impact on Municipalities
The earlier piece in this series, covering the 2022 PFI Act amendments and the 2024 Action Plan revision
PPP/PFI Method Selection by Fiscal Capacity
Method selection guide aligned with municipal scale and fiscal capacity
Operational Model for Priority Review — Toyoake City Case
Implementation example of Priority Review regulations at the 50K-100K population scale
What to do next
When considering PPP/PFI, review the facility conditions and the municipality's rules.
| # | What to check or consider | Responsible team or contact |
|---|---|---|
| 1 | Check the project's cost against the national reference thresholds of ¥1 billion for projects including construction and ¥100 million a year for operation-only projects, and against your municipality's rules | Budget team |
| 2 | Check the municipality's priority review rules. If none exist, consider developing them with reference to Cabinet Office guidance | Planning team |
| 3 | Check whether user charges are collected and assess expected income. For facilities that can charge users, also examine concession requirements | Departments responsible for each facility |
| 4 | Compare applicable methods using project cost, facility type and expected user fee income. Park-PFI may be an option for urban parks, and small concessions for idle facilities | Responsible department and planning team |
| 5 | Choose a facility to pursue and ask private operators about their interest and project requirements | Market sounding |
Check project cost and the municipality's rules to establish whether priority review applies, then compare methods suited to the facility's use and expected income.
References
Partial Revision of the PFI Guidelines (June 4, 2025) — Cabinet Office, Office for Promotion of Private Finance Initiative (2025)
Response to Price Fluctuations (PFI Promotion Committee 14th Project Subcommittee, Document 2-1) — Cabinet Office, Office for Promotion of Private Finance Initiative (2025)
PPP/PFI Promotion Action Plan (2024 Revision) Follow-up Document 1 — Cabinet Office, Office for Promotion of Private Finance Initiative (2025)
FY2024 PFI Implementation Status — Cabinet Office, Office for Promotion of Private Finance Initiative (2025)
