The Japan Federation of Bar Associations (JFBA) has been requesting fundamental reform of the administrative complaint review system, which is one of the critical issues for reforming the administrative legal system, and published the "Opinions Requesting Fundamental Reform of the Administrative Complaint Review System" on July 20, 2006. The Study Group of the Ministry of Internal Affairs and Communications on Administrative Complaint Review System has been working on revision of the Administrative Complaint Review Act since October 2006 and published an interim report in this April as a specific proposal for the reform.

Appreciating that this interim report was a first step toward revision of the act which had not been reviewed for over forty years, the JFBA, however, requested further reform and as its concrete proposal released a proposed amendment to the administrative complaint review system on May 2, 2007.

The draft amendment of the JFBA is to establish a new system to request correction of administrative activities. It also expands the extent of administrative activities which is subject to the correction system to the activities performed by administrative organs which could infringe on rights and interests of the people. Based on the interpretation that the eligibility to make administrative appeals should be wider, the draft expressly provides for the wider eligibility to request a correction than the scope of the eligibility for plaintiffs to file appeal lawsuits. Furthermore, it proposes the establishment of a third-party body, tentatively named, the Board of Administrative Review, and an administrative agency which has received a request for correction is to make a decision based on a Board's opinion.