How to Write a Subsidy Performance Report: The Critical Step After Adoption

Over the past 5 years, I have worked with hundreds of Chinese-owned businesses, of which about 30% ran into problems at the performance report stage, resulting in the subsidy being deducted, returned, or even deemed non-compliant. This article explains, from a practical perspective, how to write a subsidy performance report and how to respond to issues.

What Is a Subsidy Performance Report? Why It Must Be Done Well

A performance report (実績報告書) is the achievement-proof document that a company submits to the subsidy-granting body (usually the Chamber of Commerce and Industry, a local government, or a national agency) after the subsidy's target period ends.

There are three core purposes:

1. Prove the compliance of fund usage — prove that the money you spent was indeed used according to the plan submitted at the time of adoption
2. Verify the project's implementation results — prove that the subsidized project actually produced the expected effects
3. Serve as the basis for review — determine whether to make additional deductions, pay the full amount, or trigger a second review

Simply put: the adoption notice only means "the government agrees to give you this money," while the performance report is what "proves you deserve this money."

According to data from Japan's Small and Medium Enterprise Agency, in 2022 about 12% of subsidies were partially or fully returned due to failing performance reports. The return rate for Chinese-owned businesses is even higher, mainly because of:

• Insufficient understanding of Japanese administrative logic
• Non-standard record keeping of receipts
• Reports that are logically inconsistent with the original plan
• Unclear translation or explanation

Submission Timing and Deadline for Performance Reports

This is a detail many companies overlook, but late submission directly leads to the subsidy being frozen or returned.

Report Deadlines for Typical Subsidies

| Subsidy Type | Subsidy Target Period | Report Submission Deadline | Real Example | |---------|---------|---------|---------| | Small Business Sustainability Subsidy | 6 months | Within 30 days after the period ends | Adoption in March, period ends September, must submit within October | | IT Adoption Subsidy | About 4 months after grant decision | Within 45 days after the period ends | Grant decision June, ends October, submit by mid-November | | Business Restructuring Subsidy | 12 months | Within 60 days after the period ends | Adoption April, ends March the next year, submit by end of May | | Startup Subsidy | 6 months | Within 30 days after the period ends | Commonly Q4 adoption, submit in January the next year |

Key reminder: "Within the deadline" refers to the date the granting body receives the documents, not the date you send them. We recommend submitting at least 5 business days in advance.

What Content Must a Performance Report Include? A Specific Writing Guide

A complete performance report usually consists of two parts: the main report + supporting materials.

Required Sections of the Main Report

Part 1: Business Overview (事業概要)

Use 300–500 characters to briefly describe what your project did. This part is the decisive area for the reviewer's first impression.

Writing points:

• Correspond closely to the plan submitted at adoption (not a word-for-word copy, but the logic must be consistent)
• Use specific numbers rather than vague statements
• The timeline should match the actual execution status

Case (wrong version):

"We executed a digital marketing project and achieved significant results."

Case (correct version):

"Between April and September 2024, we collaborated with a professional production company, invested JPY 980,000 of the subsidy, and produced 3 corporate promotional videos (each 10–15 minutes) and 36 social media content pieces. Published via YouTube and Instagram, we gained about 23,000 views within 6 months, with a conversion rate improvement of 18% compared to the same period the previous year."

Part 2: Project Execution Status (実施内容)

Correspond item by item to the plan at adoption, explaining the deviations between plan and reality and the reasons.

This part is the most prone to problems. Many companies either completely copy the plan (which seems unrealistic) or conceal deviations (which is a violation once discovered by the reviewer).

Correct approach: Honestly list changes and explain reasonable reasons.

Example:

Plan: Purchase 5 CNC machine tools, total JPY 5,000,000

Actual: Purchased 4 CNC machine tools + 1 auxiliary device, total JPY 4,980,000

Reason for change: During implementation, communication with the supplier revealed that adding 1 auxiliary device rather than the 5th machine tool would better improve capacity utilization. After internal evaluation and while keeping the total within budget, we made the adjustment. This change does not undermine the original project goals.

Part 3: Achievement Indicators (成果指標)

This is the part reviewers focus on most. You must speak with measurable, specific data.

The adoption plan usually sets 3–5 achievement indicators. The performance report must answer "Was it achieved?" for each one.

Common indicator types:

1. Quantitative indicators — sales growth, number of orders, percentage improvement in production efficiency
2. Qualitative indicators — new customer development, improved brand awareness, skill improvement
3. Procedural indicators — system implementation completion rate, employee training coverage rate

Example setup:

Indicator 1: New product sales
  Planned target: JPY 10,000,000/year
  Actual result: JPY 12,800,000/year
  Achievement rate: 128%

Indicator 2: Customer satisfaction
  Planned target: 80 points or above (out of 100)
  Actual result: 85 points
  Achieved: Yes

Indicator 3: Production cycle reduction
  Planned target: reduce from 30 days to 20 days
  Actual result: reduced from 30 days to 18 days
  Achievement rate: Exceeded

Part 4: Fund Usage Status (資金使用状況)

This part is the strictest and requires item-by-item correspondence with receipts.

Key points:

• List the date, target company, amount, and use of each expenditure
• Classify by the expenditure categories of the adoption plan
• The total expenditure must match the settlement report
• Subsidy-target expenses and expenses borne by the company itself must be labeled separately

Sample table structure:

| Expenditure Date | Category | Target Company | Amount (incl. tax) | Subsidy Target | Receipt No. | |---------|------|---------|----------|---------|---------| | 2024/4/15 | Machinery & Equipment | A Machinery Co. | ¥2,500,000 | ¥1,875,000 | 発001 | | 2024/5/20 | Personnel (Outsourcing) | B Design Office | ¥800,000 | ¥600,000 | 発002 | | 2024/6/10 | Advertising | C Printing Co. | ¥300,000 | ¥225,000 | 発003 |

Supporting Materials Checklist

70% of a performance report's "persuasiveness" comes from supporting materials. Official documents usually require:

1. Photos/videos of project implementation — machine installation site, product production process, team training scenes (at least 5–10 images)
2. Copies of original receipts — invoices, receipts, bank transfer proof, delivery confirmations, etc.
3. Achievement-proof documents — sales data sheets, customer feedback, media coverage, certificates (if training)
4. Change application form (if there were major changes)
5. Self-evaluation sheet — self-evaluation of achievement level according to the official format

Common Performance Report Error Cases for Chinese-Owned Businesses and How to Avoid Them

Error 1: Plan and Performance Report Being "Two Separate Things"

Phenomenon: The plan is written grandiosely, but the performance report is evasive, or the complete opposite.

Consequence: Reviewers will doubt the report's authenticity. I have seen cases where 50% of the subsidy was required to be returned for this reason.

Avoidance solution:

• After completing the performance report, re-check it item by item against the plan submitted at adoption
• If there are deviations, clearly explain them in the "reasons for change" (do not conceal)
• Invite a consultant or third party to review and ensure logical consistency

Error 2: Non-Standard or Missing Receipts

Phenomenon:

• The invoice name does not match the applying company
• The receipt has only the shop's stamp, no tax number
• The transfer record does not match the invoice amount
• No saved contract or quotation with the supplier

Consequence: Unable to prove "you actually spent this money," so the subsidy is fully deducted.

Avoidance solution:

• Get quotations from three companies before purchasing ("相見積もり") and save the quotations
• Ensure all invoice names match the subsidy-applying company exactly
• Save a complete chain for each expenditure: quotation → order → invoice → receipt → deliverable
• Build a table checklist recording the location and number of each receipt

Error 3: Inflated or Unverifiable Achievement Data

Phenomenon: The report says "sales grew 50%," but the sales reports dug up are a mess of data.

Consequence: Deemed as fabrication—not only no subsidy, but possibly held accountable.

Avoidance solution:

• Achievement data must be a formal export from the company's internal systems (ERP, accounting software, sales management system)
• Do not be overly optimistic when setting indicators in the plan (plan for 50% growth, actual 40% still counts as achieved)
• If not achieved, honestly explain the reasons (market changes, supply chain issues, etc.)

Error 4: Late Submission

Phenomenon: Business owners busy with operations treat the performance report as something to do "when there's time."

Consequence: Even 1 day late may be rejected. I encountered a company whose subsidy was frozen for 3 months because it was 2 days late.

Avoidance solution:

• Start collecting materials 2 months before the subsidy target period ends
• Complete a first draft 1 month in advance
• Set calendar reminders marking the "final submission date" and "recommended submission date" (3–5 days early)
• Use express delivery and save the delivery-confirmation proof; do not use only ordinary mail

Error 5: Non-Standard Wording or Translation Errors

Phenomenon: Using colloquial, informal wording, or even dialect; or awkward machine-translated Japanese.

Consequence: The reviewer puts a question mark on the report's credibility.

Avoidance solution:

• Use formal business Japanese or Chinese (depending on the granting body's requirements)
• Verify technical terms (the difference between "販売数" and "売上数")
• Have someone with high Japanese or Chinese proficiency review it word by word
• Check numbers, amounts, and dates three times in particular

Frequently Asked Questions (FAQ)

Q1: The subsidy target period hasn't ended yet—can I submit the performance report early?

A: No. The submission time for a performance report has a hard rule: it must be submitted only after the subsidy target period ends. Early submission will be directly returned by the subsidy-granting body and not accepted. The reason is: the granting body needs to confirm that the entire project cycle proceeded as planned, and early ending may mean the project was not fully executed. But you can start preparing 1 month before the period ends—collecting receipts, organizing data, writing a draft—so you can quickly make final adjustments and submit after the period ends. For example, if a company's IT subsidy target period ends June 30, then you should start preparing in May and complete submission by July 15 (assuming the deadline is 45 days).

Q2: In the performance report, I find one expenditure that had no invoice at the time. Can I make one up now?

A: Strictly speaking, no. Japanese government subsidies require formal receipts that existed at the time; they cannot be made up afterward. But there are exceptions: for small expenditures (generally under JPY 5,000) where an invoice truly cannot be obtained, you can substitute a shop receipt + on-site photo + internal company proof; for things like employee travel meal expenses, a travel report form can be substituted. But these alternatives must be explained at the time of report submission, and the risk is high. My advice is: when you discover a missing receipt, immediately contact the subsidy-granting body for consultation (usually the Chamber of Commerce and Industry) and ask whether that expenditure can still be recognized—don't wait until you submit the report to discover it, when it can no longer be remedied. Another preventive measure is: during the subsidy target period, reconcile accounts once at the end of each month to confirm that every expenditure has a complete receipt.

Q3: The achievement indicators set in the plan were not met due to market reasons. How should the performance report be written?

A: You must write it honestly. Many business owners are anxious about "will not achieving it lead to deductions," but the subsidy system's definition of "not achieved" is actually quite lenient—as long as you can prove the project was indeed executed, invested in, and there was a reasonable external cause, deductions usually will not occur. The key is how to write it. Do not conceal or fabricate data; instead, in the "achievement analysis" or "review" section of the performance report, explain in detail: what the goal was, what actually happened, why there was a difference, and what this result demonstrates. For example, if the plan called for 30% sales growth but only 15% was achieved, you can write: "Affected by the industry order decline in the first half of 2024, although we did not meet the original target, we still grew 15% compared to the same period in previous years, showing that the subsidy project (such as product development and market expansion) has begun to bear fruit. According to customer feedback, new product satisfaction reached 85 points, and we expect continued growth in the next fiscal year." Such honest explanations are usually accepted. Only when data is obviously fabricated or the project was simply not executed will there be deductions or accountability.

Q4: How are employee wages handled in the performance report? Do specific amounts need to be disclosed?

A: If the plan at adoption already included a "personnel expenses" (人件費) category, then the performance report needs to list them. But you do not need to disclose the specific wages of individual employees—only list: expenditure category, number of people, total amount, and what work those personnel did. Legally, you can use codes instead of employee names, but you must have a corresponding table internally. In practice, in the report submitted to the subsidy-granting body, the employee wage part can be written as "Employee A (development role) 120 hours, hourly rate JPY 3,000, total JPY 360,000" without revealing personal identities. But to prevent later audit trouble, we recommend keeping a complete employee wage sheet and working-hour sheet for the granting body's verification. For external outsourcing (such as hiring freelancers or outsourcing companies), you need to provide contracts and invoices, which are usually disclosed.

Q5: After the performance report is submitted, how long until I know the review result? Can it be modified in the meantime?

A: Generally, the review period after submitting a performance report is 30–90 days, depending on the subsidy type and the granting body's workload. Large subsidies (such as the Business Restructuring Subsidy) may take 3 months; small subsidies (such as the Small Business Sustainability Subsidy) may have a result within 1 month. Review results usually fall into three types: (1) unconditional approval, entering the payment process; (2) conditional approval, requiring supplementary materials or revised explanations; (3) disapproval, requiring return of all or part of the subsidy. Can it be modified after submission? You cannot modify it on your own initiative. But if the granting body proactively requests supplementary materials or clarification, you must provide them within the specified period (usually 14–30 days). If during the review you discover an error or omission in the report, you should immediately and proactively report and correct it with the granting body—this appears honest and usually will not be penalized; if you wait until the granting body discovers it before correcting, there may be problems. We recommend having a consultant or third party review it once more before submission to reduce the probability of being asked for supplementary materials later.

Complete Checklist for Submitting a Performance Report

To ensure everything is foolproof, we recommend following these steps:

Phase 1: Preparation period (2 months before the subsidy target period ends)

• [ ] Confirm the subsidy target period end date and report submission deadline
• [ ] Build an expenditure detail sheet, checking each invoice and transfer item by item
• [ ] Organize and scan all receipts, creating a digital backup
• [ ] Collect photos and videos from the project execution process
• [ ] Aggregate sales, production, and other related data

Phase 2: Drafting period (within 1 month after the subsidy target period ends)

• [ ] Draft each part of the main report according to the official format
• [ ] Prepare the supporting materials checklist, confirming no omissions
• [ ] Calculate the achievement rate of the achievement indicators
• [ ] List all expenditures and classify/aggregate them

Phase 3: Review period (1 week before submission)

• [ ] Check item by item against the plan submitted at adoption, marking all differences and reasons
• [ ] Invite a professional consultant or knowledgeable third party to review
• [ ] Correct typos, translation errors, and logically unclear parts
• [ ] Confirm that the document format and upload method meet the requirements

Phase 4: Submission period (3–5 days before the deadline)

• [ ] Choose express delivery to submit (save delivery confirmation) or upload to the system in the specified way
• [ ] Save submission proof (express tracking number, system confirmation email, etc.)
• [ ] Back up all submitted documents
• [ ] Record the expected review-result return date

Conclusion: The Performance Report Is Not the End, but a New Beginning

Many Chinese business owners treat receiving the adoption notice as "the subsidy is in hand," but this mindset is wrong. Between adoption and final payment, there is still a 50–60% risk of failure, and the biggest part of this risk lies in the performance report step.

The core principles of writing a good performance report are simple: honest, specific, complete, standardized. Do not conceal, do not fabricate, do not omit, and above all do not violate the submission deadline.

According to my past statistics, among Chinese-owned businesses:

• 70% pass on the first try (usually companies that prepared well)
• 25% pass after providing supplementary materials (report content qualifies, but there are minor formal flaws)
• 5% have deductions or returns (usually receipt problems or data fabrication)

Which category your company falls into depends on how much importance you place on this step.

If your subsidy is still in progress, or you have reached the performance report stage but are unsure how to proceed, we recommend immediately seeking guidance from a professional consultant. A professional consultant's fee (usually JPY 30,000–100,000) is negligible compared to the subsidy amount (usually JPY 500,000–5,000,000), but can significantly reduce the risk of deductions.

For any specific questions about subsidy applications, post-adoption procedures, or implementation reports, we welcome you to consult our professional team for free. We have experience interfacing with many Japanese subsidy-granting bodies and can help you avoid 90% of common pitfalls.