# Beware the 'you can use a subsidy' sales pitch — spotting bad-faith vendors and the fraudulent-receipt risk > System-development sales pitches that sell 'effectively free with a subsidy' or 'zero out-of-pocket' hide the fraudulent-receipt pitfalls of kickbacks, padded invoices, and rollouts with no substance. The penalties (full repayment, a 10.95%-per-year surcharge, publication of the business's name, criminal punishment) fall on the buyer themselves. From a neutral standpoint, this article explains the four types of bad-faith vendor tactics and the checkpoints for spotting them before you order. - Published: 2026-07-07 - Author: 友田 陽大 - Tags: 補助金, DX, 中小企業, システム開発, IT導入補助金, 発注 - URL: https://tomodahinata.com/en/blog/subsidy-vendor-selection-avoid-scams-guide - Category: DX with government subsidies - Pillar guide: https://tomodahinata.com/en/blog/subsidy-system-development-outsourcing-complete-guide ## Key points - A pitch that stresses 'effectively free with a subsidy' or 'zero out-of-pocket' is a red flag — the subsidy rate is fixed by the program, and a proposal that erases your out-of-pocket cost is very likely a fraud such as a kickback - De facto rebates (kickbacks), padded invoices, rollouts with no substance, and impersonated applications are the representative types of officially prohibited fraudulent receipt - Responsibility for fraudulent receipt falls not on the vendor but on the subsidized party (the buyer) themselves — rescission of the grant decision, full repayment, a 10.95%-per-year surcharge, publication of the business's name, and, in bad-faith cases, imprisonment of up to 5 years or a fine of up to 1 million yen - The key to spotting it is 'whether the features and the amount were decided subsidy-first' — before ordering, confirm competing estimates, the substance of the rollout, maintenance terms, and support-vendor registration - Even if you're dragged in unknowingly, there is a voluntary-repayment channel — with an early voluntary declaration, the treatment of the surcharge can change. Don't lose the principle that the program is a tool and the goal is solving a business problem --- The conclusion first. **A sales pitch that makes "with a subsidy you can build a system effectively for free" or "we can bring your out-of-pocket cost to zero" its "selling point" is a sign to be on guard.** The subsidy rate and out-of-pocket amount are fixed by the program (the call-for-applications guidelines), and behind a proposal that makes them zero, **fraudulent-receipt tactics** such as kickbacks, padded invoices, and rollouts with no substance can be lurking. And the most important fact is that **when the fraud comes to light, responsibility falls not on the vendor but on the buyer (the subsidized party) themselves, in whose name the application was filed.** Full repayment, a 10.95%-per-year surcharge, publication of the business's name, and, in bad-faith cases, criminal punishment. This article organizes bad-faith vendor tactics and how to spot them before you order, from a **neutral standpoint that does not file applications on your behalf.** --- ## 1. Why you should be wary of the "you can use a subsidy" sales pitch Proposing to use a subsidy is, in itself, an honest commercial act. Good vendors, too, naturally point out usable programs. The problem is the case where **the subsidy is not a "means" but "the center of the sales pitch."** Sound ordering proceeds in the following order. ```text ① 事業課題 どの業務のどんな困りごとを解決したいか ↓ ② 必要な機能 その課題に本当に必要な機能・範囲 ↓ ③ 適正な費用 人月・工数から積み上げた見積もり ↓ ④ 使える制度 ②③に合致する補助金を後から当てはめる ``` In a bad-faith pitch, this order is **stood on its head.** "The subsidy pays up to 2 million yen, so let's make it a 2-million-yen proposal" — in other words, **inflating the amount and the features by working backward from the subsidy cap rather than from the problem.** A subsidy is supposed to be a tool that lightens the buyer's burden, but it's been swapped out for a tool that maximizes the vendor's order value. > **The perspective a buyer should hold first**: not "it gets cheaper" but "to solve what, how much is a reasonable investment?" The subsidy is a matter that comes after that investment decision. A proposal in the reverse order is, by itself, a reason to step up your guard a notch. The thinking behind ordering system development itself is also laid out in [a guide to outsourcing system development: vendor selection and cost that don't fail](/blog/system-development-outsourcing-guide-vendor-selection-cost). Keeping this foundation steady, whether or not a subsidy is involved, is the greatest defense. --- ## 2. Bad-faith vendor tactics — the four types of fraudulent receipt The IT Introduction Subsidy secretariat [officially spells out the types of "fraudulent conduct"](https://it-shien.smrj.go.jp/antifraud). The representative tactics a buyer should know are these four. | Type | What the tactic actually is | Why it's fraud | |---|---|---| | **De facto rebate (kickback)** | Providing the IT tool effectively for free or at a discount, or later refunding the out-of-pocket portion under the name of a "referral fee" or "consulting fee" | Making the eligible cost look higher than it is, erasing the out-of-pocket cost and extracting only the subsidy | | **Padded / false application** | Applying with an estimate higher than the real price, or falsifying requirements like the number of employees to fit the target category | Receiving an amount you couldn't properly get through an excessive or false application | | **Rollout with no substance** | Providing only a trial version rather than a licensed one, sending an email while calling it in-person training, no actual delivery | The "actual rollout / service provision" that is the premise of the subsidy does not exist | | **Impersonated application** | Getting the buyer to share their ID and having the vendor open the application "My Page" or carry out the grant-application procedure in their place | It violates the principle that the subsidized party applies in person, becoming a false application under a borrowed name | Particularly dangerous is the **kickback.** Come-ons like "we'll return your out-of-pocket portion later" or "we can make it effectively free" sound like "a deal" to a buyer, but **this is nothing less than an invitation into a conspiratorial structure for swindling the subsidy.** ```text 【キックバックの構造 — 見かけと実態】 見かけ: 発注者 --300万円で契約--> ベンダー 発注者 <--200万円 補助金-- 事務局 （発注者の自己負担 100万円…に見える） 実態: ベンダー --80万円“紹介料”を還元--> 発注者 発注者の実質負担 = 20万円 → 本来200万円の価値がないものに補助金200万円が流れる → 差額は不正に引き出された公金 ``` This gap between "appearance" and "reality" is the very core of a fraud determination. See through the relationship: **exactly to the extent the buyer feels they "came out ahead," public money is flowing out illegitimately.** --- ## 3. Who bears the responsibility — fraudulent receipt is the "buyer's" crime This is the point this article most wants to convey. **The party to a fraudulent receipt is the subsidized party in whose name the application was filed — that is, the buyer themselves.** "I was just recommended it by the vendor," "I left the whole procedure to them" — these **do not exempt you.** The grant application for a subsidy is filed in the subsidized party's name, and it's the named party who bears responsibility for its contents. It goes without saying that the vendor receives sanctions such as registration rescission, but **separately** from that, the buyer is held to repayment, publication, and in some cases criminal responsibility. > In other words, going along with a bad-faith vendor is not "helping the vendor do something bad" — it is equivalent to **"filing, as the principal offender yourself, an application to defraud public money."** This is the essence of the structure. In the world of payments, it's the same mindset as [idempotency design that keeps zero double charges in production](/blog/payment-double-charge-prevention-idempotency-procurement-guide), which pushes to the bottom of "under whose responsibility is the correctness of a money-moving operation guaranteed?" In the flow of money that is a subsidy, too, it's safest to think that **the responsibility for guaranteeing final correctness lies with the buyer.** --- ## 4. The full picture of the penalties — what happens if it's discovered The measures if fraud is confirmed are multilayered, from administrative dispositions to criminal punishment. I organize them based on the secretariat's published items and the underlying law, the [Subsidy Optimization Act](https://laws.e-gov.go.jp/law/330AC0000000179/). | Penalty | Content | |---|---| | **Rescission of the grant decision** | The decision is rescinded and the right to receive the subsidy is lost | | **Full repayment of the subsidy** | You are demanded to return the subsidy already received | | **Surcharge** | You pay, on top, a surcharge calculated at a rate of **10.95% per year from the date of receipt to the date of payment** (Optimization Act, Article 19) | | **Late-payment charge** | If you don't pay by the due date, a further late-payment charge of **10.95% per year** | | **Publication of the business's name** | The secretariat publishes the business's name. The blow to trade and creditworthiness is heavier than the repayment amount | | **Rescission of the support vendor's registration** | The involved IT introduction support vendor has its registration rescinded and is published | | **Criminal punishment** | Receipt by false or other fraudulent means is subject to **imprisonment of up to 5 years (formerly penal servitude) or a fine of up to 1 million yen**, with concurrent imposition possible (Optimization Act, Article 29). Use for other than the intended purpose, etc., is up to 3 years / up to 500,000 yen (Article 30) | The interest rate of **10.95% per year** is on par with a consumer loan. If it's discovered a few years later, the surcharge alone reaches tens of percent of the principal. On top of that, **the reputational damage of "publication of the business's name,"** which money can't buy back, awaits. The blow to business partners, financial institutions, and the recruitment market can far exceed the repayment amount. > **"It's fine as long as no one finds out" doesn't hold**: subsidies are subject to inspection by the Board of Audit, and after-the-fact fact-finding and on-site checks are carried out. It's not rare for cases to come to light retroactively, years after the rollout. Fraud is "an order carrying a time bomb." --- ## 5. Spotting it before you order — checkpoints Before you sign the contract, confirm the following. If even one applies, it's a reason to stop. - [ ] **Are they selling "effectively free," "zero out-of-pocket," or "cashback later"?** — a kickback come-on - [ ] **Is the estimate exactly at the subsidy cap?** — suspicion of working backward from the cap rather than building up from the problem - [ ] **Do they blatantly dislike competing estimates or third-party checks?** — possibly a price/content that collapses under comparison - [ ] **Do they rush you with "sign today," using the grant-application deadline as a pretext?** — a textbook way of not letting you deliberate calmly - [ ] **Is the substance of the tool/service to be rolled out concrete?** — are they trying to get by with a trial version, email training, and the like? - [ ] **Are they trying to operate the application ID or My Page in your place rather than having you, the buyer, do it?** — the gateway to an impersonated application - [ ] **Are the terms for maintenance, operation, and additional costs stated explicitly in the contract?** — the subsidy is upfront cost only. Be wary of a business that avoids explaining running costs - [ ] **Are they properly registered as an IT introduction support vendor?** — you can check the registration status and past rescission cases on the official site The perspective of competing estimates and estimate comparison is valid whether or not a subsidy is involved. An attitude of judging the reasonableness of the amount itself is the best line of prevention against bad-faith proposals. --- ## 6. A sound vendor, and the right way to use a subsidy So how do you tell an honest vendor? Paradoxically, the more a vendor **doesn't lead with the subsidy,** the more trustworthy they are. First carefully hearing out the problem and requirements, presenting the necessary features and an appropriate cost, and pointing out the subsidy in the order **"for that investment, this is the program that happens to be usable"** — this is the sound shape. And the smart way to use a subsidy is to apply the aid to a **"hybrid" that builds only the core of your differentiation from scratch and locks down the generic parts with off-the-shelf SaaS or open source.** This idea is also touched on in [how to approach legacy-system modernization](/blog/legacy-system-modernization-2025-cliff-cost-guide). The proper use of a subsidy is not "filling the hole of over-investment beyond your means" but **"a tailwind that lightens the out-of-pocket cost of a reasonable investment."** Incidentally, proposals to accelerate development with generative AI are increasing, but a proposal of only "we can build it cheap and fast," without the process of [finishing AI-generated code to production quality](/blog/vibe-coding-ai-generated-code-production-hardening-guide), carries a quality risk whether or not a subsidy is involved. Always confirm **whether there is a verification process behind the speed and the low price.** --- ## 7. In summary — the subsidy is a tool; the goal is solving a business problem - **A pitch that sells "effectively free" is a red flag.** The subsidy rate and out-of-pocket cost are fixed by the program; a proposal that erases them is a suspicion of fraud - **Responsibility for fraudulent receipt is the buyer's own.** Full repayment + a 10.95%-per-year surcharge + publication of the business's name, and criminal punishment if it's bad-faith - **The key to spotting it is "whether the amount was decided subsidy-first."** Confirm competing estimates, the substance of the rollout, maintenance terms, and support-vendor registration - **If you're ever dragged in, declare voluntarily and early.** For unintended receipt there is also a treatment where no surcharge is imposed - **The subsidy is a means, not an end.** Make a reasonable investment in the core of your differentiation, and use the program as a tailwind for it --- **A note on neutrality**: The author is not a registered IT introduction support vendor and does not file subsidy applications on your behalf. This article is a neutral explanation to help buyers see through bad-faith proposals and make sound decisions. The program's details and the latest subsidy rates, caps, schedules, and criteria for determining fraud are updated each fiscal year, so always confirm on the official call-for-applications guidelines and the secretariat's site. For those who want to separate out, together, "is this proposal's amount inflated subsidy-first?" and "what are the truly necessary features?": with a **pre-order checklist** and a **free DX assessment**, I help from the making of a proper, problem-first investment plan. Not application support, but a neutral standpoint that aids the buyer's judgment.