What is Article 28 of the Road Act? How to Read the Road Ledger and 5 Points to Check

Table of Contents

• Basics of the Road Register as Defined by Article 28 of the Road Act

• Practical role to understand before reading the road register

• Checkpoint 1: Identify the administrator and route of the target road

• Checkpoint 2: Confirm the assumptions such as the area, length, and width in the register

• Checkpoint 3: Check the relationship between the road boundary lines and current site conditions on the drawings

• Checkpoint 4: Confirm the discrepancy between the reference materials' update date and the current site conditions

• Checkpoint 5: Organize the information to be used for applications, consultations, and surveys

• Approach to using the road register for on-site verification

• Summary: Use Article 28 of the Road Act as the entry point to link the road register and on-site conditions

Basics of the Road Register Prescribed by Article 28 of the Road Act

Article 28 of the Road Act is the provision that requires road administrators to prepare and keep road registers for the roads they manage. Many people who look up "Article 28 of the Road Act" in practice are not just seeking the text itself but also want to know how to read a road register, how to confirm the road area and width, and to what extent it can be used for field surveys and application procedures.

Article 28 of the Road Act stipulates that road administrators must prepare and keep a register of the roads they manage, that the items to be recorded in the road register and other matters necessary for its preparation and preservation are prescribed by ordinance of the Ministry of Land, Infrastructure, Transport and Tourism, and that a road administrator may not refuse a request to inspect the road register. In other words, the road register is not merely a document for the internal organization of road administrators but is an important basic reference for stakeholders who wish to confirm road boundaries and management information. ([e-Gov Law Search][1])

The specific composition of the road register is set out in the Enforcement Regulations of the Road Act. The road register is composed of records and drawings, and the records and drawings are to be prepared for each route. The records serve as an entry point for confirming the road type, route name, matters related to designation or recognition, the starting and ending points, length, width, information related to the commencement of use, and so on. The drawings provide clues for reading the boundary lines of the road area, surrounding topography, orientation, changes in width, and positional relationships with intersections and structures. ([e-Gov 法令検索][2])

Viewed in this way, Article 28 of the Road Act is not simply a provision that prescribes the administrative procedure of "creating a road ledger." It provides the basis for organizing how the public space of roads is to be treated — which routes, in which areas, and based on what management information — and for putting that information into a state in which concerned parties can confirm it. The reason the road ledger is consulted in situations such as road construction, occupancy applications, planning of roadside properties, development consultations, maintenance and management, and disaster recovery is that it serves as the starting point for confirming the road's management information.

However, consulting the road register does not mean that everything on the ground is conclusively determined. The road register is a basic reference for road management and serves a different purpose from current-condition survey maps, boundary determination maps, registration-related documents, construction completion drawings, and occupancy-permit documents. The viewing guidance of some national offices likewise cautions that the road register does not certify the information it contains, and that the boundary lines of road areas indicate areas under the Road Act, not land boundaries or rights relationships. ([国土交通省 交通研究所][3])

Therefore, even if the road ledger indicates road boundary lines and widths, that alone does not necessarily establish the parcel boundary with private land, the extent of ownership, building-related road-access requirements, or the exact locations of on-site structures. In practice, it is important to use the road ledger as the initial reference document and then, where necessary, proceed to related materials and on-site verification.

Practical Context to Keep in Mind Before Reading the Road Ledger

The first thing to keep in mind when reading a road register is that it is a document for road management. A road is not composed solely of the paved surface on which vehicles and pedestrians travel. Many elements are involved: sidewalks, shoulders, gutters, slopes, planting strips, guardrails, signs, lighting, drainage facilities, bridges, tunnels, retaining walls, and encroachments. The road register is a resource for organizing, by route, the information needed for such road management.

On the other hand, the reasons practitioners check the road ledger vary. They may be determining whether road occupancy is permitted, or they may be checking the extent of the impact of road works. In connection with development of properties along the road, they may confirm the frontage road’s width and road classification. Sometimes the on-site pavement edge does not match the road boundary line shown in the ledger, leaving them unsure which document should serve as the reference for starting discussions. When the purpose of consulting the road ledger differs, the information to focus on also changes.

For example, for personnel involved in road occupancy, it is important whether the subject property falls within the road area, and which part—roadway, sidewalk, shoulder, side ditch, slope, etc.—it relates to. For construction personnel, it is necessary to confirm pavement width, side ditch location, road area, existing structures, intersection geometry, gradient, and drainage flow. For those responsible for land use or design, it is required to organize the type of road adjacent to the site, route name, width, road area, and operational status.

In addition, the storage and viewing methods for road ledgers differ depending on the road administrator. The Ministry of Land, Infrastructure, Transport and Tourism has issued guidance on electronic data of road ledgers under Article 28 of the Road Act, stating that drawings and records of nationally managed roads and materials for roads managed by expressway companies, etc., can be viewed. For roads managed by local public bodies, operations may vary by administrator, such as viewing at counters, electronic viewing, or issuance of copies upon application. ([Ministry of Land, Infrastructure, Transport and Tourism][4])

One thing to note here is to view the road register from the perspective of "which administrator created it and which road the document is intended for." Even a continuous traffic space that appears to be the same road may contain a mix of national highways, prefectural roads, municipal roads, private roads, roads prior to transfer of management, and occupied passages. If you judge road names only by their everyday usage, you may mistake the route name or administrator shown in the register.

The road register under Article 28 of the Road Act is, fundamentally, a register concerning roads managed by road administrators. Therefore, the starting point for interpreting the road register is to confirm which road administrator has jurisdiction over the location in question. In particular, at intersections where national highways and municipal roads meet, in sections where an old road runs parallel to a new road, and at locations with side roads or access roads, it is important not to judge solely by apparent continuity.

Checkpoint 1: Identify the managing authority and route of the road in question

The first point to check when looking at a road ledger is to identify the road’s administrator and its route. Article 28 of the Road Act assumes that a road administrator prepares and keeps the ledger for “the roads they manage.” Therefore, the first thing to confirm is which road administrator manages the road in front of the subject site or the road adjoining the planned construction area.

In practice, people sometimes conclude that two stretches are the same road based solely on the shape visible on site. However, they may be recorded as separate routes in the road register. This can occur when a route changes at an intersection, when the old and new alignments run in parallel, when side roads or access roads are registered as separate routes, or when management divisions change at bridge or tunnel sections. If the target location is mistaken, confirmations of carriageway width, road area, and the sections where the road was opened to traffic will also be off.

When checking a route, first look at the type of road. The type of road—general national highway, prefectural road, municipal road, etc.—determines the administrator and where to consult records. Next, confirm the route name. It is important to verify the route name as it appears in the ledger, not by its common or local name. Then, cross-check the start and end points, major intermediate points, and where the section of interest lies within the overall route. Because looking only at the drawings in the road ledger can easily lead to an unclear understanding of route names and management sections, check the ledger entries and drawings together.

Particular care should be taken when identifying the subject road near intersections, in sections where the road has been improved, at crossings with rivers or railways, and in areas where land readjustment or development has been carried out. In these places, the actual road alignment on the ground may have changed, or the past road area may differ from the current road area. Even if the road ledger has been updated, other related materials may still retain the old alignment. Conversely, the site may have been altered by construction while the ledger you viewed is from before the update.

When identifying the road administrator and the route, it is smoother to review after organizing the property's address, lot number, intersection name, nearby public facilities, the road's common name, on-site photographs, location maps, and so on. When consulting at the counter, rather than vaguely saying "I want to see the ledger for this road," it is better to say "I would like to review the records and drawings from the road ledger pursuant to Article 28 of the Road Act for the roadway in front of this address," which makes it easier to obtain materials that match your purpose.

Note that although the obligation to permit inspection of the road ledger is stipulated by law, the methods, extent, and formats in which materials can be obtained are not the same. In some cases the ledger can be viewed online, while in others you will need to check in person at a counter. Because issuance of copies, fees, reservations, responsible departments, and usage notes differ by road manager, checking beforehand can help avoid unnecessary rework.

Checkpoint 2: Verify assumptions such as area, length, and width in the report

The second point to check is to confirm the road’s basic information in the record. When people think of the road register, they tend to picture plan views first, but the record is indispensable for understanding a road’s attributes. By establishing the assumptions about the subject road in the record before checking lines and shapes on the drawings, you can reduce misinterpretation.

In the record, you may check the road type, route name, information related to the designation or approval of the route, the start and end points, major passing locations, the sections opened to traffic, length, the area of the road site, road width, matters related to road structure, and major items occupying the road. It is not necessary to examine every item in detail for all tasks, but it is important not to overlook items that are relevant to the task at hand.

For example, when confirming the width of the fronting road in planning a roadside site, you should check not only the width shown on the drawings but also the width and section information organized in the records. Road widths can vary depending on the location. If you do not pay attention to areas that widen near intersections, sections with sidewalks, sections that include gutters, road areas that include slopes, or the difference between carriageway width and road area width, you may make incorrect practical judgments.

Length and area are also important. In maintenance and construction planning, it is a prerequisite to know which section of the subject route will be handled, which portions have been opened to traffic, and how much area is being managed as road right-of-way. In particular, in areas where old alignments remain, in zones after bypass development, or in sections where road improvements were carried out in stages, the treatment of the route is not straightforward. If you make judgments on site alone without checking the register’s information on length and area, you may not be able to grasp the management targets accurately.

When reviewing records, don't just pick out the numbers; confirm which section each number corresponds to. Even if a width is recorded, its meaning changes depending on whether it is a representative value for the entire route, a value for a specific section, the minimum width, the carriageway width, or the width of the road area. Because the format of the road register and the practices of the managing authority can differ, you should confirm with the road authority if any doubts remain.

Also, the records may contain information related to the history of the road. The sequence of events—such as approval, area designation, area changes, opening to traffic, abolition, and transfer of management—can provide clues for understanding the current road boundaries and management scope. If the purpose of consulting the road ledger is to organize the scope of construction impacts or to confirm the road area, it may be necessary to trace past changes as well as review the current drawings.

Checkpoint 3: Confirm on the drawing the relationship between the road boundary line and the existing conditions

The third point to check is to confirm, on the drawings, the relationship between the road boundary line and the existing conditions. The drawings in the road register are reference materials used to visually understand the shape and positional relationships of the road in question. They are used to read the road area boundary line, surrounding topography, orientation, changes in width, curved sections, intersection geometry, structures such as bridges and tunnels, and road components such as side ditches and slopes.

The most important thing to be careful about when looking at road ledger drawings is not to confuse the road boundary line with the edge of the pavement. On site, the paved area may look like the road, but the road boundary does not necessarily consist only of the paved surface. Ditches, shoulders, sidewalks, slopes, tree-planting strips, parts of retaining walls, and spaces required for management may be included in the road boundary. Conversely, even if an area is paved, it may be pavement on private land outside the road boundary, such as driveways or internal site access ways.

Also, the road area line and the parcel boundary are not necessarily the same. The road register is a record showing areas for road management and is not a document for directly determining land ownership boundaries or parcel boundaries. The road area and land boundary may be close to each other, but the road area line, the boundary-determination line, the parcel boundary recorded in the land registry, on-site boundary markers, pavement edges, and the locations of structures each have different meanings. If you use the road register as a starting point for confirming boundaries, you must understand these differences and cross-check it against boundary-determination documents, registry materials, and survey results.

Another point to verify on the drawing is the exact position of the target point. Road register drawings are created at a fixed scale, but when viewed on paper or enlarged in a PDF the sense of location can shift. Use multiple cues — intersections, bridges, drainage ditches, public facilities, changes in topography, surrounding parcel boundaries, the road centerline, and so on — to confirm the target point. Relying on a single landmark can lead to misreading an adjacent section.

Care must be taken when reading width values. On road ledger drawings, widths may be indicated at each location where the width changes. However, unless you confirm whether that width refers to the carriageway width, the road right-of-way width, whether it includes the sidewalk, whether it includes the gutter, and which positions on site it is measured between, it cannot be used directly for design or consultation. In practice, the width shown on drawings may not match the pavement width measured on site, the gutter inside measurement, the outer-to-outer dimension of structures, the distance between boundary markers, and so on.

Plans are very useful, but they are not foolproof. Depending on the surveying accuracy at the time of creation, the scale, update status, the drafting method, terrain alterations, and the extent to which past works are reflected, they may differ from conditions on the ground. When looking at road ledger drawings, it is important not simply to conclude “the line is here,” but to confirm which sources that line is based on and at what point in time the information represents.

Checkpoint 4: Confirm the difference between the time the reference materials were updated and the actual on-site conditions

The fourth point to check is to verify the difference between the update date of the road register you consulted and the current conditions on site. The road register is a fundamental resource for road management, but changes in the field are not necessarily reflected immediately or in full. Road works, pavement repairs, side-ditch rehabilitation, sidewalk improvements, widening, intersection upgrades, disaster recovery, works occupying the road, and changes to external works on adjacent private land can all alter site conditions. Therefore, when consulting the road register, you need to confirm the document’s creation date and revision date.

In guidance for public viewing at some national offices, the contents recorded in the road ledger reflect the state at the time of compilation, and because of factors such as the timing of updates to the drawings, the shape of the road and other aspects may differ from current conditions. It also states that when using the drawings users must pay attention to the original paper size and scale. ([Ministry of Land, Infrastructure, Transport and Tourism, Transport Research Institute][3])

What you should pay particular attention to is when there are discrepancies between the road registry and on‑site photographs. For example, a gutter may be drawn within the road area on the registry drawing, but on site the gutter may appear to be integrated with structures on the private‑land side. A road area may be shown broadly on the drawing, yet on site the portion that appears to be road can feel narrower because of plantings or walls. Conversely, the on‑site pavement may be wide while the road area on the registry is narrower.

When there are such discrepancies, it is dangerous to immediately conclude that "the ledger is wrong" or "the on-site conditions are correct." The road ledger is meaningful as a record for road management, but the on-site conditions reflect the history of construction and use. To determine the reason for the discrepancy, it is necessary to check whether there have been changes to the road area, notices of commencement of use, as-built drawings, land acquisition documents, boundary determination documents, occupation permit documents, records of past road improvements, and so on.

When confirming the update timing, check the drawing number, date of preparation, date of revision, date of notification, date of commencement of use, date of area change, and so on. These pieces of information are not always clearly displayed, but it is important to be aware, at least, of what state the document you are viewing represents. If you proceed with on-site decisions based on old drawings, you may overlook construction work or area changes that have already been reflected.

When checking for discrepancies with the site, it is effective to keep records that show positional relationships, not just photographs. Even when taking on-site photos, if it is not clear from which direction, at which point, and over what area the photos were taken, it will be difficult to later cross-reference them with the road ledger. Including easily cross-referenceable features—such as side ditches, boundary markers, pavement edges, manholes, utility poles, signs, building corners, fences, retaining walls, and areas near the road center—in your records will make explanations easier during consultations and internal reviews.

If the road register and the on-site conditions do not match, it is also important to quantify and organize the differences. Expressions such as "slightly shifted" or "different from the site" alone will not ensure a shared understanding among stakeholders. A practical point is to clarify at which location, in which direction, and to what extent discrepancies exist, and to separate items that should be confirmed with the road administrator from those that your company should re-survey.

Checkpoint 5: Organize the information used for applications, consultations, and surveys

The fifth point to check is to organize the information extracted from the road ledger into a format usable for applications, consultations, and surveys. The road ledger is not a document to be merely viewed and set aside. It is a resource used to inform subsequent practical decisions such as road occupation, road construction, development consultations, confirmation of road areas, design review, maintenance management, and current condition surveys. Therefore, unless the contents you reviewed are organized by purpose, even if you take the trouble to check them, it will be difficult to apply them to your work.

When road occupancy or road construction is involved, determine whether the subject location is within the road area and which part it relates to—roadway, sidewalk, shoulder, gutter, slope, etc. The positional relationship with existing occupying structures and road appurtenances is also important. If confirmation of underground buried items is necessary, the road register alone is often insufficient; it is necessary to verify them together with buried-utility records from each facility manager and on-site surveys.

In consultations related to development and construction, the type of the frontage road, route name, width, road area, operational status, and the shape of the portion adjoining the site are important. However, the information confirmed in the road register under the Road Act and the treatment of roads under other laws, such as the Building Standards Act and the City Planning Act, may not coincide. Whether it is a road under the Road Act, whether it is recorded in the road register, and whether it meets the road conditions required for building or development procedures each involve different perspectives for verification. To avoid confusion, organize the matters separately by responsible department and by reference materials.

When using them for surveying or field investigations, it is important not to use road ledger drawings as a direct substitute for on-site surveys. Road ledger drawings are documents for road management and do not fully show the detailed coordinates or the locations of the latest structures on site. When conducting an on-site survey, determine the target area and reference points from the road ledger, measure on site the pavement edges, side ditches, boundary markers, structures, and estimated positions of the road area, and, if necessary, verify these against materials held by the road administrator.

When using this for internal briefings or client explanations, rather than simply pasting the road ledger information as-is, it is effective to separate and show what has been checked, what is known, and what remains unverified. For example: the route names and road managers on the ledger have been confirmed; the road area boundary lines have been confirmed on the ledger drawings; differences between those lines and the on-site pavement edges require additional surveying; and whether boundaries have been legally established requires separate confirmation. Organizing the information in this way clarifies what can be determined from the road ledger and what requires further verification.

When using the road register for verification, it is also important not to rush to judgment. Rather than drawing conclusions simply because a line appears on a drawing, a width is shown in a record, or the document could be viewed, consider whether that information is sufficient for the current purpose. The required level of accuracy and the supporting documents change depending on whether it will be used for an application, design, preliminary study, or boundary discussions. The road register under Article 28 of the Road Act is an entry point, and the documents necessary for a final decision need to be organized according to the purpose of the work.

How to Make Use of the Road Register for On-Site Verification

To make practical use of the road ledger, it is efficient to proceed in the sequence of ledger review, document organization, field verification, discrepancy reconciliation, and stakeholder confirmation. First, identify the manager and the route of the target road, and check the ledger’s records and drawings. Next, organize from the records the road type, route name, start and end points, length, width, and sections where service began. Then, from the drawings, read the road boundary lines, points of width change, intersection configurations, and the positional relationships of side drains and structures.

During on-site inspections, record the actual composition of the road as seen while keeping in mind the road-area lines shown on the official register. Confirm features such as the pavement edge, gutters, the sidewalk–roadway boundary, curbs, retaining walls, slopes, drainage facilities, road appurtenances, encroachments, privately owned structures adjacent to the road, and boundary markers, and take photos and notes so they can be cross-checked with the register drawings. For site photographs, take separate shots of the overall view, the specific locations, close-ups, and images that show spatial relationships; this makes later explanation easier.

When organizing discrepancies, separate the points where the records and the field agree from those where they differ. Points that agree serve as evidence that is easy to explain to internal stakeholders and the client. Points that differ should be organized as items to confirm with the road manager, targets for additional surveying, and design considerations. For example, if the road boundary line and the pavement edge are offset, record the direction of the offset and its approximate magnitude. If the location of a side ditch differs from the drawings, check the history of side ditch repairs and the possibility that the on‑site structure has been changed.

When confirming with stakeholders, it is important for the road authority, designers, contractors, surveyors, and application officers to align their understanding by looking at the same materials. If only those who have consulted the road register understand, misunderstandings will arise in later stages. Clarifying which line on the drawings is being treated as the road boundary line, which width is being used, and which on-site structure is being used as the reference can reduce rework in consultations.

To make effective use of road ledger information during on-site verification, the accuracy of the records is also important. Rather than merely taking photos on site, keeping them in a state where position and shape can be confirmed later makes comparison with the road ledger easier. In particular, when explaining discrepancies between the road area and current conditions, the locations of gutters and structures, changes at pavement edges, or differences before and after construction, combining photos with location information, simple measurement notes, current-condition survey results, and three-dimensional data makes it easier to convey the situation to stakeholders.

The road register is an important basic resource held by road administrators. However, without on-site verification, it is difficult to judge how the lines and numbers on drawings are actually expressed in the field. Establish the assumptions from the register, verify the actual conditions on site, organize the discrepancies, and use them to inform discussions. By keeping this sequence of steps in mind, the road register under Article 28 of the Road Act can be utilized not merely as a reference document but as a foundation for practical decision-making.

Summary: Use Article 28 of the Road Act as an entry point to connect the registry and the on-site conditions

Article 28 of the Road Act is an important provision that stipulates that road administrators shall prepare, keep, and make available for inspection the road register. The road register is a basic reference for confirming a road’s type, route name, area, length, width, structure, operational status, and other details, and it is related to many practical matters such as road construction, occupation, development consultations, confirmation of road zones, maintenance and management, and current condition surveys.

When consulting a road ledger, first identify the road’s administrator and route, check basic information in the records, and interpret the relationship between the road boundary lines and the actual conditions on the drawings. Then confirm the differences between the documents’ update time and the current site, and organize the information into a form usable for applications, consultations, and surveying. A road ledger is a very useful resource, but it does not by itself determine everything on the ground or all land boundaries. You need to combine related documents with on‑site verification to build the basis for your decisions.

In practice, what is particularly important is not to treat the road ledger as the definitive answer but as the starting point for verification. Cross-check the ledger’s road boundary lines, the widths recorded in the survey documents, the actual pavement edges on site, side gutters, boundary markers, and the locations of structures, and make clear what has already been confirmed and what still requires additional checking. If this clarification is in place, it becomes easier to improve the quality of consultations with road authorities, internal briefings, explanations to the client, and pre-construction verifications.

If you want to efficiently reconcile the road ledger with on-site conditions, it is effective to record the site not only with photographs but also as positional information and three-dimensional data. If you can clearly record discrepancies between the road boundary line and the pavement edge, the locations of side ditches and structures, and changes before and after construction, it will be easier to compare later with the ledger drawings. By linking the information obtained on site with the results of the road ledger verification and preparing it so it can be developed into consultation and report materials, the road ledger under Article 28 of the Road Act can be naturally connected to field operations.