In the mid Heian period, kaihatsu ryoshu (local nobles who actually developed the land) began to donate their land to temples or high-ranking aristocrats in order to make their land fuyusoden (donated-type of shoen [manor]); however, they were required to submit kugen (official documents authorized by kokushi [provincial governor] or Gunji [local magistrate] for transfer of the ownership of private property) consisting of daijokanpu (official document issued by Daijokan, Grand Council of State) and minbushofu (official document issued by the minister of minbusho) based on the chokkyo (the imperial sanction) to have their land designated as fuyusoden -- Shoen which consisted of fuyusoden with the complete set of documents submitted was called Kanshofu sho (a shoen enjoying immunity from taxation by virtue of having official documents from both the Council of State and the Ministry of Popular Affairs), and shoen which was virtually treated as fuyusoden merely with approval of kokushi was called kokumen shoen (provincially exempted shoen).
平安時代中期になると、開発領主が自らの土地をこの不輸租田にするために寺社や上級貴族に寄進するようになる（寄進地系荘園）が、不輸租田の指定には勅許とそれに基づく太政官符及び民部省符からなる公験が必要とされており、それらが揃った不輸租田によって構成された荘園を官省符荘、単に国司が承認したために事実上の不輸租田の対象となっていたものを国免荘田と呼ばれた。