Minpaku vs Ryokan License in Japan: Three Lodging Regimes Compared

There are three ways to run a minpaku (民泊, short-term rental lodging) in Japan: a notification under the Private Lodging Business Act (住宅宿泊事業法; up to 180 days a year), a licence under the Hotel Business Act (旅館業法; for example, for simple lodging, with no cap on operating days), or certification as a special-zone minpaku (特区民泊) in a National Strategic Special Zone (stays of at least two nights and three days required). The choice has a major impact on operating days, where the property can be located and how demanding the procedures are.

The three minpaku regimes compared

In addition, municipalities may impose their own stricter rules by ordinance. Typical examples are limits on the days of the week or areas where operation is allowed, and requirements for a front desk. Do not rely on the national rules alone; always check the ordinances where the property is located.

Notification under the Private Lodging Business Act (Minpaku Act)

A private lodging business accommodates guests in a residence. No hotel business licence is required, and the business can start once notification has been filed with the prefectural governor or other competent authority. Notification can be filed through the minpaku system operation platform accessible from the Japan Tourism Agency’s minpaku portal.

Requirements for the residence

• It has a kitchen, bathroom, toilet and washbasin
• It is a dwelling used for residential purposes, for example by currently serving as someone’s principal home or being advertised for tenants

The 180-day annual cap

Guests may be accommodated for up to 180 days in each one-year period running from noon on 1 April to noon on 1 April of the following year. A day is counted from noon to noon the following day. Because hosting guests beyond 180 days is not permitted, put a system in place to manage the cap, for example through booking-site settings. In some areas, ordinances set an even shorter operating period.

Main obligations

• Ensuring guests’ hygiene and safety (emergency lighting, signage for evacuation routes, etc.)
• Providing guidance in foreign languages for foreign guests
• Preparing and keeping a guest register
• Explaining considerations for neighbors, such as noise and garbage disposal
• Handling complaints
• Displaying a sign at the notified residence
• Periodic reports: by the 15th of each even-numbered month, report the number of nights, number of guests and breakdown by nationality for the previous two months (a report is required even if there were no guests)

Entrusting management to a registered management company

If the host does not live in the notified residence or will be absent for long periods, management must be entrusted to a private lodging management company (住宅宿泊管理業者) registered with the Minister of Land, Infrastructure, Transport and Tourism. Even if family members live there, the host is treated as absent unless the family member is the person who filed the notification. For owners living overseas, entrusting management is a given.

When attracting guests through booking sites and similar channels, use a private lodging intermediary (住宅宿泊仲介業者) registered with the Commissioner of the Japan Tourism Agency.

Licences under the Hotel Business Act (simple lodging, etc.)

The Hotel Business Act covers three types of business: hotel and ryokan operation, simple lodging (簡易宿所) operation and boarding house operation. What is commonly called minpaku usually operates as simple lodging.

• Licensing: an application is made to the public health center (保健所), which examines whether the structure and facilities meet the standards. A licence is not granted unless the standards are met.
• Floor area: simple lodging requires a total guest room floor area of at least 33㎡. If capacity is set at fewer than 10 guests, an area of at least 3.3㎡ multiplied by the capacity is sufficient. Hotel and ryokan operation requires at least 7㎡ per guest room (at least 9㎡ for rooms with beds).
• Location: operation is not permitted in exclusively residential zones.
• Other laws: the property must also conform to the hotel/ryokan use classification under the Building Standards Act and meet fire safety standards.
• Ordinances: each municipality has additional standards, such as requiring a front desk (玄関帳場).

With no cap on operating days, this route suits businesses that operate year-round. By the same token, property selection and the renovation plan determine whether a licence can be obtained.

Special-zone minpaku and the end of new applications in Osaka City

Special-zone minpaku is the business of operating facilities for foreign visitors’ stays (外国人滞在施設経営事業) under the National Strategic Special Zones Act. Once certified by a municipality in a special zone that has enacted an ordinance, the facility is exempt from the Hotel Business Act.

• Stays must be at least the number of days set by ordinance, with a minimum of two nights and three days.
• Each room must in principle have a floor area of at least 25㎡ (this can be varied at the municipality’s discretion).
• There is no cap on annual operating days.

Only municipalities designated as special zones that have enacted an ordinance can offer this scheme. Osaka City, which has a particularly large number of special-zone minpaku facilities, stopped accepting new certification applications on 29 May 2026, following a rise in complaints about garbage, noise and other issues. Applications to add rooms or increase floor area at already certified facilities also closed on the same date. Facilities certified before then may continue to operate.

Anyone starting a new minpaku in Osaka City will therefore need to choose between a Hotel Business Act licence and a notification under the Private Lodging Business Act. Anticipating that more operators would run similar businesses under hotel business licences after special-zone minpaku closed, Osaka City held a public comment process in June 2026 on a draft amendment to its ordinance on enforcement of the Hotel Business Act. If you are considering a hotel business licence, check the ordinance as it stands at the time of application. Other municipalities may also review their schemes, so check the latest information.

Points for foreign nationals and foreign companies starting a minpaku

Both a private lodging business notification and a hotel business licence can be obtained by a company or an individual. Procedures are not restricted merely because the applicant is a foreign national or foreign company. However, note the following.

• Grounds for disqualification: under both the Private Lodging Business Act and the Hotel Business Act, persons who have received certain criminal sentences, members of organized crime groups and others cannot file a notification or obtain a licence. For companies, this also applies to officers.
• Status of residence: a foreign national living in Japan who runs the business personally needs a status of residence (在留資格) that permits business management.
• Operating structure: you need the capacity to act within Japan, for example to handle complaints and attend the property in an emergency. Owners living overseas should check the specific terms of their contracts with management or operating companies.
• Fire safety procedures: even a private lodging business must confirm compliance with fire safety laws and regulations. Consult the local fire station before filing the notification.

Note also that a residence notified for a private lodging business is treated as a residence under the Building Standards Act. Unlike with a hotel business licence, no change of use to hotel or ryokan is required, which is one reason this route is easier to start.

Choosing a regime: what to check before buying a property

The choice of regime depends on the revenue plan and the property’s conditions.

• To operate year-round: a Hotel Business Act licence (simple lodging, etc.) is the standard route. Properties in exclusively residential zones cannot be used.
• To let your home or a vacant house for part of the year: a private lodging business notification is the simplest option, subject to the 180-day annual cap and any ordinance restrictions.
• To host medium- to long-stay guests within a special zone: special-zone minpaku is an option. Check each municipality’s application status.

Before signing a purchase or lease contract, check the following.

1. The zoning district and which regimes allow operation there
2. Municipal ordinances (stricter rules on operating days, areas, front desks, etc.)
3. For a condominium, whether the management rules prohibit minpaku
4. For a rented property, whether the landlord permits subletting or use as a minpaku
5. Whether renovation is needed to meet Building Standards Act and Fire Service Act standards, and at what cost

The process for foreign nationals buying property in Japan is explained in Buying property in Japan as a foreign national: process and key points. For the tax treatment of lodging income earned by owners living overseas, see also Real estate income for non-residents: tax returns and withholding. If you will operate through a company, How to set up a company in Japan is also useful.

Summary: minpaku vs hotel business licence

A private lodging business can be started by notification but is capped at 180 days a year. A hotel business licence allows year-round operation but requires meeting location and facility standards. Special-zone minpaku is limited to certain municipalities, and Osaka City has stopped accepting new applications. All three are subject to stricter local rules set by ordinance, so checking before you commit to a property is the most important step.

Working with partner administrative scriveners and other specialists, TIMOA supports regime selection, pre-purchase checks on properties and preparation of notifications and licence applications. We can also advise on property acquisition, setting up an operating company and the related tax matters. For details, see our Permits & Financial Licenses services.