Japan's Minpaku Rules in 2026: The 180-Night Cap, Ward Limits, Ryokan Licenses and Tokku

TL;DR: Japan’s Private Lodging Business Act (住宅宿泊事業法, the “minpaku law”, in force since June 2018) lets you rent a home to travellers after a simple notification, but only for 180 guest-nights a year. Cities and wards can cut that further by ordinance: Kyoto confines its residential-only zones to a winter window of roughly 60 days, and Tokyo wards restrict days in certain zones. If you need more nights there are two legitimate routes, a special-zone (tokku) minpaku permit inside a designated zone or a hotel/ryokan-law license (usually the simple-lodging category), and the building and its zoning, not your preference, decide which is open to you. The official data shows how unforgiving the model is: as of July 15, 2026 the Japan Tourism Agency counts 26,346 minpaku notifications in Tokyo’s 23 wards since 2018, of which 9,426 (≈36%, computed) have filed for closure, leaving 16,920 active. This page covers the rules; the economics are linked below.

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The 180-Day Rule, Defined

The 180-day rule (the annual cap in the Jutaku Shukuhaku Jigyo Ho, 住宅宿泊事業法, the Private Lodging Business Act, often called the minpaku law) is the ceiling on how many nights a notified private home may host paying guests: at most 180 per year. It counts nights guests actually stay, not nights you list, and unused capacity never rolls over. Per the Japan Tourism Agency’s own system overview, one “day” runs from noon to noon and the year runs from April 1 at noon to the following April 1 at noon. That is neither the calendar year nor a rolling 12 months. The same law lets local governments restrict where and when minpaku may operate by ordinance, and hosting past the cap counts as unlicensed lodging under the hotel/ryokan law. If you need to operate year-round, the only legitimate exits are special-zone (tokku) minpaku or a hotel/ryokan license, both covered below. (Short version: what minpaku is.)

What that means in practice:

• The cap belongs to the dwelling. The notification is filed per dwelling, and the 180 attaches to that dwelling, not to the operator. Cycling the listing between your name, a family member’s name and a management company’s name does not reset the counter; layering registrations that way is legally dubious and not something a foreign investor should try without Japanese-language legal support.
• The practical ceiling is lower than 180. After cleaning turnovers, gap days and local rules, a realistic bookable figure is often 130–150 nights, and a strict ward or city overlay can cut far deeper.
• Pacing matters. Because the counter resets only once a year, an operator who launches partway through the count period and runs hard can hit 180 early and then sit dark until the reset. Plan the calendar around the peak periods you most want to sell.
• Platforms enforce it, and so do regulators. OTA platforms increasingly count nights automatically and cooperate with municipal governments on compliance checks. Operating past 180 nights is unlicensed lodging under the hotel and ryokan business law: business suspension orders, fines up to ¥1,000,000, potential imprisonment, and criminal referral in repeat cases. Enforcement has increased in tourist-heavy zones since 2020.

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Who You File With, and What the Notification Requires

A minpaku notification is not a license application: you are notifying the authority that you intend to operate. That is normally the prefectural governor, but in Tokyo’s 23 wards each ward receives and supervises notifications itself, which is why the Japan Tourism Agency lists every ward as its own authority (see the data below). Your counterparty is the ward office, not the Tokyo Metropolitan Government.

The checklist is still substantial:

• Proof of ownership or lessor consent. Many standard leases prohibit subletting.
• A floor plan showing the unit meets safety requirements.
• Fire alarms and extinguishers, which the law requires.
• Neighbor notification, and in many buildings the management association’s approval. In Japan’s condo market the association has real authority, and many bylaws prohibit minpaku outright. A short-term rental restriction often shows up in the pre-contract disclosure, so read it before contract day (see our sales contract guide).
• Ongoing duties: post the required notices on-site (fire safety, noise rules, contact information) and keep a guest ledger.
• A registered manager if you are absent. If the host does not live on-site, the law requires the management duties to be entrusted to a registered minpaku management company (住宅宿泊管理業者). Fees range from 10% to 25% of gross revenue, with full service typically 18–22%. For a non-resident owner this is not optional, so put it in the model from day one.

The notification does not transfer. It is tied to the registrant, not the property. When you sell, the buyer must file a new notification, and the unit cannot legally operate as a short-term rental in the gap. Price that gap into any purchase of a “turnkey” minpaku.

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How Cities and Wards Cut the Cap Further

The national 180 is a maximum. Municipalities can, and do, set lower limits by zone and by period. Before you model any cash flow you need the ordinance for the property’s specific zone: not the prefecture, not the ward, the zone designation of that address. A licensed Japanese real estate professional or a minpaku management company that works in that municipality is the right person to check, along with the ward’s own minpaku desk.

Tokyo’s ward overlays

Even within the 23 wards, individual ward governments have passed ordinances restricting operating days in certain zoning categories. Some residential zones in Shinjuku limit operation to weekend periods, and Shibuya’s rules are among the strictest in the city, so eligibility there has to be verified address by address. Osaka’s Namba and Shinsaibashi areas have their own overlay rules as well. The ward-level differences show up clearly in the official counts below.

Kyoto: the worked example of a city cutting 180 to about 60

Kyoto City passed its minpaku ordinance in 2018, before the national law came into force, and it is one of the most restrictive in Japan. In residential-only zones, which cover most of Kyoto’s traditional neighbourhood fabric, minpaku under the standard notification is permitted only from mid-January to mid-March: roughly 60 days a year, not 180. In commercial and neighborhood commercial zones the national 180-night limit applies, but those zones are not where most machiya (traditional wooden townhouses) sit. Year-round operation of a residential-zone machiya needs a hotel/ryokan simple-lodging license, which changes the renovation scope entirely. The ordinance also has its own conditions and exceptions, so confirm the rule for the specific address with Kyoto City.

This is where “I’ll buy a machiya for Airbnb” plans most often collapse. A representative case: a buyer models ¥180,000 a month of Airbnb revenue on a ¥28M Nishijin machiya, then learns the zone allows about 60 operating days a year, and walks.

Renovation sets the real cost base. A structurally sound machiya needing interior work runs roughly ¥3–7M, plus ¥0.5–1.2M to bring fire safety up to hotel/ryokan standard. Moderate condition with partial structural work runs ¥8–15M plus ¥1–2M of fire safety. Poor condition, common in Kyoto’s abandoned stock, means ¥15–25M+ or a demolish-and-rebuild that loses the historic character that justified the premium. The model below uses a ¥28M house with ¥12M of work, so yield starts from ¥40M. (Illustrative figures for a 2-room, 4-guest machiya, not a specific property or guaranteed outcome.)

Same machiya, ¥40M all-in	Commercial zone or simple-lodging license (180 nights modeled)	Residential-only zone, minpaku notification (~60-night window)
Nights available	180	60
Occupancy / nights sold	72% / 130	80% / 48
ADR	¥45,000	¥45,000
Gross revenue	¥5,850,000	¥2,160,000
Operating costs (OTA 15%, cleaning ¥15,000/turn, manager 20%, utilities ¥360,000, insurance, reserve)	¥4,677,500	¥2,156,000
NOI	¥1,172,500	¥4,000
NOI yield on ¥40M	2.9%	≈0%

Pushing the commercial-zone case to 80% occupancy adds roughly 14 nights and lifts NOI to ¥1,642,500, a 4.1% yield (computed on ¥40M): better, but thin for an illiquid, management-intensive asset that leans on appreciation of a finite stock. The residential-zone version is near break-even before mortgage, tax and depreciation, an expensive hobby rather than an investment. The ¥45,000 ADR (authentic units run roughly ¥35,000–¥60,000 on Airbnb Kyoto, as of writing) also has to be earned with original materials, tatami, a proper soaking tub and professional photography; saving ¥2M on interior work and pricing at ¥30,000 breaks the model.

Some operators use the 60 minpaku days in peak season and let the house as a furnished monthly rental for the rest of the year, which might achieve ¥150,000–¥250,000 a month in a desirable Kyoto neighbourhood. Stays of 30 nights or more are generally not minpaku, but the blended model needs its own modelling and its own legal structure. Other Kyoto realities: heritage renovations commonly take 12–18 months from purchase to opening; older machiya may not meet current seismic standards; good Kyoto-based minpaku managers are scarcer than in Tokyo and price accordingly; city preservation subsidies are modest (typically ¥500,000–¥2M) and short-term rental use can disqualify you; and the subsidized machiya loans some regional banks offer are generally for Japanese residents.

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How Many Minpaku Tokyo Actually Has (JTA Data, July 2026)

The Japan Tourism Agency (観光庁) publishes cumulative counts of notifications under the Private Lodging Business Act by authority. The table below is the status as of July 15, 2026, from its notification and registration status list. “Notified” is cumulative notifications since the law took effect in 2018 (届出件数), “Closed” is cumulative business-closure filings (事業廃止件数), and “Active” is currently notified dwellings (届出住宅数). The closure rate is our computation (closures ÷ notifications). Wards are sorted by active dwellings.

Ward	Notified (since 2018)	Closed	Active dwellings	Closure rate (computed)
Shinjuku	5,496	1,721	3,775	31.3%
Sumida	3,359	1,045	2,314	31.1%
Shibuya	3,052	1,207	1,845	39.5%
Toshima	2,957	1,131	1,826	38.2%
Taito	2,413	1,040	1,373	43.1%
Minato	1,490	616	874	41.3%
Kita	859	253	606	29.5%
Setagaya	768	222	546	28.9%
Edogawa	783	239	544	30.5%
Nakano	715	257	458	35.9%
Itabashi	684	229	455	33.5%
Suginami	609	169	440	27.8%
Katsushika	800	406	394	50.7%
Bunkyo	500	173	327	34.6%
Adachi	385	107	278	27.8%
Ota	434	180	254	41.5%
Shinagawa	415	173	242	41.7%
Nerima	162	43	119	26.5%
Chuo	126	19	107	15.1%
Chiyoda	69	13	56	18.8%
Koto	112	64	48	57.1%
Meguro	52	26	26	50.0%
Arakawa	106	93	13	87.7%
23 wards (computed sum)	26,346	9,426	16,920	35.8%
Tokyo prefecture (computed: 23 wards + Tokyo-administered areas + Hachioji)	27,076	9,587	17,489	35.4%
Japan (national total, as printed)	65,837	23,767	42,070	36.1%

Source: Japan Tourism Agency, 住宅宿泊事業法に基づく届出及び登録の状況一覧, status as of 2026-07-15. Subtotals and closure rates computed by TPI. The full ward dataset sits on our Tokyo 23 wards property data page.

How to read it honestly:

• More than a third of everything ever notified has closed. In the 23 wards, 9,426 of 26,346 notifications (35.8%, computed) have filed for closure, almost exactly the national rate of 36.1%. The data records that closures happened, not why. The cap economics are one plausible reason: at 180 nights many single-unit P&Ls are thin or negative once cleaning, OTA fees and management are counted (see the line-by-line in our minpaku P&L). Other plausible reasons include the 2020–21 collapse in inbound travel, buildings changing their bylaws, owners moving to a hotel/ryokan license or a long-term lease, and sales. Because a notification does not transfer, a sold unit that the buyer re-notifies shows up as one closure plus one new notification. Read the closure rate as a churn indicator and an upper bound on real exits, not as a failure rate.
• Supply is concentrated. The five largest wards, Shinjuku, Sumida, Shibuya, Toshima and Taito, hold 11,133 of the 16,920 active dwellings (65.8%, computed); Shinjuku alone holds 22.3%. Tokyo’s 23 wards account for 40.2% of all active notified dwellings in Japan (computed).
• Some central wards are nearly empty. Chiyoda (56), Chuo (107) and Meguro (26) are not short of visitors. Low counts there are more plausibly explained by ward ordinances, condo bylaws and building stock than by weak demand, though the table alone cannot separate those causes. Check the ward rule before reading anything into a low number.
• Churn varies widely. Arakawa has closed 87.7% of its notifications, Koto 57.1%, Katsushika 50.7% and Meguro 50.0%. Among the big five, Taito (43.1%) has churned more than Shinjuku (31.3%) or Sumida (31.1%).
• What the table leaves out. Units licensed under the hotel/ryokan law (including simple lodging) or as tokku minpaku are counted separately and are not in these figures, so the table understates total short-term rental supply. And “active” means currently notified, not currently booked: a dormant notification still counts.

For what this supply means for nightly rates in each ward, see our Tokyo STR benchmarks.

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Path Two: Special-Zone (Tokku) Minpaku

Tokku minpaku (特区民泊, special-zone minpaku) is a separate licensing regime created under Japan’s National Strategic Special Zones Act. Inside designated zones it removes the 180-night ceiling entirely, so the same unit can roughly double its booked nights. The catches: a minimum consecutive stay (historically 2–6 nights), a license issued by the municipality after a site inspection, and in practice a Japanese legal entity or resident to hold it. The zones are geographically limited and not static. It is not a gray area, just a different regime with different rules.

Under tokku minpaku:

• No annual cap on operating days.
• Minimum stay requirement, varying by zone: historically 6 consecutive nights in some areas, 2 nights in more recent implementations. Two nights works much like standard minpaku; six targets a different guest (extended-stay leisure, relocating expats, digital nomads), with lower per-night ADR after length-of-stay discounts but lower cleaning cost per night.
• Licensed directly by the municipality, with facility requirements lighter than a full hotel/ryokan license but not trivial: minimum room size, ventilation, fire safety basics, sanitation.
• Regular inspections, and in some zones periodic reporting.

Where it exists. Osaka, notably the Nanko/Bays area and other designated zones in the city, has been the most developed tokku market and the first major implementation, though Osaka is moving to wind it down (see our Tokyo short-term rental investment guide). Tokyo’s footprint is much smaller: parts of Ota-ku had designations in prior years, but ward-level implementation has been far less expansive than Osaka’s. Several regional areas hold National Strategic Special Zone status for other deregulation purposes without the lodging component. A national designation does not guarantee local implementation; some municipalities inside designated zones never implemented tokku minpaku or added restrictions that approach the standard framework.

The process (illustrative, varies by zone): pre-consultation with the municipal authority to confirm the address sits inside the zone and the facility meets baseline requirements; application with photos, floor plans and compliance documents; site inspection; license issuance, typically 2–4 months; then ongoing compliance. A standard minpaku notification does not convert; you apply for tokku separately. Tokku also does not switch off noise ordinances, waste rules or building regulations. It removes the cap, not the rest of the rulebook.

The traps. Marketing material sometimes claims tokku eligibility from proximity to a zone, not confirmed inclusion; verify the exact address with the municipality, not a map. And properties in established tokku areas are already priced for the income upside, so the NOI advantage shown below may be capitalized into the purchase price.

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Path Three: The Hotel/Ryokan License

The ryokan license (旅館業許可, ryokan-gyo kyoka) is the full lodging license under Japan’s Hotel and Ryokan Business Act (旅館業法). It covers hotels, ryokan and the simple-lodging category (kani shukusho, 簡易宿所) that most residential short-term rental investors actually pursue, because its requirements are lower than full hotel classification. The prize is no operating-day cap: you can run 365 nights a year. The price is facility and zoning compliance, gated by a public health center (hokenjo) inspection.

For simple lodging in Tokyo (requirements vary by ward and property type):

• Minimum floor area: 33㎡, or 3.3㎡ per guest sleeping area, depending on jurisdiction.
• Ceiling height: minimum 2.1m in sleeping rooms.
• Fire safety: automatic fire alarm system, emergency lighting, extinguishers and exit signage meeting fire defense codes.
• Sanitation: ventilation, lighting, and washing/toilet facilities meeting public health center standards.
• Zoning: the property must sit in a zone where hotel/ryokan business is permitted.

The hokenjo inspection is the gating event; fail it and you restart. Approval typically runs 2–6 months after the inspection, and renovation comes before that, so budget 6–12 months from acquisition to legal operation, often with several million yen of work. Foreign investors usually hold the license through a Japanese company, a GK (godo kaisha) or KK (kabushiki kaisha); confirm with the health center and a local professional what your case requires. Ongoing compliance is heavier than minpaku: guest records kept to a higher standard and, in some jurisdictions, annual inspections. A remote owner paying a manager to handle it should budget roughly 20–25% of gross. And a hotel/ryokan license does not exempt you from ward rules: wards can impose additional operating restrictions, so verify the license path and local operating rules independently.

A standard Tokyo condo is not license-ready. Apart from management-association rules, the public health center will not license a single unit in a residential condo block as a hotel. A detached house sometimes is, especially older construction with generous layouts, although old wooden buildings may need significant structural work to meet fire safety.

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Choosing Your Path: Zoning First, Then the Building

The license decision sets your revenue ceiling before you choose a single guest, and the building usually makes it for you. The kitchen, the fire exits and the toilet-to-room ratio answer the license question faster than any spreadsheet. On a typical detached two-story house in Taito-ku, the minpaku route can be live in about two months, while the hotel/ryokan route for the same house can run around eight months and ¥3.5M of renovation (illustrative).

	Minpaku notification	Tokku minpaku	Hotel/ryokan license (simple lodging)
Law	Private Lodging Business Act (2018)	National Strategic Special Zones Act	Hotel and Ryokan Business Act
Night cap	180 a year, lower where local ordinance says so	None; minimum stay (historically 2–6 nights)	None
Where	Residential use, subject to ward/city overlays	Only inside a designated and implemented zone	Zones permitting lodging; many residential zones excluded
Gatekeeper	Ward (Tokyo 23) or prefecture; a notification	Municipality; application and site inspection	Public health center inspection
Facility bar	Fire alarms, extinguishers, notices, guest ledger	Lighter than a hotel, not trivial	Floor area, ceiling height, fire alarm system, emergency lighting, sanitation
Time to operate (illustrative)	About 2 months	License typically 2–4 months	6–12 months from acquisition
Condo units	Only if building bylaws allow	Bylaws still apply	Almost never

Zoning is the first gate. The hotel/ryokan license is issued by the ward-level public health center, but the underlying zoning must permit commercial lodging. In Tokyo that generally means commercial, neighborhood commercial and semi-industrial zones; many residential zones prohibit hotel-category use outright, whatever the building’s condition. Zoning permits the use; it does not grant the license. The Tokyo Metropolitan Government publishes zoning maps online and any licensed agent can pull one in minutes. Do it in week one: buyers who budget a hotel/ryokan renovation and discover the zoning problem in week six of due diligence have wasted the most expensive weeks.

From the desk — With foreign buyers eyeing STR acquisitions, the pattern I keep seeing is that they fall for the building first and ask about the license last, when it should run the other way. The buyers who win are the ones who pull the zoning map and the fire-exit layout before they ever picture the guest reviews, because the building quietly decides which license you can even hope for.

What the 365-night licenses are worth. Same 1LDK, same ¥20,000 ADR and 65% occupancy, two night ceilings (illustrative; costs from a tokku-style operating model):

	Minpaku (180-night cap)	365-night license (tokku or hotel/ryokan)
Nights available	180	365
Booked nights at 65%	117	237
Gross room revenue	¥2,340,000	¥4,740,000
Cleaning (¥10,000 per turn)	¥530,000	¥1,078,000
Management (20% of gross)	¥468,000	¥948,000
Utilities, supplies, insurance, property tax, tools, reserve	¥1,070,000	¥1,320,000
NOI	¥272,000	¥1,394,000
NOI yield on a ¥30M purchase	0.9%	4.6%

Cleaning and variable management roughly double with the doubled nights; fixed costs stay similar. The gross gap is ¥2.4M a year, so a ¥3.5M hotel/ryokan renovation pays back in roughly 1.5 years on revenue alone, or about 3.1 years on the ¥1,122,000 NOI gap (computed). That only holds if the building passes inspection, the zoning permits it and occupancy holds year-round, and with a hotel/ryokan license the 20–25% management cost widens the cost side further.

The hybrid reality. Most buyers still end up with minpaku: their targets sit in mixed residential zones, their buildings are condominiums with bylaws, or the renovation cost for hotel/ryokan compliance exceeds the uplift within their holding period. Minpaku is not a consolation prize; at the right purchase price, 117 booked nights at ¥20,000 still pencils. The two real mistakes are modeling minpaku as if the cap didn’t exist, and buying a hotel/ryokan-viable building, then running it as minpaku because the paperwork felt harder.

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What the Cap Does to the Numbers (Short Version)

Under a hard cap, the night you cannot book is gone, so the rate on the nights you do book becomes the main lever, while fixed costs (utilities, building fees, insurance, reserve) do not shrink with the cap. The full model, rebuilt around about 140 bookable nights, with the case for pushing rate over occupancy, is in our Tokyo short-term rental investment guide. The line-by-line P&L, including the same unit run as a long-term rental and the breakeven occupancy, is in Tokyo minpaku P&L. Neighborhood ADR, occupancy and RevPAR benchmarks, including how to price backwards from a RevPAR target under the cap, are in Tokyo STR benchmarks 2026. To test your own ward and night count, use the minpaku estimator.

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Where This Goes Wrong

• Modeling 180 nights before checking the zone ordinance and the bylaws. In Kyoto this mistake is catastrophic; in Tokyo it is merely expensive. The management association can kill the plan outright.
• Assuming the counter resets on January 1. It resets at noon on April 1; plan launch timing around that.
• Treating “near a tokku zone” as “inside a licensable boundary”, or a national designation as local permission. Confirm the exact address with the municipality.
• Assuming any building can be licensed. Old wooden construction may fail fire safety without structural work, and condo units almost never qualify for a hotel/ryokan license. Pull the zoning map in week one.
• Forgetting the gap on a sale. The notification does not transfer; a buyer must re-file before operating.
• Reading the JTA counts as demand. Active notified dwellings measure permitted supply under one law, not bookings.

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FAQ

What is Japan’s 180-day minpaku rule? Under the Private Lodging Business Act (the minpaku law, in force since June 2018), a notified private home may host paying guests for at most 180 nights a year. It counts nights guests actually stay, not nights you list, and local ordinances can cut it further.

When does the 180-night count reset, and can unused nights roll over? The Japan Tourism Agency defines the year as April 1 at noon to the following April 1 at noon, and one day as noon to noon. Unused nights do not carry forward.

What happens if I exceed 180 nights? Hosting beyond the cap is unlicensed lodging under the hotel and ryokan business law. Penalties include business suspension orders and fines, with repeat cases referred for prosecution; unlicensed operation can carry fines up to ¥1,000,000 and potential imprisonment.

Is there a legal way to operate more than 180 nights? Yes: special-zone (tokku) minpaku inside a designated and implemented zone, or a hotel/ryokan-law license, usually the simple-lodging category. Stays of 30 nights or more are also generally not treated as minpaku. Each route has heavier requirements than a minpaku notification.

Is tokku minpaku available in Tokyo? Only in a small footprint. Ota-ku had special-zone designations in prior years, but Tokyo’s tokku market is much smaller than Osaka’s. Confirm current boundaries for the exact address with the ward office.

How long does a hotel/ryokan license take, and can a foreigner hold one? Approval typically runs 2–6 months after the public health center inspection, so budget 6–12 months from acquisition to legal operation. Foreign investors usually hold the license through a Japanese company (GK or KK); confirm what your health center requires.

Can a Kyoto machiya work as a short-term rental? Only in the right zone-license combination. Kyoto limits minpaku in residential-only zones to a mid-January to mid-March window of roughly 60 days, which in our illustrative model leaves NOI near zero. A commercial-zone house or a simple-lodging license changes the math.

How many minpaku are there in Tokyo? As of July 15, 2026 the Japan Tourism Agency counts 26,346 notifications in the 23 wards since 2018, 9,426 closures and 16,920 active notified dwellings. Shinjuku leads with 3,775.