Introduction
In recent years, inbound tourism to Japan has rebounded significantly. According to data published by the Japan Tourism Agency, the number of foreign visitors to Japan in 2025 exceeded pre-COVID-19 levels recorded in 2019. As demand has recovered, accommodation supply, particularly in popular tourist destinations, has also expanded. One format that has grown in recent years is “private lodging (minpaku)”, a model under which ordinary residential properties are used to accommodate guests.
Traditionally, the operation of accommodation facilities in Japan has been regulated under the Hotel Business Act. However, operating an accommodation business under that Act requires permission from the prefectural governor, and the requirements for obtaining such permission are relatively stringent. As a result, it has not been easy for ordinary homeowners to enter the market. Against the backdrop of rising inbound demand and growing interest in utilizing vacant properties, the Private Lodging Business Act was enacted in 2018.
According to statistics published by the Ministry of Land, Infrastructure, Transport and Tourism, as of May 15, 2026, the number of notifications filed for a Private Lodging Business under the Private Lodging Business Act had reached 63,658 and has continued to rise since the Act came into force.
This newsletter provides an overview of Japan’s legal framework governing private lodging and highlights recent regulatory developments.
Legal Framework for Private Lodging in Japan
In Japan, a person wishing to operate a private lodging business must generally choose one of the following three frameworks:
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Permission under the Hotel Business Act
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Approval of a Special Zone Private Lodging Business under the National Strategic Special Zones Act
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Notification for a Private Lodging Business under the Private Lodging Business Act.
(A) Permission under the Hotel Business Act
Permission under the Hotel Business Act is typically used for full-scale accommodation businesses, such as hotels and inns, as well as for simple lodging houses where multiple guests share accommodation space. Under this permission-based regime, the relevant facility must satisfy the requirements set out in the Hotel Business Act and other related laws and regulations. Unlike the Private Lodging Business Act, there is no upper limit on the number of operating days per year.
(B) Special Zone Private Lodging Business
A Special Zone Private Lodging Business under the National Strategic Special Zones Act is available only in certain areas designated as National Strategic Special Zones. In these designated areas, a corporation that obtains the required approval may operate a private lodging business without obtaining permission under the Hotel Business Act or filing a notification under the Private Lodging Business Act.
However, this framework is available only in limited areas, including Ota Ward (Tokyo), Osaka Prefecture, and Osaka City. In addition, a major region, Osaka City, has suspended new registrations for Special Zone Private Lodging Businesses.
(C) Notification under the Private Lodging Business Act
Where the above two options are not available or suitable, operators often consider filing a notification under the Private Lodging Business Act. Unlike the first two frameworks, this regime does not require permission or approval. Instead, a person may commence the business by filing a notification with the prefectural governor or other competent authority.
Overview of the Private Lodging Business Act
(A) Regulated Persons and Activities
The Private Lodging Business Act mainly regulates:
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a person engaging in a Private Lodging Business (“Private Lodging Operator”);
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a person entrusted by a Private Lodging Operator to manage a private lodging facility (“Private Lodging Administrator”); and
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a person providing a platform service, such as an online booking or brokerage site for private lodging (“Private Lodging Intermediary”).
The Act also distinguishes between two categories of Private Lodging Businesses:
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a resident-host type, where the host resides in the relevant property (for example, a homestay arrangement); and
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a non-resident-host type, where the host does not use the relevant property as their principal residence.
Different regulatory requirements apply depending on which category is involved.
(B) Key Regulatory Requirements
The principal requirements applicable to Private Lodging Businesses include the following. For brevity, this newsletter does not cover in detail the separate regulations applicable to Private Lodging Administrators and Private Lodging Intermediaries.
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A person intending to engage in a Private Lodging Business must file a notification with the prefectural governor (Article 3).
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The total number of days on which guests may be accommodated in the relevant property must not exceed 180 days per year (Article 2, paragraph (3)).
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The property must be equipped with the following facilities: a kitchen, bathroom, toilet, and washbasin (Article 2, paragraph (1), item (i)).
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For non-resident-host type businesses, the host must, in principle, entrust lodging management services for the property to a Private Lodging Administrator (Article 11).
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Private Lodging Operators must take certain measures to ensure the comfort and convenience of guests who are foreign tourists (Article 7).
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Private Lodging Operators must explain to guests of certain matters, including precautions necessary to prevent noise disturbances, and must respond appropriately and promptly to complaints and inquiries from neighboring residents (Articles 9 and 10).
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Private Lodging Operators must report to the prefectural governor once every two months on matters including the number of days on which guests were accommodated, the number of guests, the cumulative number of guests, and a breakdown of guests by nationality (Article 14).
(C) Supervision and Enforcement
To ensure proper business operations by Private Lodging Operators, the Act provides for various supervisory measures. Administrative actions available under the Act include the following, listed in increasing order of severity:
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Collection of reports and on-site inspections
The prefectural governor may require a Private Lodging Operator to submit reports to confirm compliance with applicable laws and regulations. The governor may also authorize officials to enter the relevant property and inspect books, documents, and other materials (Article 17).
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Order for business improvement
If the prefectural governor determines it necessary to ensure the proper operation of a Private Lodging Business, the governor may issue an order for business improvement (Article 15).
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Order for suspension or discontinuation of business
If a Private Lodging Operator violates an order for business improvement or otherwise breaches applicable laws and regulations, the prefectural governor may issue an order to suspend or discontinue the business (Article 16).
(D) Additional Local Ordinances and other Related Regulations
In addition to the statutory requirements described above, local governments often impose stricter restrictions through ordinances, including limitations on operating hours and operating days. Accordingly, any person considering starting a private lodging business should carefully review the relevant local ordinances, guidelines, and administrative practices in advance.
In addition, where a condominium unit is to be used for private lodging, operators must confirm whether the condominium management bylaws impose any restrictions.
Because properties are being provided to guests for accommodation, operators must also comply with the Building Standards Act, the Fire Service Act, and other building-related regulations.
Recent Regulatory Updates
As noted above, the number of notifications filed for Private Lodging Businesses has continued to rise. At the same time, however, various issues remain unresolved, including disputes with neighboring residents. Recent developments suggest a broader trend toward stricter supervision and regulation.
First, with respect to the Special Zone Private Lodging Business regime, Osaka City—where the majority of special zone private lodging facilities nationwide are located—suspended acceptance of new applications on May 29, 2026. Although facilities that had already obtained certification before that date may continue to operate.
Second, local governments are moving to tighten their supplemental regulations. For example, Sumida Ward (Tokyo) amended its private lodging ordinance on April 1, 2026, significantly strengthening restrictions, including by prohibiting weekday operations for non-resident-host type properties.
Third, administrative enforcement against non-compliant operators has become more visible. Toshima Ward (Tokyo) issued business suspension orders to 15 operators on June 17, 2026. In Shinjuku Ward (Tokyo), the authorities issued the most severe administrative sanction—orders for business discontinuation—on December 4, 2025 and March 16, 2026.
Going forward, it will be important to monitor whether this trend toward stricter regulation continues.
