Applying for a hotel license in Japan (旅館・ホテル営業)

Applying for a hotel license in Japan (旅館・ホテル営業)

We are running an Airbnb in Minato-ku Tokyo. It is a detached house. We successfully applied for a minpaku operating license @ 15 June and are now in the process of applying for a hotel license under the new hotel/ryokan law effective 15 June 2018 which would allow a non restricted operation - the chief benefit being no more 180 day limit.

 

If my understanding is correct, previously there were four categories of operation: 「ホテル営業」「旅館営業」「簡易宿所営業」「下宿営業」- roughly corresponding to hotel, hostel, simple hostel, monthly accommodation - with different rules and requirements for each category. Effective 15 June  the first two categories 「ホテル営業」「旅館営業」were merged and a new hotel law introduced (旅館・ホテル営業), which in many cases actually simplifies the hotel operating requirements. This is the one we are applying for. On the other hand interpretation and appliction of the law varies from city to city, ward to ward and is based on zoning - i.e.  第1種住居地域」*less than 3000sqm 「第2種住居地域」 「準住居地域」「近隣商業」「商業」「準工業」- with different rules and restrictions accordingly. 

 

As with minpaku licensing, it is a slow, convoluted, opaque and expensive process. We are using a lawyer to help with the process, however, as it is their first time they are feeling their way in the dark just as much as we are. Of course there is no help from the local Airbnb team. As we need to follow three separate laws (architect, fire, hotel) certain modifications are necessary in order to complete the process. Quotes from would be contractors to complete this are extremely expensive. We wonder to what to extent these are fair given lack of precedent.

 

It seems totally inefficient for individual members of the community to individually embark on this process alone, and the scope for being misadvised and overcharged along the way by would be advisers and contracters seems high, so I hope we can use this conversation thread to share experiences and ideally normalise the process for the benefit of the wider community.

3 Replies 3
Caroline256
Level 2
Tokyo, Japan

Hi! Read your article with a lot of interest! We are considering appyling for the Hotel license as well and don't have a clue where to start. Getting the Minpaku license was bothersome but easy enough that we could manage (we are both foreigners). Have you made any progress since writing the article? Please share! Thanks!

Hi there! We are going through the same problem now! 

We only want to rent out apartments for 30 days+ and our lawyer told us that 30 day stays are NOT classified as "short stays" under Japanese law; and therefore do NOT require any license / notification.

We went to multiple lawyers and they said the same.

However, Airbnb still will not let me list my apartments, insisting on a "notification" or a "license".

 

Are you planning to rent out for "short stay" (less than 30 days) or rent out for 30 days+ only?   Would be keen to compare notes from our lawyers.  Please let me know and we can connect.  Thanks! 

Hey Ana, any luck here?  I notice you have a couple of listings that have - "

Other reasons | Monthly rental for this apartment. This falls outside of the Minpaku or Hotel Business Act. So no need register"
 
How did you do that?