What to check before signing a lease for a clinic in Japan — zoning, change of use, and the opening notification

In short: under the zoning rules of the 建築基準法 (Building Standards Act), a 診療所 (shinryojo, a clinic with no inpatient beds or with up to 19 beds) can be built in all thirteen use zones. What stalls a clinic project is not the zone. It is four other things: whether you will have inpatient beds, whether a change-of-use confirmation application is required, what fire safety equipment the building already has, and whether the operator will be an individual physician or a medical corporation. All four can be checked before the lease is signed.

"All that is left is the property." Then the search stops at the viewing stage. The same backtracking that happens with care-service premises happens with clinics. This article is for physicians and dentists opening a clinic in Tokyo, and for landlords considering a medical tenant. Final confirmation always rests with the specified administrative authority, the fire station with jurisdiction, and the public health centre.

Which use zones allow a clinic?

The 建築基準法 (Building Standards Act, Act No. 201 of 1950) lists, in Appended Table 2, the buildings permitted in each use zone. A 診療所 (clinic) is permitted even in the Category I exclusively low-rise residential zone, the most restrictive of them (Appended Table 2, item (i), No. 8). The Category II exclusively low-rise residential zone and the agricultural residential zone incorporate items 1 to 9 of that list by reference.

A 病院 (hospital) is different. It is prohibited in the industrial zone (item (wo), No. 6) and the exclusively industrial zone (item (wa), No. 1), and it is not listed as permitted in the two exclusively low-rise residential zones or the agricultural residential zone.

The dividing line is the number of beds. Article 1-5, paragraph 1 of the 医療法 (Medical Care Act, Act No. 205 of 1948) defines a hospital as a facility with beds for 20 or more inpatients; paragraph 2 defines a clinic as one with no inpatient facility, or with beds for 19 or fewer.

Use zone	Clinic (0–19 beds)	Hospital (20+ beds)
Category I / II exclusively low-rise residential	Permitted	Not permitted
Agricultural residential	Permitted	Not permitted
Category I / II mid-to-high-rise residential	Permitted	Permitted
Category I / II residential, quasi-residential	Permitted	Permitted
Neighbourhood commercial, commercial, quasi-industrial	Permitted	Permitted
Industrial, exclusively industrial	Permitted	Not permitted

District plans, building agreements and municipal ordinances can add restrictions on top. Confirm with the specified administrative authority. How zoning and floor-area ratio move land prices is covered in this article.

Is a change-of-use confirmation application required?

This is where clinics with and without beds diverge most sharply.

Article 87, paragraph 1 of the 建築基準法 applies the confirmation procedure where a building's use is changed into one of the "special buildings" under Article 6, paragraph 1, item 1. That item covers special buildings used for a purpose listed in column (i) of Appended Table 1, where the total floor area for that purpose exceeds 200 m².

And column (i), row (2) of Appended Table 1 reads: "hospitals, clinics (limited to those with facilities for accommodating patients), hotels, inns, boarding houses, apartment buildings, dormitories …".

In other words — a clinic without inpatient beds does not fall within column (i) of Appended Table 1. Converting an office or a shop into a clinic without beds therefore does not, in principle, require a change-of-use confirmation application.

Do not relax at that point. Article 87, paragraph 2 applies Article 48 (use zone restrictions) and other provisions to any change of use, and the substantive requirements — daylighting, smoke exhaust, means of escape, interior finish restrictions — still apply according to the new use. "No confirmation application" does not mean "nobody looks at the work."

	Clinic without beds	Clinic with 1–19 beds
Special building under Appended Table 1 (i)	No	Yes (row (2))
Change-of-use confirmation (Art. 87 (1))	In principle not required	Required if that floor area exceeds 200 m²
Adding beds	—	Prefectural governor's permission (医療法 Art. 7 (3))

Article 7, paragraph 3 of the 医療法 requires the permission of the prefectural governor before beds are installed in a clinic. Beds are not something you add after the property is fixed.

What fire safety equipment should be checked before signing?

Appended Table 1 of the 消防法施行令 (Enforcement Order of the Fire Service Act, Cabinet Order No. 37 of 1961) places clinics in item (6)(i) and splits them four ways.

Category	Content
(6)(i)(1)	Hospitals with a designated clinical department and long-term care or general beds
(6)(i)(2)	Clinics with a designated clinical department and beds for four or more inpatients
(6)(i)(3)	Other hospitals; other clinics with inpatient facilities; birth centres with accommodation
(6)(i)(4)	Clinics with no facility for accommodating patients; birth centres without accommodation

An automatic fire alarm system is required for (6)(i)(1) to (3) regardless of floor area (Article 21, paragraph 1, item 1(i)). A clinic without beds — (6)(i)(4) — needs one where the total floor area is 300 m² or more (same paragraph, item 3(i)).

Here is the trap. Item 3(i) lists "(6)(i)(4) and (ni), (16)(i)" together. Item (16)(i) is a mixed-use fire protection property. Where you lease one room in a tenant building, the unit of assessment can be the building, not the room. A small clinic can fall within scope if the whole building is 300 m² or more.

Sprinkler systems are required for (6)(i)(1) and (2) under Article 12, paragraph 1, item 1(i). Category (4) is not included.

Whether the equipment is already installed, whether additional work is needed and who pays for it — consult the fire station with jurisdiction before signing. A comparable case, where the fire and municipal checks have to come before the lease, is covered here.

How does the operator change the lease?

It changes when the rent starts running.

Article 8, paragraph 1 of the 医療法 requires a physician who has completed clinical training to notify the prefectural governor (or, in a city or special ward with its own public health centre, the mayor or ward mayor) within ten days after opening. Open first, notify afterwards.

Article 7, paragraph 1, by contrast, requires permission where the person opening the clinic is not such a physician — a medical corporation falls here. Permission first, opening afterwards.

Bunkyo City's guidance (accessed 22 August 2026) sets this out as a concrete sequence.

	Individual physician	Medical corporation
Procedure	Opening notification	Permission application → permit issued → open → notification
Timing	Within 10 days after opening	Application before opening
Site inspection	Not stated	Carried out after application
Fee	Not stated	19,000 yen
Prior consultation	Required	Required

And — in both cases the attachments include a copy of the lease. Bunkyo City lists the certificate of all registered matters for the land and building (with a copy of the lease where either is rented), a site plan, a location map, and a floor plan of the building at a scale of 1:100 or larger.

The lease is therefore a precondition for the procedure. Where a medical corporation is the operator, rent runs between signature and the issue of the permit. When to raise a rent-free period, and where to set the handover date, are decided with that gap in mind.

Bunkyo City's page also directs applicants to the Tokyo Metropolitan Government's outpatient medical care plan procedures, and names the Kanto-Shinetsu Regional Bureau of Health and Welfare, Tokyo Office, for insured medical practice. Counters and practice change. Check the page itself at the time you start.

In what order should things be checked?

Order	What to check	Where
1	Use zone; district plans and ordinances	Specified administrative authority
2	Beds or no beds (permission under 医療法 Art. 7 (3))	Prefecture
3	Change-of-use confirmation; certificate of inspection	Specified administrative authority / designated agency
4	Fire safety equipment required and already installed	Fire station with jurisdiction
5	Individual or medical corporation as operator	Public health centre (prior consultation)
6	Landlord's consent (use, signage, plumbing, electrical capacity, restoration)	Landlord / management company
7	Lease terms	Licensed real estate agent

Signing before items 1 to 5 are settled puts the cost of backtracking on the tenant. Settling them first gives you material you can show the landlord — zoning and fire safety are what the landlord wants to know too.

Which clauses of a Japanese lease to read is covered here, and why the same backtracking happens with care-service premises here. See also investment and commercial property and offices and permits.

Who should you consult?

Property investigation, brokerage and the sale or lease contract are handled by Yotsuba Real Estate Co., Ltd. (licensed real estate agent, Tokyo Governor (1) No. 113304). Preparation of documents submitted to public authorities — the clinic opening notification, the opening permission application, and documents for the establishment of a medical corporation — is handled by Yotsuba Administrative Scrivener Office.

These are two independent business entities, engaged separately and directly by you. We neither pay nor accept referral fees or introduction commissions.

Registration is for a judicial scrivener, tax for a licensed tax accountant, disputes for an attorney — each engaged by you directly. Consultation is free of charge.

Frequently asked questions

Q. Can a clinic open in a Category I exclusively low-rise residential neighbourhood?
A. Appended Table 2, item (i), No. 8 of the 建築基準法 lists 診療所 among the buildings permitted there. District plans, building agreements, ordinances, the existing structure, parking and signage all vary by property. Confirm with the specified administrative authority.

Q. We are converting one floor of an office building into a clinic with no beds. Is a change-of-use confirmation required?
A. A clinic without inpatient facilities is not a special building under column (i) of Appended Table 1, so a confirmation application under Article 87, paragraph 1 is in principle not required. Daylighting, smoke exhaust, means of escape and interior finish restrictions still apply. Check the scope of work with your architect and the administrative authority.

Q. Does a small clinic need an automatic fire alarm system?
A. A clinic without beds falls under Appended Table 1 (6)(i)(4) of the 消防法施行令, and Article 21, paragraph 1, item 3(i) requires an alarm system at 300 m² or more. Because that item also lists mixed-use category (16)(i), the assessment in a tenant building can be made for the whole building. Consult the fire station with jurisdiction.

Q. If a medical corporation is the operator, when should the lease be signed?
A. Opening requires permission under Article 7, paragraph 1 of the 医療法, and a copy of the lease is among the attachments to that application — so the lease comes first. Rent runs until the permit is issued. The rent-free period, handover date and termination terms can all be structured before signing.

Q. As a landlord, what should be checked before letting to a clinic?
A. Five things: whether the use zone permits it, the current fire safety equipment and who pays for additions, plumbing and electrical capacity, signage, and the scope of restoration. Where heavy equipment or radiological facilities are involved, floor structure and shielding are also issues. Asking whether the tenant has already consulted the public health centre and the fire station speeds everything up.

Sources (primary)

• e-Gov "建築基準法" (Building Standards Act) — Act No. 201 of 1950. Art. 6 (1) (i); Art. 87 (1) and (2); Appended Table 1 column (i) row (2); Appended Table 2 items (i) No. 8, (ro) No. 1, (ha) Nos. 1 and 3, (chi) No. 1, (wo) No. 6, (wa) No. 1. Current text as amended by Act No. 23 of 2026, in force 27 May 2026. Accessed 22 August 2026.
• e-Gov "医療法" (Medical Care Act) — Act No. 205 of 1948. Art. 1-5 (1) and (2); Art. 7 (1) and (3); Art. 8 (1). Current text as amended by Act No. 31 of 2026, in force 5 June 2026. Accessed 22 August 2026.
• e-Gov "消防法施行令" (Enforcement Order of the Fire Service Act) — Cabinet Order No. 37 of 1961. Appended Table 1 (6)(i)(1)–(4); Art. 12 (1) (i); Art. 21 (1) items 1(i) and 3(i). Current text as amended by Cabinet Order No. 85 of 2025, in force 1 October 2025. Accessed 22 August 2026.
• Bunkyo City, opening notification for a clinic by an individual — within 10 days, prior consultation, required documents. Page updated 8 April 2026. Accessed 22 August 2026.
• Bunkyo City, opening permission for a clinic by a corporation — application before opening, site inspection, fee of 19,000 yen. Accessed 22 August 2026.

Whether a change-of-use confirmation is required depends on the uses before and after, floor area, whether the change is between similar uses designated by Cabinet Order, and whether construction work is involved. This article does not assess any individual property. Fire safety obligations depend on the category, floor area, number of storeys and structure of the fire protection property; prior consultation with the fire station with jurisdiction is necessary. Counters, forms, fees and practice change — check the municipality's own page when you start. Procedures for insured medical practice fall to the Regional Bureau of Health and Welfare.

This article is general information. It does not judge or guarantee the feasibility of any particular property or the grant of any permit. Final confirmation rests with the specified administrative authority, the fire station with jurisdiction and the public health centre. Property investigation, brokerage and sale or lease contracts are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent); the preparation of opening notifications, permission applications and other documents for submission to public authorities is undertaken by Yotsuba Administrative Scrivener Office — two independent business entities, engaged separately and directly. We neither pay nor accept referral fees.

About the author

Joji Uramatsu — licensed real estate transaction specialist (Tokyo Governor registration No. 293544) and administrative scrivener (registration No. 25087022). Representative Director, Yotsuba Real Estate Co., Ltd. (licensed real estate agent, Tokyo Governor (1) No. 113304); principal, Yotsuba Administrative Scrivener Office. Kohinata, Bunkyo, Tokyo, about five minutes' walk from Myogadani station. Property and paperwork are put on the same table. Full profile: author page.