A property for an after-school children's club (gakudo): use zone, area and evacuation

In short: a property usable for an after-school children's club (gakudo = a healthy-development service for after-school children) is decided by roughly five points — (1) the use zone (Building Standards Act, Table 2: a child welfare facility cannot be built in an exclusive industrial zone, but is permitted in the other 12 zones); (2) the exclusive-area figure (the Standards on facilities and operation of after-school children's healthy-development services, MHLW Ordinance No. 63 of 2014, Art. 9: roughly 1.65 m² or more per child, including a resting area); (3) ease of evacuation (if the children's room is above the ground floor, escape routes and fire prevention must be checked); (4) fire service (the use classification under the Fire Service Act enforcement order); and (5) seismic standard (new standard = built on or after June 1981). Final feasibility is confirmed at the counters of the specified administrative authority, the municipality and the fire station.

"I've read about the property requirements for an after-school day-service — is a children's club the same?" We hear this often. The answer is: it is a different scheme, so some of how you read the property differs too. This article sets out, from the provisions and the ordinance, the conformity conditions a landlord or tenant can confirm at the property-selection stage for a children's club (gakudo). The notification for the business itself (the after-school children's healthy-development service notification) is a procedure the administrative scrivener or the operator files with the municipality — we do not act for it. Where a use-change confirmation is required by scale, that goes to an architect.

Is an after-school children's club a different scheme from an after-school day-service — including the property requirements?

Yes. The names are similar and often confused, but the governing law, the supervising authority and the area standard all differ. Get this wrong and both the property you should look for and whom you should consult change.

An after-school children's club (gakudo) is the "after-school children's healthy-development service" defined in Article 6-3, paragraph 2 of the Child Welfare Act: giving children in elementary school whose guardians are not at home in the daytime, owing to work etc., an appropriate place to play and live after class, to foster their healthy development. It is the ordinary "gakudo," regardless of disability.

An after-school day-service, by contrast, is one of the disabled-child day-support services under Article 6-2-2 of the Child Welfare Act, for school-age children with disabilities. The two differ in authority, procedure and standard.

	After-school children's club (gakudo)	After-school day-service
Governing law	Child Welfare Act, Art. 6-3(2)	Child Welfare Act, Art. 6-2-2 (disabled-child day support)
Target	Elementary pupils (guardians away in daytime)	School-age children with disabilities
Procedure	Notification to the mayor (Art. 34-8(2))	Designation by prefecture / designated city
Facility standard	Ordinance No. 63 + municipal by-law	Ordinance No. 15 + municipal by-law
Area	Exclusive area ~1.65 m²/child	Training room etc. (municipal by-law)

The day-service property requirements are set out separately at a property for an after-school day-service, and nurseries at a small-scale nursery and the use zone. This article stays with the children's club (gakudo).

In which use zones can a children's club be used?

A children's club is generally treated under the Building Standards Act as a "child welfare facility, etc." Whether it can be built in a given use zone is decided by Article 48 and Table 2 of the Building Standards Act (Act No. 201 of 1950).

Broadly, you cannot build a child welfare facility in an exclusive industrial zone. In the other 12 use zones it can, in principle, be built. It is also permitted, in principle, in Category I / II low-rise exclusive residential and rural residential zones, though a scale check may apply. Clubs sit inside residential neighbourhoods, so in practice this point rarely blocks.

Use zone	Building a child welfare facility, etc.
Cat. I / II low-rise residential, rural residential	In principle yes (scale check may apply)
Mid/high-rise and residential	Yes
Neighbourhood commercial, commercial	Yes
Quasi-industrial, industrial	Yes
Exclusive industrial	No

"Permitted in that zone" is not a guarantee. Final confirmation rests with the specified administrative authority.

What are the per-child area, resting space and evacuation benchmarks?

The area framework is set by the Standards on facilities and operation of after-school children's healthy-development services (MHLW Ordinance No. 63 of 2014). The core is three things.

• Exclusive-area figure: Article 9(2) sets the area of the exclusive section — with a function as a place to play and live and a function for resting — at roughly 1.65 m² or more per child. The resting space is not a separate aspiration; it is required as an element of this exclusive section.
• Support unit: Article 10(4) sets the number of children in one support unit at roughly 40 or fewer.
• Staff: Article 10 requires at least two after-school children's support workers per support unit, who are childcare workers, certified social workers, etc. who have completed prefectural-governor training (one may be replaced by an assistant).

At the property stage, we first look at whether an exclusive section of children × 1.65 m² can be taken and whether a resting section can be secured. For 40 children, roughly 66 m² or more for the exclusive section is a benchmark. Note, however, that this ordinance is now a "standard to be referred to," and the figures actually applied are set in the municipal by-law. The 1.65 m² and 40 are national benchmarks; confirm against the by-law and operating rules of the intended municipality.

Item	Decided by	Where to check
Exclusive-area figure	Ordinance No. 63 (~1.65 m²/child) + by-law	Municipality
Resting space	As a function of the exclusive section (Art. 9)	Municipality
Support unit (~40 or fewer)	Ordinance No. 63, Art. 10 + by-law	Municipality
Evacuation (if above ground floor)	Building Standards Act rules / practice	Specified administrative authority

Where the children's room is above the ground floor, the evacuation rules of the Building Standards Act and municipal practice add checks. A single ground floor keeps this light.

Can a detached house or vacant shop be converted into a children's club? (from what scale is a use-change needed)

Yes — conversions of vacant shops and houses are common, and here you look at use-change confirmation, seismic and fire.

Article 87, paragraph 1 of the Building Standards Act provides that where a building's use is changed to a special building and the floor area serving that use exceeds 200 m², the confirmation-application rules apply by reference. A child welfare facility is such a special building. Conversely, at 200 m² or less no use-change confirmation is required (this rise to 200 m² came with the amendment in force 25 June 2019; before that it was 100 m²).

But "no application = use it as is" does not follow. Even at a scale needing no application, compliance with evacuation, fire prevention and fire-service law is still required. For seismic, the first split is the new standard, on or after 1 June 1981.

Item	What to confirm	Where
Use-change confirmation	That-use portion over 200 m²? (Art. 87(1))	Specified administrative authority / architect
Seismic	New standard, June 1981 on? If old, diagnosis/reinforcement	Architect
Fire	Use classification and equipment need	Fire station of jurisdiction

Whether the floor area exceeds 200 m², and the design and procedure, are the work of an architect. We give a view on the property's area and current state; the final judgement and application go to an architect directly.

Before securing a property, what should you confirm with the municipality?

A children's club is a service for which the municipality is the implementing body according to local circumstances, and subsidies and operating frameworks differ greatly by municipality. Confirming the following before securing a property reduces rework.

Confirm	Why
By-law standards for area and support unit	The ordinance is only "to be referred to"; real figures are set by by-law
Whether/how to notify (Art. 34-8(2))	A private operator must notify the mayor in advance
Subsidy/commission rules and timing	Where the municipality runs or subsidises, property requirements firm up
Prior fire/building consultation	Fixture burden on conversion can be grasped before signing

The view on whether the layout meets the standard, and the lease/sale brokerage, are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent, Tokyo Governor (1) No. 113304). The roles divide as follows.

Who	Role
Licensed real estate agent (us)	Confirm use zone, area, current state; lease/sale brokerage
Administrative scrivener	Draft the service notification; municipal negotiation
Architect	Use-change confirmation: need, design, procedure
Fire station / fire-equipment worker	Judge and install fire equipment
Judicial scrivener	Company incorporation; property registration

The business notification goes to an administrative scrivener or the operator, the use-change confirmation to an architect, fire equipment to a fire-equipment worker, and incorporation and registration to a judicial scrivener — each engaged directly. These are independent business entities, engaged separately from us. We neither pay nor accept referral fees or introduction commissions. Consultation is free. Business-property matters generally are at business property; property search toward opening, at office and premises.

Frequently asked questions

Q. Can I search for a children's club and an after-school day-service under the same property standard?
A. No — they are different schemes with different standards. A children's club (gakudo) is the Art. 6-3(2) service, exclusive area roughly 1.65 m²/child (Ordinance No. 63), procedure a notification to the mayor. A day-service is disabled-child day support, with a different area standard and a designation procedure. Fix which business it is before you search.

Q. How many square metres must the exclusive area be?
A. Article 9 of Ordinance No. 63 sets the exclusive section — including the resting function — at roughly 1.65 m² or more per child. For 40 children, roughly 66 m² or more is a benchmark. But the ordinance is "to be referred to," and the actual figure is confirmed against the intended municipality's by-law.

Q. Where does a private operator file the notification?
A. Where a party other than the state, prefecture or municipality carries on an after-school children's healthy-development service, it notifies the mayor in advance under Article 34-8(2) of the Child Welfare Act. Drafting the notification is undertaken by an administrative scrivener; we do not act for the notification. The property brokerage and the notification are engaged as independent business entities, separately.

Q. Does changing an office into a children's club always need a use-change confirmation?
A. Where the floor area serving that use exceeds 200 m², a confirmation is required under Article 87(1) of the Building Standards Act. At 200 m² or less none is needed, but compliance with evacuation, fire prevention and fire-service law is separately required. The floor-area judgement and the application go to an architect directly.

Sources (primary)

• e-Gov "児童福祉法" (Child Welfare Act) — Act No. 164 of 1947. Art. 6-3(2) (definition of the after-school children's healthy-development service); Art. 34-8(2) (advance notification to the mayor by a party other than a municipality). Accessed 30 August 2026.
• Standards on facilities and operation of after-school children's healthy-development services (MHLW Ordinance No. 63 of 2014) — Art. 9(2) (the exclusive section, play/live and resting function, roughly 1.65 m² or more per child); Art. 10 (at least two support workers per unit, their qualification and training); Art. 10(4) (one support unit is roughly 40 or fewer). Accessed 30 August 2026.
• e-Gov "建築基準法" (Building Standards Act) — Act No. 201 of 1950. Art. 48 and Table 2 (a child welfare facility cannot be built in an exclusive industrial zone); Art. 87(1) (use change to a special building over 200 m² brings the confirmation rules by reference). Accessed 30 August 2026.
• MLIT, "The Building Standards Act amendment removed the use-change procedure for small buildings (in force 25 June 2019)" — the scale needing a use-change confirmation raised from over 100 m² to over 200 m². Accessed 30 August 2026.

The feasibility of building in a use zone, the area and support-unit standards, and whether a use-change confirmation or fire equipment is needed vary by property and municipality. This article does not assess any individual property. Confirm area, support unit and notification with the intended municipality, use zone and use change with the specified administrative authority, and fire equipment with the fire station of jurisdiction. Figures such as 1.65 m² and 40 are "standards to be referred to," with the applied figures set in the municipal by-law; the figures here are national benchmarks. This article is general information; it does not judge or guarantee that a children's club's notification or operation succeeds at any particular property. Property investigation, the view and brokerage are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent). The service notification goes to an administrative scrivener or the operator, the use-change confirmation to an architect, fire equipment to a fire-equipment worker, and incorporation and registration to a judicial scrivener — independent business entities, engaged separately. 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.