What kind of property can host a dementia group home? Use zones, size and fire-safety requirements

In short: a dementia group home (dementia-responsive communal living care) cannot be opened in just any property. Four things bite while you choose the property. First, whether the municipality's "daily-living area" still has room within its planned total user capacity (supply control). Second, that the building is category (6)-ro of Appended Table 1 of the Fire Service Act Enforcement Order and therefore needs sprinklers and other fire equipment. Third, the scale — 5 to 9 residents per unit, up to three units per office — and the size of the private rooms. Fourth, whether converting an existing building triggers a change-of-use confirmation application. Much of this can be narrowed down from the documents before any viewing.

"I want to turn a vacant house or a small apartment building into a group home" — the first thing to check in that conversation is these four points. This article is for care operators and investors considering opening a dementia-responsive communal living care group home (a community-based service) in Tokyo, seen from the standpoint of a real estate transaction. The designation application under the Long-Term Care Insurance Act is handled by an administrative scrivener; fire equipment and change-of-use confirmation applications by fire-protection engineers, architects and designated confirmation and inspection bodies; the labour side for care workers and care-plan staff by a labour and social security attorney. We handle only the property investigation and the transaction, as an independent business entity you engage separately.

What kind of property can host a dementia group home?

It helps to fix how this service is positioned in law, because that drives the property search.

Dementia-responsive communal living care is defined in Article 8, paragraph 20 of the Long-Term Care Insurance Act (Act No. 123 of 1997): providing bathing, toileting, meals and other daily-living care and functional training, in a residence for communal living, to people requiring care who have dementia. It is one of the "community-based services" in Article 8, paragraph 14 of the same Act, used in principle by residents of the municipality where the office is located. It is the mayor of the municipality — not the prefectural governor — who grants the designation (Article 78-2, paragraph 1).

Seen from the property side, the conditions narrow in this order.

Stage	What to look at	Basis
(1) Area capacity	Whether the daily-living area still has room within its planned total user capacity	Long-Term Care Insurance Act Art. 78-2 (5) (iv)
(2) Use zone	Whether the use can be built there	Building Standards Act, use-zone restrictions
(3) Fire safety	Whether category (6)-ro fire equipment can be installed	Fire Service Act Enforcement Order Appended Table 1, Art. 12
(4) Scale / rooms	Whether 5-9 residents per unit and room sizes can be met	Ministerial Ordinance No. 34 of 2006, Art. 93
(5) Change of use	Whether an existing building needs a confirmation application	Building Standards Act Art. 87 (1)

Stage (1) should be checked before you even start looking. However good the property, if the area has no capacity the designation may not be granted.

How do the use zone and the "daily-living area" restriction work?

This is where a group home differs sharply from visiting or day-service offices.

Take the use zone first. A group home is a "residence for communal living" and can be built in most use zones, though restrictions remain — for instance, dwellings and dormitories cannot be built in exclusive industrial zones. Confirm with the municipality's city-planning section that the use is allowed there before you commit.

The "daily-living area" restriction bites harder. In its long-term care insurance business plan, each municipality sets a planned total user capacity for dementia-responsive communal living care per daily-living area. Article 78-2, paragraph 4, item (iv) of the Long-Term Care Insurance Act lets the mayor decline the designation where the total capacity in the applicant's area has already reached, or would exceed, the planned total in the municipal plan, or where the plan's achievement would otherwise be hindered. In other words, if the area has no room, the designation may not be granted however suitable the property.

So the right order is not "find a good property, then check the area" but "first confirm that the municipality and area you want still has capacity, then search for a property within that area." Availability is often shown through public calls for proposals; ask the responsible section at the municipality.

What fire equipment (sprinklers, etc.) and barrier-free requirements apply?

A dementia group home falls within category (6)-ro of Appended Table 1 of the Fire Service Act Enforcement Order (Cabinet Order No. 37 of 1961). Category (6)-ro covers social-welfare facilities housing people who find self-evacuation difficult — short-stay facilities for the elderly, special nursing homes for the elderly, dementia group homes and the like. This heavily affects the fire-equipment burden.

Sprinklers used to be required for (6)-ro only from a total floor area of 275 m². An amendment to the Enforcement Order (in force 1 April 2015) removed that area threshold, so (6)-ro in principle now requires sprinklers regardless of total floor area. A special exception remains where the total floor area is under 275 m² and the building meets certain requirements such as a fire-spread-suppressing structure.

Facility total floor area	Sprinklers ((6)-ro)
275 m² or more	Required
Under 275 m²	In principle required; exempt if it meets a fire-spread-suppressing structure and other requirements

Category (6)-ro also calls for an automatic fire alarm system and a fire alarm that reports to the fire authority, depending on area and other factors. When converting a second-hand house or small apartment building, this sprinkler and alarm cost can be a large part of the opening budget, so consult the fire station with jurisdiction before you commit, to establish what that building actually needs. Feasibility and equipment design belong to fire-protection engineers and the fire station; we do not judge them.

On barrier-free, the Act on Promotion of Smooth Movement of Elderly Persons, Persons with Disabilities, etc. (the Barrier-Free Act) requires conformity with the building-accessibility standard when a "special designated building" such as a home for the elderly is built (including a change of use to it) at a total floor area of 2,000 m² or more. Most group homes fall below that and are only under a duty of effort, but a municipal welfare-town-planning ordinance may extend the scope or lower the size threshold, so check with the municipality. The same structure — administrative and fire checks coming before the property is fixed — is set out in this article on converting an older building with no certificate of inspection into a welfare facility.

When does converting an existing building need a building confirmation?

When converting a vacant house, a former apartment building or an office into a group home, first check whether a change-of-use confirmation application is required.

A dementia group home is treated as a special building under column (i), row (2) of Appended Table 1 of the Building Standards Act (Act No. 201 of 1950). Article 87, paragraph 1 applies the confirmation procedure where a building's use is changed into one of the special buildings under Article 6, paragraph 1, item 1, which 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".

In other words — if the floor area used for that purpose exceeds 200 m², a change-of-use confirmation application is required. This "200 m²" used to be "100 m²"; an amendment (Act No. 67 of 2018, in force 25 June 2019) raised it from over 100 m² to over 200 m², making existing building stock easier to use for smaller welfare facilities.

Floor area used for that purpose	Change-of-use confirmation application
200 m² or less	In principle not required
Over 200 m²	Required (Building Standards Act Art. 87 (1) and Art. 6 (1) (i))

But — "no confirmation application" and "no need to comply with the Act" are two different things. Article 87, paragraph 2 applies Article 48 (use-zone restrictions) and the evacuation and fire-prevention provisions to any change of use; substantive requirements — daylighting, smoke exhaust, means of escape, interior-finish restrictions — apply regardless. The requirement and the design of a change of use belong to architects and designated confirmation and inspection bodies; we handle obtaining and delivering the property documents (registration records, drawings and so on).

How much do the cost and schedule roughly run to?

Cost and schedule turn heavily on the building's state (new build or conversion, sprinklers or not, change of use or not) and on the timing of the municipality's public call, so no single figure applies. What to read at the property-selection stage are the variables below.

Variable	Where it bites
Timing of the area's public call	The entry point for designation; without a call, some periods cannot start
Sprinklers and other fire equipment	Conversion cost; differs by whether the under-275 m² exception applies
Change-of-use confirmation	If over 200 m², design and application time is added
Room and common-area renovation	Meeting 5-9 residents per unit and room sizes (in principle single rooms, 7.43 m² or more)
Securing staff	Care-plan staff (at least one a certified care manager), care workers, etc.

Scale and room standards are set by the Ministerial Ordinance on Standards for Personnel, Facilities and Operation of Designated Community-Based Services (Ministerial Ordinance No. 34 of 2006). Article 93 sets the number of communal-living residences (units) at, in principle, one or two (up to three where local circumstances warrant), the occupancy per unit at 5 to 9, and private rooms at, in principle, one person and a floor area of 7.43 m² or more. Article 90 sets staffing, requiring that at least one of the care-plan staff be a certified care manager. Securing this staffing and designing the labour side belong to a labour and social security attorney; from the property side we confirm only how the building's size caps the number of units and residents. For finding commercial property generally, see investment and commercial property; for the relationship between opening a business and choosing an office, see company formation and choosing an office.

Who should you consult?

Property investigation, obtaining documents, 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 — such as the designation application for dementia-responsive communal living care — is handled by Yotsuba Administrative Scrivener Office.

These are two independent business entities, engaged separately and directly by you. Fire-equipment design and installation go to fire-protection engineers; the change-of-use confirmation application to an architect or designated confirmation and inspection body; the staffing and work rules for care-plan staff and care workers to a labour and social security attorney; tax to a licensed tax accountant; disputes to an attorney — each engaged by you directly. We neither pay nor accept referral fees or introduction commissions. Consultation is free of charge.

Frequently asked questions

Q. If I find a good property, can I open a group home in any municipality?
A. No. Dementia-responsive communal living care is a community-based service, and each municipality sets a planned total user capacity per daily-living area. If the area has no room, the mayor may decline the designation (Long-Term Care Insurance Act Art. 78-2 (5) (iv)). Before searching for a property, confirm with the responsible section that the municipality and area you want still has capacity.

Q. When converting a second-hand house, are sprinklers always required?
A. A dementia group home is category (6)-ro of Appended Table 1 of the Fire Service Act Enforcement Order, and since the amendment in force on 1 April 2015 sprinklers are in principle required regardless of total floor area. A total floor area under 275 m² may be exempt if it meets a fire-spread-suppressing structure and other requirements. It varies by building, so consult the fire station with jurisdiction first.

Q. From what size is a change-of-use confirmation application required?
A. Where the total floor area used for that purpose exceeds 200 m² (Building Standards Act Art. 87 (1) and Art. 6 (1) (i)). This threshold was raised from over 100 m² to over 200 m² by Act No. 67 of 2018 (in force 25 June 2019). Even at 200 m² or less, substantive requirements — daylighting, smoke exhaust, means of escape, interior-finish restrictions — apply according to the new use.

Q. How many residents can one building take?
A. Occupancy per unit (communal-living residence) is 5 to 9; a single office has, in principle, one or two units, up to three where local circumstances warrant (Ministerial Ordinance No. 34 of 2006, Art. 93). The building's size caps how many units and rooms it can hold. Private rooms are, in principle, single rooms of 7.43 m² or more.

Sources (primary)

• e-Gov "介護保険法" (Long-Term Care Insurance Act) — Act No. 123 of 1997. Art. 8 (14) definition of community-based services; Art. 8 (20) definition of dementia-responsive communal living care; Art. 78-2 (1) designation by the municipal mayor; Art. 78-2 (5) (iv) refusal where the planned total user capacity has been reached. Accessed 6 September 2026.
• e-Gov "指定地域密着型サービスの事業の人員、設備及び運営に関する基準" (Standards for Personnel, Facilities and Operation of Designated Community-Based Services) — Ministerial Ordinance No. 34 of 2006. Art. 90 staffing (at least one care-plan staff a certified care manager); Art. 93 number of units, occupancy of 5-9 per unit, private rooms in principle single and 7.43 m² or more. Accessed 6 September 2026.
• e-Gov "消防法施行令" (Fire Service Act Enforcement Order) — Cabinet Order No. 37 of 1961. Appended Table 1 category (6)-ro (dementia group homes, etc.); Art. 12 sprinkler installation standards. The area threshold of 275 m² for (6)-ro was removed by the amendment in force 1 April 2015, making sprinklers in principle mandatory, with an exception under 275 m² for a fire-spread-suppressing structure. Accessed 6 September 2026.
• e-Gov "建築基準法" (Building Standards Act) — Act No. 201 of 1950. Art. 6 (1) (i) special buildings of Appended Table 1 column (i) over 200 m²; Art. 87 (1) confirmation on change of use and (2) application of Art. 48 etc.; Appended Table 1 column (i) row (2). The area threshold was amended from over 100 m² to over 200 m² by Act No. 67 of 2018, in force 25 June 2019. Accessed 6 September 2026.
• MLIT, "Overview of the Barrier-Free Act" — Act on Promotion of Smooth Movement of Elderly Persons, Persons with Disabilities, etc. Homes for the elderly and other special designated buildings must conform to the building-accessibility standard at a total floor area of 2,000 m² or more; municipal ordinances may extend the scope or size threshold. Accessed 6 September 2026.

Whether a property can host a group home depends on the area's capacity, the use zone, fire safety, scale and whether a change of use is required, all combined. This article does not assess any individual property. The requirement and design of fire equipment and of a change of use vary by building; the judgment on legality and the design belong to fire-protection engineers, the fire station, architects, the specified administrative authority and designated confirmation and inspection bodies. Public calls, plans, counters, forms and practice change — check the municipality's, the fire station's and the specified administrative authority's own pages when you start.

This article is general information. It does not judge or guarantee the feasibility of opening any particular property or the grant of any designation. Property investigation, brokerage and sale or lease contracts are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent); the preparation of designation applications and other documents for submission to public authorities is undertaken by Yotsuba Administrative Scrivener Office — two independent business entities, engaged separately. Fire equipment belongs to fire-protection engineers; the change-of-use confirmation to architects and designated confirmation and inspection bodies; staffing and work rules to a labour and social security attorney; tax to a licensed tax accountant. 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.