Premises for an acupuncture or judo-therapy clinic — what to check on the use zone and the health-centre notification

In short: for an acupuncture or judo-therapy (bonesetting) clinic — a treatment facility under the AHAKI Act and the Judo Therapists Act — two things bite first: the use zone (unlike a medical clinic, a treatment facility is generally treated like a "service-business shop" and is subject to use-zone restrictions), and whether you can meet the structure-and-equipment standards (a dedicated treatment room of 6.6 m² or more, a waiting room of 3.3 m² or more, ventilation, and disinfection equipment). The opening notification is filed "within 10 days after opening" by the practitioner themselves; preparation of the documents is undertaken by an administrative scrivener. Confirm the use zone and the floor area and ventilation before you sign, and you avoid the rework.

You lease a place told "all that's left is the fit-out," and then find the treatment room is too small or the ventilation falls short. The same rework that hits restaurants and salons hits acupuncture and judo-therapy clinics. This article is for practitioners opening a shinkyu (acupuncture) or seikotsuin (bonesetting) clinic in Tokyo, and for those leasing to them: what you can confirm before signing the lease, set out from the AHAKI Act (Act on Anma Massage-Shiatsu Practitioners, Acupuncturists and Moxibustion Practitioners) and the Judo Therapists Act. This article does not enter medical judgments such as the handling of treatment fees or the appropriateness of treatment. Final confirmation rests with the specified administrative authority and the health centre.

In which use zones can an acupuncture or judo-therapy clinic open?

First, the framing. A shinkyu clinic is a treatment facility for acupuncture and moxibustion (AHAKI Act); a seikotsuin/bonesetting clinic is one for judo therapy (Judo Therapists Act). Together with anma massage-shiatsu, these are not medical clinics under the Medical Care Act, but "treatment facilities" (施術所). That is the starting point of the use-zone question.

A medical clinic can be built in every use zone under the Building Standards Act, but a treatment facility has no dedicated category in Table 2 of the Building Standards Act, and many specified administrative authorities operate it as being treated like a "service-business shop" (akin to a barber or beauty salon) subject to use-zone restrictions. On that footing, in the strictest residential zone it cannot open as a standalone shop.

Article 130-3 of the Enforcement Order of the Building Standards Act (Cabinet Order No. 338 of 1950) lists the combined-use dwellings that may be built in a Category-1 low-rise exclusive residential zone, on condition that at least half of the total floor area is residential and the shop portion totals 50 m² or less. Where a treatment facility is fitted to item 3 ("a barber shop, beauty salon … and other similar service-business shops"), a Category-1 low-rise exclusive residential zone allows only a small combined-use dwelling. From a Category-1 residential zone upward, it becomes easier to build as a shop of 3,000 m² or less.

Use zone	Rough treatment (where treated as a shop)
Category-1/2 low-rise exclusive residential	As a rule, combined-use dwelling only (residence ≥ ½ of total floor area; shop ≤ 50 m²)
Category-1/2 medium-to-high-rise exclusive residential	Possible under an area limit (depends on local operation)
Category-1/2 residential, quasi-residential	Easier to build as a shop of 3,000 m² or less
Neighbourhood-commercial, commercial, quasi-industrial	May be built

But take care. Some municipalities treat a statutory treatment facility "like a medical clinic" and allow it even in a low-rise exclusive residential zone, so the treatment differs by specified administrative authority. In a tenant building you also need to look at the whole building's use. Because feasibility varies by property, confirm at the specified administrative authority before signing. How the use zone and floor-area ratio move land pricing is at why Japanese land prices change with the floor-area ratio.

What are the structure-and-equipment standards you notify to the health centre?

What the health centre (the prefectural governor, etc.) looks at is the "structure and equipment." Article 9-5, paragraph 1 of the AHAKI Act provides that "the structure and equipment of a treatment facility must conform to the standards prescribed by Ministry of Health, Labour and Welfare ordinance," and paragraph 2 requires hygiene measures. Article 20 of the Judo Therapists Act has the same structure. If it falls short of the standard after the fit-out, you cannot use it as-is. That is the starting point of choosing premises.

The specific figures are in the ordinances. Article 25 of the AHAKI Enforcement Regulation (MHW Ordinance No. 19 of 1990) and Article 18 of the Judo Therapists Enforcement Regulation (MHW Ordinance No. 20 of 1990) require almost the same (accessed 29 August 2026):

Item	The ordinance standard
Treatment room	A dedicated treatment room of 6.6 m² or more
Waiting room	A waiting room of 3.3 m² or more
Ventilation	The treatment room must be openable to the outside air over at least one-seventh of its floor area (unless there is suitable ventilation equipment in its place)
Disinfection	Equipment to disinfect tools and hands used in treatment

Further, Article 26 of the AHAKI Regulation and Article 19 of the Judo Therapists Regulation require, as hygiene measures, keeping the place clean at all times and ensuring sufficient daylight, lighting and ventilation.

What is worth confirming on the property side is whether the place has the makings to meet these figures.

Confirm before signing	Why it matters
Room/layout for a 6.6 m²+ treatment room and a 3.3 m²+ waiting room	Area is core to the ordinance; a one-room unit may not separate treatment and waiting
Window size/position, or ventilation equipment	The treatment room needs 1/7-area outside-air opening or a ventilation device
Position of water supply/drainage	Disinfection of hands and tools needs a washing point
Electrical capacity	Physiotherapy devices, HVAC and water heating draw capacity; upgrades cost time and money
Cleanability of floors/walls	The makings of "kept clean at all times"; also tied to restoration scope

Design of ventilation, plumbing and electrical capacity is the work of the contractor (designer). We (the real estate agent) assist with the groundwork of whether the property can meet these conditions, and with negotiating terms with the lessor. We do not do the equipment design itself. Why the same rework arises is covered at why care-facility premises are hard to find; which parts of the lease to read, at reading a lease.

Where does a second-hand fit-out differ from a bare shell in re-notifying?

A great deal. If the previous tenant was an acupuncture or judo-therapy clinic, the treatment-room partition, washing point and ventilation may remain. But "it was a treatment facility before, so it's fine" is not a guarantee.

Two reasons. First, the notification is filed for each facility (AHAKI Act Article 9-2 / Judo Therapists Act Article 19); the previous shop's notification does not carry over to the new operator. Second, acupuncture/moxibustion (AHAKI) and judo therapy have different governing statutes, so if you do both, each needs its own notification. If the previous shop did only acupuncture and you add bonesetting, the judo-therapy structure and notification are separately required.

	Second-hand (was a treatment facility)	Bare shell
Treatment/waiting partition	May follow the old layout	Designed from scratch
Washing point / plumbing	Often remains (inspect)	New; position from design
Ventilation	May be reusable	New
Notification	Filed anew (AHAKI and judo therapy separately)	Filed anew
Initial-cost tendency	Easier to contain	Tends to rise

Even with a second-hand fit-out, it is safer to inspect before handover whether the treatment-room size and ventilation meet the current ordinance standard. How the lease allocates ownership, repair and removal of the equipment left behind is a point peculiar to second-hand premises.

Who files the opening notification, and when? What to check before the fit-out starts

Here is where it is the reverse of a beauty/barber shop. A salon's opening notification is filed "in advance (before opening)," but a treatment facility's notification is "within 10 days after opening." Article 9-2 of the AHAKI Act provides that "a person who has opened a treatment facility must, within 10 days after opening, notify the prefectural governor of the place of opening, the names of the practitioners engaged, and other matters prescribed by ordinance," and Article 19 of the Judo Therapists Act is the same (in a health-centre city or special ward, the notification goes to that mayor/ward head). On suspension or abolition, you notify within 10 days from that day.

Even though it is "after opening," the structure and equipment must conform to the ordinance standard at the time of opening, so the practical flow is:

Order	What to do	Who
1	Confirm use zone and whether a use-change confirmation is needed	Specified administrative authority; licensed real estate agent
2	Groundwork on treatment/waiting size, ventilation, plumbing	Licensed real estate agent; contractor
3	Lease contract	Licensed real estate agent
4	Fit-out (partition, treatment room, waiting room, ventilation, disinfection)	Contractor
5	Open → notify the facility within 10 days	Operator (the practitioner)
6	Health-centre confirmation / on-site inspection	Health centre

Note that when converting an office or a shop of another trade into a treatment facility, a treatment facility does not usually fall among the special buildings of Table 1, column (i) of the Building Standards Act, so a use-change confirmation application is generally not required. Even so, apart from that, the use-zone restriction (Article 48) and the substantive rules on daylight and ventilation still apply. On fire safety, an acupuncture/judo-therapy clinic is generally treated as item (15) (non-specified use) of Table 1 of the Fire Service Act Enforcement Order, and the required fire equipment varies with the whole building's tenant mix, number of floors and total floor area. Use zone, use change and fire safety can be confirmed before signing with the specified administrative authority and the fire station.

Where do people stumble in the property contract?

Preparation of documents submitted to the health centre, such as the facility notification (within 10 days after opening), is undertaken by Yotsuba Administrative Scrivener Office. The notification itself is done by the practitioner — the administrative scrivener assists with preparing the documents rather than filing on the practitioner's behalf. Where a use change or building confirmation is involved, the design is by an architect; the plumbing and ventilation design of the fit-out, by the contractor. The counter, forms, ordinance figures and intake operation vary. Check the pages of the health centre and specified administrative authority with jurisdiction directly at the outset. Business property in general is at investment and business real estate; the link between offices and permits, at company formation and choosing an office.

Investigation of the property, 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 offices, such as the facility notification, is handled by Yotsuba Administrative Scrivener Office.

These two (the real estate agent and the administrative scrivener office) are independent business entities. You engage each directly. We neither pay nor accept referral fees or introduction commissions. Registration goes to a judicial scrivener, tax to a tax accountant, and labour matters to a certified social insurance labour consultant (opening planned September 2026) — each engaged by you directly. Consultation is free of charge.

Frequently asked questions

Q. Can an acupuncture or judo-therapy clinic open in a residential area (Category-1 low-rise exclusive residential zone)?
A. Under the common operation of treating a treatment facility like a service-business shop, not as a standalone shop as a rule. Under Article 130-3 of the Enforcement Order, it may be built as a combined-use dwelling (residence ≥ ½ of total floor area; shop ≤ 50 m²). Some municipalities treat a statutory treatment facility like a medical clinic, so treatment differs. Confirm per property at the specified administrative authority.

Q. Is there a statutory figure for the size of the treatment room or waiting room?
A. Yes. Article 25 of the AHAKI Enforcement Regulation and Article 18 of the Judo Therapists Enforcement Regulation require a dedicated treatment room of 6.6 m² or more, a waiting room of 3.3 m² or more, outside-air opening over at least one-seventh of the treatment-room area (or ventilation equipment), and disinfection equipment. These are nationwide ordinance standards.

Q. If it was a bonesetting clinic before, will the notification simply pass?
A. It does not carry over. The notification is filed anew for each facility (AHAKI Act Article 9-2; Judo Therapists Act Article 19). Because acupuncture/moxibustion and judo therapy have different governing statutes, doing both needs separate notifications. Inspect before handover whether the equipment left behind meets the current ordinance standard, and confirm with the health centre.

Q. When should I file the notification? Before the property contract?
A. A treatment facility's notification is "within 10 days after opening" (AHAKI Act Article 9-2; Judo Therapists Act Article 19) — the reverse of a salon's "in advance." But the structure and equipment must conform at the time of opening, so prepare in the order property contract → fit-out → opening → notification within 10 days.

Sources (primary)

• e-Gov "AHAKI Act" — Act No. 217 of 1947. Art. 9-2 (facility notification within 10 days after opening to the prefectural governor; suspension/abolition/resumption also within 10 days); Art. 9-5 (structure and equipment to conform to ministerial-ordinance standards; hygiene measures). Accessed 29 August 2026.
• e-Gov "Judo Therapists Act" — Act No. 19 of 1970. Art. 19 (facility notification within 10 days after opening); Art. 20 (conformity of structure and equipment; hygiene measures); Art. 21 (reporting and on-site inspection). Accessed 29 August 2026.
• e-Gov "AHAKI Enforcement Regulation" — MHW Ordinance No. 19 of 1990. Art. 25 (structure/equipment standards — dedicated treatment room ≥ 6.6 m², waiting room ≥ 3.3 m², outside-air opening over ≥ 1/7 of the treatment-room area or ventilation equipment, disinfection equipment); Art. 26 (hygiene measures — cleanliness, daylight/lighting/ventilation). Accessed 29 August 2026.
• e-Gov "Judo Therapists Enforcement Regulation" — MHW Ordinance No. 20 of 1990. Art. 18 (structure/equipment standards, almost identical to AHAKI Reg. Art. 25); Art. 19 (hygiene measures). Accessed 29 August 2026.
• e-Gov "Enforcement Order of the Building Standards Act" — Cabinet Order No. 338 of 1950. Art. 130-3 (combined-use dwellings in a Category-1 low-rise exclusive residential zone — residence ≥ ½ of total floor area, shop portion ≤ 50 m²). Accessed 29 August 2026.
• e-Gov "Building Standards Act" — Act No. 201 of 1950. Art. 48 (use-zone restrictions); Table 2 (buildings by use zone). Accessed 29 August 2026.

The use-zone treatment of a treatment facility (whether treated like a service-business shop or like a medical clinic) differs by specified administrative authority. This article does not assess any individual property. Confirm with the health centre, specified administrative authority and fire station with jurisdiction at the outset. Whether fire equipment or evacuation measures are required varies with the number of floors, total floor area and tenant mix. This article is general information; it does not judge or guarantee the feasibility of any particular property or acceptance of a notification, and does not enter medical judgments such as treatment-fee handling. Investigation and brokerage, and the sale/lease contract, are by Yotsuba Real Estate Co., Ltd. (licensed real estate agent); preparation of the facility notification and other public-office documents, by Yotsuba Administrative Scrivener Office — 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.