Special-zone minpaku (national strategic special zone foreign-visitor accommodation business): property requirements and the certification flow

In short: a property usable for special-zone minpaku (the national strategic special zone foreign-visitor accommodation business) is largely decided by three points — (1) whether it is in a zone and land-use district the municipality allows, (2) whether a room of roughly 25㎡ or more is fitted with a kitchen, bath, toilet and washbasin, and (3) whether you can put in place neighbour notification and complaint handling. The stay is, as a rule, at least two nights and three days.

For operators and investors looking for an accommodation-use property in a national strategic special zone such as Ota Ward (Tokyo) or Osaka City, this organises the property side of special-zone minpaku — only "what you can check about the property": land-use district, room area and equipment. The certification application under Article 13 of the National Strategic Special Zones Act, and the licensing judgment of which system to choose among minpaku, lodging business and special-zone minpaku, go to an administrative scrivener; the need for fire-safety equipment to the fire station with jurisdiction; tax to a licensed tax accountant — each routed separately. How to view a minpaku property under the Housing Accommodation Business Act is in conditions for a property usable as minpaku. The licensing procedures — the difference between a minpaku notification and a lodging-business permit, the 180-day cap — are in the administrative scrivener's columns what is needed to start a minpaku and the conditions and flow of a simple-lodging lodging-business permit.

How does special-zone minpaku differ from minpaku and the lodging business?

Special-zone minpaku is a separate system allowed only in national strategic special zones. You receive municipal certification and may run an accommodation business without being subject to the Hotel Business Act. A one-night stay is not allowed; the stay is, as a rule, at least two nights and three days.

Housing accommodation (minpaku), the lodging business (simple lodging, etc.) and special-zone minpaku differ in their governing law, procedure and minimum stay. Special-zone minpaku is the foreign-visitor accommodation business under Article 13 of the National Strategic Special Zones Act (Act No. 107 of 2013), and can only be carried out in an area designated as a national strategic special zone.

System	Governing law	Procedure	Minimum stay / annual cap
Special-zone minpaku	National Strategic Special Zones Act Art. 13	Municipal certification (specific certification)	As a rule, at least 2 nights/3 days. No annual operating-days cap
Minpaku	Housing Accommodation Business Act	Notification to the prefectural governor, etc.	No minimum stay. Annual provision capped at 180 days
Lodging business (simple lodging, etc.)	Hotel Business Act	Permit from the prefectural governor, etc.	No stay or operating-days limit

Once certified, special-zone minpaku is exempt from the Hotel Business Act, with no annual operating-days cap. On the other hand, the areas where it can be carried out are limited to national strategic special zones, and the stay has a floor of, as a rule, two nights and three days. Note that in Osaka City, the acceptance of new certification applications and change applications such as adding rooms ended on 29 May 2026 (Reiwa 8). Which system to choose varies with the property's location and the business plan, and the licensing judgment of system choice is the province of an administrative scrivener.

In which zone and land-use district can a property be used for special-zone minpaku?

First, it must be within the area of a municipality that carries out special-zone minpaku as a national strategic special zone. On top of that, the land-use district is limited by the municipality's ordinance and guidelines, and residential-only districts generally cannot be used.

Special-zone minpaku is carried out in areas designated as national strategic special zones, such as Ota Ward in Tokyo and Osaka Prefecture / Osaka City (new acceptance ended). The treatment of land-use districts is set by each municipality's ordinance and guidelines. Ota Ward, for instance, limits its operating area — from the viewpoint of preserving the existing living environment — to land-use districts where a hotel or inn can be built under Article 48 of the Building Standards Act.

Ota Ward example (land-use districts of the operating area)	Whether included
Category II residential, quasi-residential, neighbourhood commercial, commercial, quasi-industrial	Included in the operating area
Category I residential	Only buildings of 3,000㎡ or less are included
Category I/II low-rise residential exclusive, rural-residential, etc. (residential-exclusive system)	Not included in the operating area

Because the zone/land-use lines differ by municipality, confirm before viewing — against the municipality's latest guidelines and the city-planning map — whether the property's location is within the operating area and whether the land-use district is one where a hotel or inn can be built. For a leased property, also check that the lease and the management rules do not prohibit an accommodation business.

What room area and equipment are required?

A room of roughly 25㎡ or more, fitted with a kitchen, bath, toilet and washbasin; locks on the entrance and windows; appropriate ventilation, lighting and illumination; bedding and furniture provided and cleanliness maintained. Foreign-language guidance is also a requirement.

The facility standards for special-zone minpaku are set by the National Strategic Special Zones Act Enforcement Order (Cabinet Order No. 99 of 2014) and, under it, the MHLW ordinance and each municipality's ordinance. The main points that bite on the property side are as follows.

Check item	Guide / content
Area of one room	Roughly 25㎡ or more (confirm against the municipality's ordinance/guidelines)
Water facilities	A kitchen, bath (shower acceptable), toilet and washbasin
Security / partitioning	Each room's entrance and windows can be locked
Hygiene / habitability	Appropriate ventilation, lighting, illumination; bedding and furniture provided; cleanliness maintained
Guidance for guests	How to use the facility and the surrounding area provided also in a foreign language
Fire	Per use/scale, automatic fire-alarm equipment, fire extinguishers, etc. Confirm with the fire station

"25㎡ or more per room" is common to many operating municipalities, but the way area is reckoned by number of rooms and the fine detail differ by municipality, so confirm against the ordinance and guidelines. Fire-safety equipment varies with the building's use and scale; automatic fire-alarm equipment and fire extinguishers are required depending on the total floor area and number of storeys. Be sure to confirm the need for, and specifications of, fire-safety equipment with the fire station that has jurisdiction.

For neighbour notification and complaint handling, what is required of the property?

Before opening, you must notify neighbouring residents of the business and set up a point of contact that responds appropriately and promptly to complaints and enquiries. The property side needs a place to post the contact details and the capacity to maintain a complaint-handling setup.

For special-zone minpaku, explanation to neighbouring residents and a complaint/enquiry-handling setup are among the certification requirements. Osaka City requires setting up a complaint-handling counter and posting a sign showing the facility name, the complaint recipient and a phone number; Ota Ward and others require holding an explanatory session for neighbours and keeping a record of it. In practice, notifying residents of buildings within a set range of the facility's boundary (e.g. roughly 10 m) by leafleting or visits is the operating approach.

What the property equips	Content
Notification	Inform neighbours of the business before opening (explanatory session, leaflet, visit, etc.; keep a record)
Complaint counter	Set up a contact setup that handles complaints/enquiries appropriately and promptly
Posting a sign	Secure a place to post the facility name, complaint recipient and contact details

Where a unit in a multi-unit building is used, the relationship with the other residents of the same building is especially likely to become an issue, so checking the management rules and careful notification of neighbours matter from the property-selection stage. The concrete method of notification and complaint handling is set by the municipality's ordinance and guidelines.

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What should be prepared on the property side before the certification application?

Assemble: whether the location fits the operating area/land-use district, the floor plan, room area and equipment drawings, a prior consultation with the fire station, confirmation of the lease/management rules, and the neighbour-notification plan. These are things you can check and prepare on the property.

The certification application itself is the province of an administrative scrivener, but there are things to get in order on the property side as a premise of the application. Fixing the property's conformity first makes system choice and the application smoother.

Property-side material / check to prepare	Where to confirm
Whether the location is in the operating area, and whether the land-use district allows a hotel/inn	The municipality's city-planning map / guidelines
Current state of the floor plan, room area, equipment (kitchen, bath, toilet, washbasin)	The property drawings / site
Current state and need of fire-safety equipment	Prior consultation with the fire station
Whether the lease / management rules prohibit an accommodation business	The lessor / management association
Plan for neighbour notification and complaint handling	The municipality's guidelines

Confirm the property's conformity and the current state of fire and equipment by document and on site, and hand system choice and the certification application to an administrative scrivener. The whole picture of finding a business-use property is at business-use property consultation; the investment viewpoint is at investment and business property consultation.

For the certification application, system choice and tax — who should you consult?

Investigation of the property, conformity confirmation, brokerage and the lease are ours; the rest is divided.

Confirming the property's location, land-use district and equipment conformity, brokerage of the lease or sale, and the important-matters explanation are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent, Tokyo Governor (1) No. 113304). We and the administrative scrivener, licensed tax accountant and others are each independent business entities. Where roles overlap, we make clear before the contract who does what, and you engage each separately.

The certification application under Article 13 of the National Strategic Special Zones Act, and the licensing judgment of which system to choose among minpaku, the lodging business and special-zone minpaku, go to an administrative scrivener; tax on the accommodation business to a licensed tax accountant; disputes such as contract trouble to an attorney; the need for fire-safety equipment to the fire station with jurisdiction — each consulted or engaged by you directly. We neither accept nor pay referral fees or introduction commissions. Consultation is free of charge.

Frequently asked questions

Q. Does special-zone minpaku have an annual operating-days cap?
A. No. Whereas minpaku under the Housing Accommodation Business Act is capped at 180 days of provision a year, special-zone minpaku is certified by the municipality and exempt from the Hotel Business Act, so there is no annual operating-days cap. A one-night stay is not allowed; the stay is, as a rule, at least two nights and three days. Which system fits the property and business plan is the province of an administrative scrivener.

Q. Can special-zone minpaku be done in a property in a residential-only district?
A. Generally no. In the Ota Ward example, the operating area is limited to land-use districts where a hotel or inn can be built under Article 48 of the Building Standards Act (Category II residential, quasi-residential, neighbourhood commercial, commercial, quasi-industrial, and Category I residential at 3,000㎡ or less), and residential-exclusive districts are not included. Because the zone/land-use lines differ by municipality, confirm against the municipality's guidelines and city-planning map.

Q. How many square metres does a room need?
A. In many operating municipalities, roughly 25㎡ or more per room is the guide. But the way area is reckoned by number of rooms and the fine detail differ by municipality's ordinance and guidelines. Besides area, a kitchen, bath, toilet and washbasin, locks on entrances and windows, ventilation, lighting and illumination, bedding and furniture, and maintaining cleanliness are requirements. Confirm the latest standards against the municipality's guidelines.

Q. Can I still apply for special-zone minpaku certification in Osaka City now?
A. In Osaka City, the acceptance of new certification applications and change applications such as adding rooms ended on 29 May 2026 (Reiwa 8). You can no longer newly start in Osaka City. Because the areas carried out and the acceptance status vary by municipality, confirm the latest guidance of the municipality where the property is located, and consult an administrative scrivener on system choice.

Sources (primary)

• e-Gov "国家戦略特別区域法" (National Strategic Special Zones Act) — Act No. 107 of 2013. Art. 13 (the national strategic special zone foreign-visitor accommodation business — the specific certification of a business that has foreign tourists use accommodation facilities for a fixed period or more under a lease, etc.; exemption from the Hotel Business Act). Accessed 12 September 2026.
• Cabinet Office, Regional Revitalization Bureau, "On the special case of the Hotel Business Act (special-zone minpaku)" — under the National Strategic Special Zones Act Enforcement Order (Cabinet Order No. 99 of 2014), the period for which the facility is used is set by ordinance within a range of 3 to 10 days (minimum two nights/three days). The guest's nationality is not restricted. Accessed 12 September 2026.
• Japan Tourism Agency, minpaku portal, "On special-zone minpaku" — comparison of special-zone minpaku, minpaku and the lodging business. Accessed 12 September 2026.
• Ota Ward, "National strategic special zone foreign-visitor accommodation business" (special-zone minpaku) — the operating area's land-use districts = limited to those where a hotel/inn can be built under Building Standards Act Art. 48; neighbour notification/complaint handling; fire. Ota Ward guideline (1 April 2026). Accessed 12 September 2026.
• Osaka City, "National strategic special zone foreign-visitor accommodation business (special-zone minpaku)" — complaint-handling counter / sign posting. Acceptance of new and room-addition change applications ended on 29 May 2026. Accessed 12 September 2026.

The zone, land-use district, room area, equipment, stay days, notification and complaint-handling requirements for special-zone minpaku vary with the ordinance and guidelines of the municipality that carries it out, and the acceptance status changes too; this article asserts no specific room-area or equipment detail — confirm the concrete standards against the latest guidelines of the municipality where the property is located (individual applicability is treated as unverified). The need for, and specifications of, fire-safety equipment vary with the building's use and scale, so confirm directly with the fire station that has jurisdiction. The Article 13 certification application and the licensing judgment of system choice among minpaku, the lodging business and special-zone minpaku are for an administrative scrivener; tax on the accommodation business for a licensed tax accountant; disputes for an attorney. This article is general information and does not offer an individual legal or tax determination; the final judgment is made by each qualified professional. Investigation of the property, land-use conformity confirmation, the important-matters explanation, brokerage and the lease/sale contract are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent), which works with administrative scriveners, licensed tax accountants and others as independent business entities engaged separately. There are no referral or introduction 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. He confirms the land-use district and equipment conformity of business-use properties against the statute and municipal materials. Full profile: author page.