Rental housing management registration and sublease solicitation rules: the 200-unit threshold and the business-manager requirement

In short: a business that is entrusted with managing rental housing must be registered with the Minister of Land, Infrastructure, Transport and Tourism once the number of rental units it manages reaches 200 or more (the proviso to Article 3, paragraph 1 of the Act on Optimisation of Rental Housing Management Business, etc., and Article 3 of its Enforcement Regulation). The registration is valid for five years; the operator must appoint at least one business manager for each business office (Article 12) and must not fall under the grounds for refusal, such as lacking a financial base (Article 6). Separately, when subleasing rental housing under a master lease, regardless of the number of units or of registration, the operator is subject, as a specified sublease operator or solicitor, to the prohibitions on exaggerated advertising and improper solicitation, the pre-contract explanation of important matters, and the delivery of a document at conclusion (Articles 28 to 31). This article is general information organising the scale that triggers registration, the registration requirements, and the sublease solicitation rules; it does not determine any individual registration outcome or make any legal judgement.

From how many managed units is rental housing management registration required?

A rental housing management business is a business that, entrusted by the lessor (owner) of rental housing, carries out the management of rent and the maintenance and preservation of the rental housing (Act on Optimisation of Rental Housing Management Business, etc.; Act No. 60 of 2020). A person seeking to operate this business must be registered with the Minister of Land, Infrastructure, Transport and Tourism (Article 3, paragraph 1). However, a business whose scale is below the scale set by Ministry ordinance is exempt from registration (the proviso to that paragraph), and Article 3 of the Enforcement Regulation sets that scale at 200 managed units. In other words, while the rental housing under management entrustment is below 200 units, registration is optional; once it reaches 200 or more, registration becomes mandatory.

The registration system came into force on 15 June 2021. A person who operates without registration while managing 200 or more units is subject to imprisonment for up to one year or a fine of up to one million yen, or both (Article 41). Self-management, where an owner manages only their own properties themselves, is not management entrusted by another and is therefore outside this registration.

Managed units under entrustment	Whether registration is required
Fewer than 200 units	Optional (registering brings the operator within the rules)
200 units or more	Mandatory (unregistered operation is subject to penalties)
Self-management of one's own properties only	Not management entrustment, so outside the scope

How units are counted, and whether a company's management form amounts to "management entrustment," are ultimately matters for the practice of the registering authority. Our office does not guarantee whether registration is required or possible. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for our services, see Services.

What are the sublease (specified sublease operator) solicitation and exaggerated-advertising rules?

A sublease is a scheme in which an operator collectively leases rental housing from an owner (a master lease, i.e. a specified lease contract) and sublets it to occupants. A person who operates the business of subletting rental housing under such a specified lease contract is a "specified sublease operator," and a person who solicits the conclusion of that contract is a "solicitor." The rules on subleasing apply to all specified sublease operators and solicitors regardless of whether the operator is registered as a rental housing management business or of its scale, and they came into force on 15 December 2020.

Rule	Article	Examples of content
Prohibition on exaggerated advertising	Article 28	On matters such as rent guarantees and termination conditions, one must not make representations that differ markedly from fact or that mislead into believing the terms are markedly superior or more favourable than they are
Prohibition on improper solicitation	Article 29	One must not intentionally fail to state, or state falsely, matters affecting judgement, such as the possibility that rent may be reduced
Pre-conclusion explanation of important matters	Article 30	Before concluding the contract, deliver and explain a document setting out the rent, the content of maintenance and preservation, the contract term, the possibility of a reduction claim, and so on
Delivery of a document at conclusion	Article 31	On conclusion, deliver without delay a document setting out the subject housing, the rent and other conditions, and the method of maintenance and preservation

In particular, representations suggesting that rent is guaranteed into the future, and solicitation that conceals that the rent may be reduced, risk touching on Articles 28 and 29. On the owner's side, it is important to confirm, in the pre-conclusion explanation of important matters, that a presented rent guarantee "does not exclude a reduction claim under the Act on Land and Building Leases." Whether a particular advertisement or solicitation amounts to a violation is a matter for the supervision of the administrative authority and, if disputed, for the judgement of the court.

What are the registration requirements (business manager and financial base)?

If the requirements are met, the applicant is entered on the register of rental housing management businesses. The main requirements and the grounds for refusal of registration (Article 6) are as follows.

Item	Content
Appointment of a business manager	At least one business manager is appointed for each business office (Article 12); the manager cannot concurrently serve at another office
Requirements for the business manager	A person with two or more years of practical experience in management work who has passed the registration examination (the rental real estate management professional examination), or a real estate transaction specialist who has completed the designated training, etc. (Article 14 of the Enforcement Regulation)
Financial base	If the applicant is found not to have a financial base sufficient to carry out the rental housing management business properly, registration is refused (Article 6, paragraph 1, item 10)
Grounds for disqualification	Not falling under, e.g., mental or physical disability, being an undischarged bankrupt, being within five years of imprisonment or a fine under this Act, or ties to organised crime (Article 6)

The registration is valid for five years; to continue to be registered, an application for renewal is made from 90 days to 30 days before the expiry date (Article 3, paragraph 2). Without renewal, it loses effect on expiry. A registration and licence tax of 90,000 yen is payable on new registration.

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The judgement of who qualifies as a business manager, and whether a company's financial base meets the standard, are examined by the registering authority. At the request of an owner or a management company, an administrative scrivener prepares and files documents—such as the registration application and attachments, and the sublease's important-matters explanation and contract documents—within the scope of administrative-scrivener work. Our office does not guarantee the outcome of a registration.

To whom are the real estate broker licence and contract disputes referred?

Rental housing management registration is a system separate from the real estate transaction business (broker) licence. To act as a business in the brokerage or agency of sale, exchange, or lease requires a broker licence, which rental housing management registration cannot substitute for. Yotsuba Administrative Scrivener Office and Yotsuba Real Estate Co., Ltd. are a separate business. The real estate transactions that require a broker licence are handled by Yotsuba Real Estate Co., Ltd. as a real estate transaction agent, while the preparation and filing of registration documents for the management business or sublease are handled by Yotsuba Administrative Scrivener Office, each as an independent business under a separate contract. Our office receives no referral fee.

Individual disputes over a lease—restoration to original condition, rent arrears, eviction—and disputes over sublease rent reductions, including their representation and settlement negotiation, are the domain of a lawyer; real estate registration such as ownership and mortgages is that of a judicial scrivener; and taxation and tax returns relating to the management business or sublease are that of a certified public tax accountant. These are an independent business separate from Yotsuba Administrative Scrivener Office, and you contract with each separately. Our office receives no referral fee. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for our services, see Services.

FAQ

Q. Can I register even with fewer than 200 managed units?
A. Yes. Below 200 units registration is optional, but once registered the operator comes within the rules for a rental housing management business (appointment of a business manager, explanation of important matters in the management-entrustment contract, segregated management of funds, and so on). Voluntary registration is sometimes chosen where the number is expected to reach 200 or more in future, or to raise credibility with counterparties. How units are counted and whether a company is subject to registration are ultimately matters for the registering authority's practice.

Q. Is registration required if I only do subleasing?
A. Subleasing (the specified sublease business) itself has no registration system with a unit threshold like that of rental housing management. However, a specified sublease operator or solicitor is subject, regardless of registration or scale, to the prohibition on exaggerated advertising (Article 28), the prohibition on improper solicitation (Article 29), the pre-conclusion explanation of important matters (Article 30), and the delivery of a document at conclusion (Article 31). In addition, if the management entrustment for maintenance and the like reaches 200 or more units, separate registration as a rental housing management business becomes necessary.

Q. Can anyone become a business manager?
A. No. A business manager is limited to a person with two or more years of practical experience in management work who has passed the registration examination (the rental real estate management professional examination), or a real estate transaction specialist who has completed the designated training, etc. (Article 12 and Article 14 of the Enforcement Regulation). At least one must be appointed for each business office, and concurrent service at another office is not allowed. Whether the qualification requirements are met is ultimately examined by the registering authority.

Q. Can an administrative scrivener prepare the registration documents?
A. The preparation and filing of the registration application and attachments, and of the sublease's important-matters explanation and contract documents, can be handled by an administrative scrivener within the scope of administrative-scrivener work. On the other hand, the real estate transactions that require a broker licence are for a real estate transaction agent; the representation of lease disputes is for a lawyer; registration is for a judicial scrivener; and taxation is for a certified public tax accountant, each as an independent business under a separate contract. Our office receives no referral fee.

Sources (Primary Information)

• e-Gov Law Search, "Act on Optimisation of Rental Housing Management Business, etc." (Act No. 60 of 2020), Articles 3, 6, 12, 28, 29, 30, 31 and 41 (the rental housing management registration system came into force on 15 June 2021; the rules on specified sublease operators, etc., came into force on 15 December 2020) (accessed 2026-09-19)
• e-Gov Law Search, "Enforcement Regulation of the Act on Optimisation of Rental Housing Management Business, etc." (Ministry of Land, Infrastructure, Transport and Tourism Ordinance No. 83 of 2020), Article 3 (the scale requiring no registration = 200 managed units) and Article 14 (requirements for the business manager) (accessed 2026-09-19)
• Ministry of Land, Infrastructure, Transport and Tourism, "Rental Housing Management Business Act Portal" (registration valid for five years; renewal from 90 to 30 days before expiry; registration required at 200 or more managed units) (accessed 2026-09-19)
• Ministry of Land, Infrastructure, Transport and Tourism, "On the method of applying for registration under the Rental Housing Management Business Act" (registration and licence tax of 90,000 yen on new registration) (accessed 2026-09-19)

This article is general information and does not guarantee whether registration is required or possible in any individual case, whether a business manager's qualification requirements are met, or whether an advertisement or solicitation amounts to a violation. The preparation of registration documents and of the sublease's important-matters explanation and contract documents is handled by an administrative scrivener; the real estate transactions that require a broker licence by a real estate transaction agent; the representation of lease disputes by a lawyer; real estate registration by a judicial scrivener; and taxation by a certified public tax accountant, each as an independent business under a separate contract. Yotsuba Administrative Scrivener Office and Yotsuba Real Estate Co., Ltd. are a separate business. Our office receives no referral fee. Individual judgements depend on a meeting with a qualified professional and on the examination by the registering authority. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.