Licensing a game arcade or mahjong parlour (Entertainment Business Act, types 4 and 5): what are the requirements?

In short: to run a pachinko or mahjong parlour (type 4, Article 2, paragraph 1, item 4 of the Act on Control and Improvement of Amusement Business, the "Entertainment Business Act"), or a game arcade / amusement facility (type 5, item 5 of the same paragraph), under Article 3, paragraph 1 you must obtain, for each premises and according to the type of business, the licence of the prefectural public safety commission with jurisdiction over the premises. This is a different licence from the type-1 business that entertains customers and serves food, and you must satisfy all of: (1) the personal requirement (the grounds for disqualification in Article 4, paragraph 1), (2) the location requirement (Article 4, paragraph 2, item 2 and the distance from protected facilities set by cabinet order), and (3) the technical standards for structure and equipment (Article 4, paragraph 2, item 1 and Article 7 of the Enforcement Regulation, such as illumination and partitions). This article is general information organising the requirements and the flow of the type-4 and type-5 licence; it does not judge the outcome of any individual licence.

Which businesses do types 4 and 5 of the Act cover?

The Act defines amusement businesses by type in each item of Article 2, paragraph 1. Types 4 and 5 concern amusement (gaming). The provisions read as follows.

• Article 2, paragraph 1, item 4: "a mahjong parlour, pachinko parlour, or other business that, with equipment provided, lets customers play games that risk inciting a speculative spirit."
• Article 2, paragraph 1, item 5: "a business that, in a shop or similar partitioned facility equipped with slot machines, video game machines or other gaming equipment that can be used for games risking inciting a speculative spirit in a use other than its original use (limited to those set by National Public Safety Commission rules), lets customers play games with that equipment" (excluding businesses falling under item 4).

Type 4 covers mahjong and pachinko parlours — businesses that let customers play games that risk inciting a speculative spirit. Type 5 covers game arcades and amusement facilities that provide gaming equipment, excluding those that fall under type 4. Both differ in type from the type-1 business (snack bars, clubs) that entertains and serves amusement and food.

Type	Typical example	Basis
Type 1	Snack bar, club (entertaining food-and-drink)	Act Art. 2(1)(i)
Type 4	Pachinko parlour, mahjong parlour	Act Art. 2(1)(iv)
Type 5	Game arcade, amusement facility	Act Art. 2(1)(v)

For every type, Article 3, paragraph 1 requires the licence of the prefectural public safety commission for each premises. A licence is granted only after examination; the standard processing period is said to be roughly 55 days depending on the prefecture (some commissions count business days excluding weekends and holidays), and you cannot operate until it is granted. Because the period and forms differ by prefecture, always check with the police station or public safety commission with jurisdiction. On the property's use and area, the real-estate side article What premises can a game arcade or amusement facility choose? (Entertainment Business Act, type 5) is also helpful.

What personal grounds for disqualification prevent a licence?

Article 4, paragraph 1 of the Act provides that a licence will not be granted where the applicant (including, for a company, its officers) falls under certain grounds. The main ones are as follows.

• A person who has received a decision commencing bankruptcy proceedings and has not been restored to rights (item 1)
• A person sentenced to imprisonment of one year or more for certain crimes, or punished for prescribed crimes, and for whom five years have not passed from the day the sentence was completed, etc. (item 2)
• A person for whom there is reasonable ground to find a risk of committing violent unlawful acts or other unlawful acts collectively or habitually (item 3)
• A person addicted to alcohol, narcotics, cannabis, opium or stimulants (item 4)
• A person unable to perform the business properly due to mental or physical disorder, as set by National Public Safety Commission rules (item 5)
• A minor who does not have the same capacity to act as an adult in relation to the business (item 11), a company with an officer who falls under a disqualifying ground (item 12), or a person over whom someone at risk of committing violent unlawful acts has controlling influence (item 13), among others

(Imprisonment without distinctions came into force on 1 June 2025 through amendment of the Penal Code, unifying the former imprisonment with and without work.) The check on personal disqualification is made through the applicant's own declaration and a police investigation. Confirming facts about a criminal record or history is within the jurisdiction of the applicant and the police; our office cannot certify on the applicant's behalf whether there is a criminal record.

How do you check the location requirement (distance from protected facilities)?

For types 4 and 5 too, the "location requirement" is directly tied to property choice. Article 4, paragraph 2, item 2 of the Act provides that a licence will not be granted where the premises are in an area designated by prefectural ordinance, in accordance with standards set by cabinet order as needing special restriction to preserve a good public-morals environment. That cabinet order is Article 6 of the Enforcement Order, which sets a framework allowing ordinances to designate as restricted areas: (1) areas where many dwellings are concentrated, and (2) the areas within a certain distance around "protected facilities" such as schools, libraries, child welfare facilities, hospitals and clinics. For the surroundings of protected facilities, the Enforcement Order sets a limit of roughly a 100-metre zone around the site.

The actual distances differ by prefectural ordinance. Even if the property is in a commercial zone, a nearby school or hospital can make the licence unobtainable due to the distance restriction. Land-use zones are fixed by city planning under the Building Standards Act and change block by block even along the same street. Before deciding on a property, it is essential to check, under the ordinance for the property's location, both the land-use zone and the distance from protected facilities.

Item to check	How to check
Whether it is a restricted area	The prefecture's ordinance under the Entertainment Business Act for the property's location
Distance from protected facilities	The positions of nearby schools, libraries, child welfare facilities, hospitals and clinics, and the ordinance's distances
Land-use zone	The municipality's city-planning information (Building Standards Act)

What must the structural standards (illumination, partitions, gaming machines) meet?

The structural standard is the technical standard under Article 4, paragraph 2, item 1 of the Act, made concrete by National Public Safety Commission rules (Article 7 of the Enforcement Regulation) and prefectural ordinances. The typical standards examined for types 4 and 5 are as follows.

Item	Approximate standard (types 4 and 5)
Illumination	Structure and equipment that keep the illumination in the premises from falling to 10 lux or below (maintenance during operation is Article 14 of the Act)
Sight lines	No equipment inside the guest room that blocks the line of sight
Public morals	No photographs, decorations or other equipment that risk harming good public morals or a clean environment (type 5: also those risking harm to the sound upbringing of minors)
Exits	No locking device on the guest-room exit (except an exit leading directly outside the premises)
Gaming equipment	Type 4: no gaming equipment other than the gaming machines used in the business; type 5: no gaming equipment with a device that accepts banknotes for game charges or that provides cash or securities

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In addition, for type-4 businesses such as pachinko and slots, installing gaming machines that markedly risk inciting a speculative spirit is prohibited, and gaming machines are subject to model regulation (Article 20 of the Act). Type-4 businesses (pachinko parlours and others set by cabinet order) are also subject to provisions prohibiting the provision of cash or securities as prizes and the buy-back of prizes provided to customers (Article 23, paragraph 1). For type-5 game arcades, a person under 18 may not be allowed to enter as a customer between 10 p.m. and 6 a.m. the next day (Article 22, paragraph 1, item 5). Because being flagged in the on-site inspection follows when the drawings (area-calculation drawing and floor plan) and the actual state differ, it is safer to build the structural standards into the interior design stage.

Who handles the property, design, labour and appeals?

Opening a business using gaming equipment spans several specialist fields. The roles are as follows.

• Confirming requirements, preparing the application documents, and acting as agent for the amusement business (type 4 / type 5) licence application → Yotsuba Administrative Scrivener Office (administrative scrivener)
• The lease of the shop property and advance checking of the location (land-use zone and distance from protected facilities) → Yotsuba Real Estate Co., Ltd. (licensed real estate broker)
• Interior and structural-equipment drawings (area-calculation drawing and floor plan), design and work → architects and interior contractors
• Labour management such as staff shifts and late-night work, and social insurance → labour and social security attorney
• Appeals against a refusal or suspension order, and litigation → lawyer

Yotsuba Real Estate Co., Ltd., a separate business from Yotsuba Administrative Scrivener Office, handles the property search, the lease and the advance check of the land-use zone and distance from protected facilities under a separate contract as an independent business. The structural drawings are for architects, labour and social insurance for the labour and social security attorney, and appeals and litigation for a lawyer; each contracts separately as an independent business. Each field is on the premise that you contract separately with each counter or qualified professional, and our office receives no referral fee. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for the whole picture of our services, see Permits and Applications. On the type-1 entertaining food-and-drink business, Distance restrictions for the type-1 entertaining food-and-drink business, a different business from a game arcade or mahjong parlour and, on late-night alcohol service, Serving alcohol after midnight: what notification do you need? are also helpful.

FAQ

Q. What is the difference between type 4 and type 5?
A. Type 4 is a mahjong or pachinko parlour or other business that, with equipment provided, lets customers play games risking inciting a speculative spirit (Article 2, paragraph 1, item 4). Type 5 is a business that provides slot machines, video game machines or other gaming equipment for customers to play, excluding those falling under type 4 (item 5 of the same paragraph). Game arcades and amusement facilities are type 5. For both, Article 3, paragraph 1 requires the public safety commission's licence for each premises.

Q. Isn't a notification enough for this business?
A. No. Types 4 and 5 require a "licence." A late-night alcohol-serving restaurant business (without entertainment) needs only the "notification" under Article 33, paragraph 1, but types 4 and 5, which let customers play games with gaming equipment, are subject to a "licence" that examines the personal, location and structural requirements. You cannot start operating until the licence is granted.

Q. If the property is in a commercial zone, is the distance restriction irrelevant?
A. No. Even in a commercial zone, a nearby protected facility such as a school, library, child welfare facility, hospital or clinic can make the licence unobtainable under the prefectural ordinance's distance restriction. The distance differs by ordinance, and Article 6 of the Enforcement Order sets a limit of roughly 100 metres around a protected facility. Check the ordinance for the location before signing the lease.

Q. Are there hours when minors may not enter a game arcade?
A. For a type-5 business, a person under 18 may not be allowed to enter the premises as a customer between 10 p.m. and 6 a.m. the next day (Article 22, paragraph 1, item 5). Check the age and hours in the guidance of the police station with jurisdiction. Note that the operating hours themselves may also be restricted by prefectural ordinance.

Sources (Primary Information)

• e-Gov Law Search, "Act on Control and Improvement of Amusement Business" (Act No. 122 of 1948), Article 2, paragraph 1, items 4 and 5; Article 3, paragraph 1; Article 4, paragraph 1 and paragraph 2, items 1 and 2; Article 14; Article 20; Article 22, paragraph 1, item 5; Article 23, paragraph 1 (accessed 2026-10-28)
• e-Gov Law Search, "Enforcement Order of the Act on Control and Improvement of Amusement Business" (Cabinet Order No. 319 of 1984), Article 6 (standards for restricted areas; limit of roughly 100 metres around a protected facility) (accessed 2026-10-28)
• e-Gov Law Search, "Enforcement Regulation of the Act on Control and Improvement of Amusement Business" (National Public Safety Commission Rule No. 1 of 1985), Article 7 (technical standards for the structure and equipment of type-4 and type-5 businesses; 10 lux of illumination) (accessed 2026-10-28)
• e-Gov Law Search, creation of imprisonment without distinctions by the "Act Partially Amending the Penal Code, etc." (in force 1 June 2025) (accessed 2026-10-28)
• Each prefecture's ordinance under the Entertainment Business Act and the amusement-business licence guidance of the police station (prefectural public safety commission) (restricted areas, structure and equipment, standard processing period) (accessed 2026-10-28)
• e-Gov Law Search, "Building Standards Act" (land-use zones) (accessed 2026-10-28)

This article is general information and does not guarantee the outcome of any individual licence, whether the premises fall within a restricted area, compliance with the structural standards, the required documents, the examination period, or the applicability of grounds for disqualification. Because standards such as distance, illumination and gaming machines and the forms differ by prefecture and the law is amended, always check the latest content in the ordinance for the premises' location and the official guidance of the police station with jurisdiction. The outcome and examination of the type-4 and type-5 licence are decided by the prefectural public safety commission (police station with jurisdiction). The lease and location check are handled by Yotsuba Real Estate Co., Ltd. (licensed real estate broker), a separate business, the structural drawings by architects, labour and social insurance by a labour and social security attorney, and appeals and litigation by a lawyer, each as an independent business under separate contracts and procedures. Our office receives no referral fee. Individual judgements are made by a qualified professional after a meeting. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.