A game arcade's type-5 licence under the Entertainment Business Act: requirements, distance rules and the application flow

In short: to run a game arcade or amusement facility that provides crane games and gaming machines, the business falls under type 5 (Article 2, paragraph 1, item 5 of the Act on Control and Improvement of Amusement Business, the "Entertainment Business Act"), and under Article 3, paragraph 1 you must obtain, for each premises, the licence of the prefectural public safety commission with jurisdiction over its location. The licence requires satisfying 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); you file the application and drawings through the police station with jurisdiction and can operate only after examination and an on-site inspection. This article is general information organising the type-5 requirements, the application flow and the operating rules; it does not judge the outcome of any individual licence.

Why is a game arcade a type-5 business under the Act, and which shops need a licence?

The Act defines amusement businesses by type in each item of Article 2, paragraph 1. A game arcade or amusement facility falls under item 5. The provision reads as follows.

• 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 a business falling under item 4, a mahjong or pachinko parlour).

What is regulated here is not every machine in the shop, but 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 (the Enforcement Regulation). Which equipment falls within scope, and how it is judged by the scale of the shop and the proportion of equipment, depends on the Enforcement Regulation's standards, so among shops that "have games," some are type-5 businesses and some are not. Whether your shop falls under type 5 (whether a licence is needed) is best confirmed, before deciding on a property, with the police station (community safety division) with jurisdiction, showing the specific type and layout of the equipment you will install.

Type	Typical example	Basis
Type 4	Pachinko parlour, mahjong parlour	Act Art. 2(1)(iv)
Type 5	Game arcade, amusement facility	Act Art. 2(1)(v)

A shop falling under type 5 requires the licence of the prefectural public safety commission for each premises under Article 3, paragraph 1, and cannot start operating until the licence is granted. On the whole picture of types 4 and 5, Licensing a game arcade or mahjong parlour (Entertainment Business Act, types 4 and 5): what are the requirements? is also helpful. 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) covers that.

What must the structural standards (sight lines, illumination, 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 a type-5 business are as follows.

Item	Approximate standard (type 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, a clean environment, or the sound upbringing of minors
Exits	No locking device on the guest-room exit (except an exit leading directly outside the premises)
Gaming equipment	No gaming equipment with a device that accepts banknotes for game charges or that provides cash or securities

A type-5 business is prohibited from mechanisms that provide cash or securities according to the result of play. The handling of prizes (which items may be provided and within what price range) also follows the National Police Agency's interpretive standards, and the handling of crane-game prizes needs to be checked shop by shop. Because being flagged in the on-site inspection follows when the drawings submitted with the application (area-calculation drawing, floor plan, lighting-equipment drawing) and the actual state differ, it is safer to build the illumination, sight lines and equipment layout into the interior design stage. As the specific figures and forms differ by prefecture, check the latest content in the guidance of the police station with jurisdiction.

Where are the land-use zone and the distance from protected facilities decided?

For type 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 signing the property lease, 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 do you file with the public safety commission, and how long does it take?

The application is made, through the police station (community safety division) with jurisdiction over the premises' location, to the prefectural public safety commission. The main documents are as follows (forms, numbers of copies and attachments differ by prefecture).

Category	Main documents
Common	Licence application (prescribed form), a document stating the method of business, a document establishing the right to use the premises (such as the lease), the floor plan, area-calculation drawing and lighting drawing of the premises, and an outline map of the surroundings (showing the positions of protected facilities within roughly 100 metres)
Individual applicant	The applicant's certificate of residence, certificate of status, and a written pledge
Corporate applicant	Articles of incorporation, certificate of registered matters, and the certificate of residence, certificate of status and written pledge of all officers
Manager	The premises manager's certificate of residence, written pledge, photograph, etc.

After filing, in addition to the documentary examination, the police carry out an on-site inspection (checking the drawings against the actual state). The standard processing period is said to be roughly 55 days depending on the prefecture, and some commissions count business days excluding weekends and holidays. You cannot operate until the licence is granted. The fee (licence application fee) is set by each prefecture. Some commissions do not accept applications by post or fax, and changing the premises' structure and equipment requires a separate change approval or notification, so always check the form, period and fee in the official guidance of the police station (prefectural public safety commission) with jurisdiction just before applying. Confirming facts about a criminal record or history relating to the grounds for disqualification (Article 4, paragraph 1) 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.

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What operating rules apply, such as admitting minors under 16 and under 18?

Even after the licence is granted, there are rules to observe during operation. The handling of minors' entry differs by age.

Target	Approximate restriction	Basis
Under 18	Not admitted as a customer between 10 p.m. and 6 a.m. the next day	Act Art. 22(1)(v)
Under 16	Not admitted as a customer after sunset (such as after 6 p.m.); ordinances set an exception for accompaniment by a guardian	Prefectural ordinance

That a person under 18 may not be admitted as a customer between 10 p.m. and 6 a.m. the next day is set by Article 22, paragraph 1, item 5 of the Act. The entry of a person under 16 after sunset is restricted by many prefectural ordinances, which set an exception where a guardian accompanies the minor. The amendment in force on 23 June 2016 relaxed the handling of the time an accompanied minor may stay, but the specific times and exceptions differ by prefecture. Check the application of ages and hours, and the restriction on operating hours themselves (set by prefectural ordinance), in the guidance of the police station with jurisdiction. Besides this, there is an obligation to maintain the structural standards during operation too, such as keeping the illumination in the premises from falling to 10 lux or below (Article 14).

Who handles the property, drawings, 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 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, floor plan, lighting drawing), 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 licence, 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. Does any shop with games need a type-5 licence?
A. No. A type-5 business is a shop equipped with 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), that lets customers play games with that equipment (Article 2, paragraph 1, item 5). Depending on the type of equipment and the scale of the shop, it may not fall under type 5. Whether your shop falls under type 5 (whether a licence is needed) should be confirmed with the police station with jurisdiction, showing the equipment and its layout, before deciding on a property.

Q. Isn't a notification enough?
A. No. Type 5 requires a "licence." A late-night alcohol-serving restaurant business (without entertainment) needs only the "notification" under Article 33, paragraph 1, but type 5, which lets customers play games with gaming equipment, is 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. Until what time may children enter?
A. A person under 18 may not be admitted as a customer between 10 p.m. and 6 a.m. the next day (Article 22, paragraph 1, item 5). The entry of a person under 16 after sunset is restricted by many prefectural ordinances, which set an exception for accompaniment by a guardian. Because the specific times and exceptions differ by prefecture, check the guidance of the police station with jurisdiction.

Sources (Primary Information)

• e-Gov Law Search, "Act on Control and Improvement of Amusement Business" (Act No. 122 of 1948), Article 2, paragraph 1, item 5; Article 3, paragraph 1; Article 4, paragraph 1 and paragraph 2, items 1 and 2; Article 14; Article 22, paragraph 1, item 5; Article 33, paragraph 1 (accessed 2026-10-29)
• 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 2026-10-29)
• 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 a type-5 business; 10 lux of illumination) (accessed 2026-10-29)
• Amendment of the Act on Control and Improvement of Amusement Business (Act No. 45 of 2015, in force 23 June 2016; revision of the handling of an accompanied minor's stay) (accessed 2026-10-29)
• Each prefecture's ordinance under the Entertainment Business Act and its ordinance on minors' entry, and the amusement-business licence guidance of the police station (prefectural public safety commission) (restricted areas, structure and equipment, standard processing period, documents, minors' entry hours) (accessed 2026-10-29)
• e-Gov Law Search, "Building Standards Act" (land-use zones) (accessed 2026-10-29)

This article is general information and does not guarantee the outcome of any individual licence, whether the business falls under type 5, 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 scope, distance, illumination and minors' entry hours 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-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.