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Permits and Licensing (From the Practice of an Administrative Scrivener)

A general charter passenger transport business (charter bus): what the requirements are and how you obtain the permit

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浦松 丈二

浦松 丈二

行政書士・宅地建物取引士(四葉行政書士事務所/四葉不動産株式会社)

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To hire out a bus and carry passengers for a fare, you need the permit for a general charter passenger transport business under Article 4, paragraph 1 of the Road Transport Act. This article organises, from the practice of an administrative scrivener, how it differs from white-plate transport, the people/assets/money/safety requirements (operations manager, maintenance manager, office, garage, liability insurance, funds), the flow from application to the start of transport and audit, and who to ask separately for the permit, labor and the garage property.

In short: To carry passengers for a fare by hiring out a bus for sightseeing or transfers to unspecified customers, you need the permit for a general charter passenger transport business under Article 4, paragraph 1 of the Road Transport Act. This is the business defined in Article 3, item 1, sub-item (ro) as "carrying passengers in a vehicle of at least the seating capacity set by ministerial ordinance, hired out as a whole under a single contract," and the seating capacity is set by ministerial ordinance at 11 persons or more. Merely transporting your own officers and employees, or your own customers, free of charge needs no permit; but if you take a fare and carry passengers, a permit is needed. The core of the permit is "people, assets, money, and safety": you assemble an operations manager (Article 23 of the Act; appointed from holders of an operations manager qualification certificate), a maintenance manager (Article 50 of the Road Transport Vehicle Act), an office, a garage, liability capacity (voluntary insurance), and the required funds, while specific criteria such as the number of vehicles are set in the examination standards published by the transport bureau (criteria may be revised, so confirm them in the latest publication of the bureau you apply to). The permit is subject to renewal every five years under Article 8 of the Act. Yotsuba Administrative Scrivener Office prepares and files the permit application, the business plan and the appointment notifications for the operations manager and others, within the scope of Articles 1-2 and 1-3 of the Administrative Scrivener Act, under a separate contract. The design of driver labor matters such as working hours and rest periods is for a labor and social security attorney, the office and garage property for a real estate agent, and the vehicles and insurance for the applicant and the insurer — each contracted separately as an independent business. This article is general information and does not guarantee an individual permit. Our office receives no referral fee.

Why does a charter bus business need a permit, and how does it differ from white-plate transport?

The permit for a general charter passenger transport business is needed, under Article 4, paragraph 1 of the Road Transport Act, when you hire out a bus under a single contract and carry passengers for a fare from unspecified customers. The vehicle concerned is one "of at least the seating capacity set by ministerial ordinance" under Article 3, item 1, sub-item (ro), and the seating capacity is set at 11 persons or more. Hiring out a vehicle with a capacity of 10 or fewer is in the category of general passenger transport by hire (the "hire" category, including jumbo taxis and the like), which is the subject of a different permit.

CategoryTypical exampleNeed for a permit
General charter passenger transport businessCarrying passengers for a fare in a hired-out bus of 11+ capacity for sightseeing or transfersPermit under Article 4, paragraph 1 of the Road Transport Act required
Own transport (white plate)Transferring your own officers and employees, or your own customers, without taking a fareNo permit (but carrying out transport as a business for value becomes subject to a permit)
Paid transport by a private vehicleCarrying out paid transport with a private vehicleIn principle prohibited (Article 78 of the Act; exceptions are limited)

The core of the difference is "paid transport for a fare" and "carrying unspecified customers." Free transfers of your own people need no permit, but once you take consideration beyond actual cost or carry outside customers, it can become an issue as unpermitted paid transport. Which it falls under is judged by the substance of the contract and the consideration, so organise it at the design stage of the transfers. For a business that needs a permit, see the Engagement Flow; for fees, see the Fee Schedule; for the work handled, see Services.

What must you satisfy for the people/assets/money requirements (operations manager, maintenance manager, office, garage, funds)?

The requirements can be organised into "people, assets, money, and safety." Specific criteria such as the number of vehicles and the amounts are set in the examination standards published by the transport bureau you apply to, and may be revised. The main items are as follows (the figures may differ by the bureau's publication, so confirm them in the latest publication immediately before applying).

CategoryMain requirement
Number of vehiclesIn principle 3 or more per operating area. For using large vehicles, 5 or more is required in many publications (3 or more but fewer than 5 generally carries a condition limiting to medium and small vehicles)
Operations managerAppointed per office from holders of an operations manager qualification certificate (Article 23 of the Road Transport Act). The required number rises with the number of vehicles
Maintenance managerAppointed per office (Article 50 of the Road Transport Vehicle Act). The requirement is met by a mechanic qualification, or a certain practical experience plus pre-appointment training
Office and garageThe garage is in principle attached to the office. If it cannot be, within roughly 2 km in a straight line from the office. The office, garage and rest/sleep facility require a right of use of 3 years or more in many publications
Liability capacityA plan for all vehicles to join voluntary insurance (mutual aid) with unlimited bodily-injury cover per victim and property cover of 2 million yen or more per accident
Required fundsEstimating the funds needed to start the business and securing them with own funds; substantiated by a bank balance

The operations manager, under Article 23-2 of the Road Transport Act, is issued the qualification certificate after passing the operations manager examination and so on. These are criteria to be maintained after the permit too: the number of vehicles, the insurance and the appointment of managers must continue to be met after transport begins. The final examination and judgment of whether the requirements are met is made by the transport bureau (the district transport bureau or transport branch office). The design of labor matters such as drivers' working hours and rest periods is organised in the labor and social security attorney's The improvement-standards notice for charter bus drivers (2024 working hours and rest) and labor (the labor and social security attorney is a separate business).

How does the flow proceed from application to permit, start of transport, and audit?

The procedure proceeds in order: fix the business plan and apply, go through the legal examination and review, obtain the permit, and begin transport. After the permit, there is renewal every five years (Article 8 of the Road Transport Act). The rough flow is as follows. The standard processing period and operation differ by bureau, so confirm them in the guidance of the bureau you apply to.

StageContent
Drafting the business planDecide the operating area, office, garage, vehicles and operations manager, and plan the required funds and voluntary insurance
ApplicationSubmit the permit application and the business plan to the transport branch office with jurisdiction over the office (Article 5 of the Road Transport Act)
Legal examinationThe applicant (a full-time officer for a corporation) sits a legal examination on the Road Transport Act and the like
Review and correctionReview of conformity with the requirements; confirmation and correction of facilities, personnel and funds
PermitOnce the permit is granted, pay the registration and license tax
Post-permit proceduresSetting fares and charges (notification), the appointment notifications for the operations and maintenance managers, the safety-management notification, and vehicle registration (green plate), etc.
Start of transportBegin transport and submit the start-of-transport notification (confirm the filing deadline in the bureau's guidance)
Renewal and auditThe permit is renewed every five years (Article 8 of the Road Transport Act). Subject to audit and patrol guidance by the bureau and the compliance body

A permit is not the end once obtained; renewal every five years and continued compliance with operations management, maintenance and labor are the premise. Confirm the specific forms, numbers of copies and standard processing period in the latest guidance of the transport branch office you apply to. What our office does is prepare and file the application documents and organise materials to pass to each professional; we do not make definitive statements on the outcome of the review or a legal outlook.

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Who do you separately ask for the permit application, labor, and the garage property?

Opening a charter bus business divides among professionals — permit, labor, property and vehicles. In the Yotsuba group, the administrative scrivener, the labor and social security attorney, and the real estate business are each an independent business, on the premise that you contract separately. Responsibility divides as follows.

  • Preparing and filing the permit application, the business plan and the appointment notifications for the operations manager and others → an administrative scrivener (Articles 1-2 and 1-3 of the Administrative Scrivener Act; us)
  • The design of drivers' labor — working hours, rest periods, wages, social insurance and work rules → a labor and social security attorney (a separate business)
  • Finding and leasing the office, garage and rest/sleep facility → Yotsuba Real Estate Co., Ltd., a separate business (real estate broker)
  • Procuring and registering vehicles, and designing voluntary insurance → the applicant, the dealer and the insurer
  • The review of conformity and the final judgment on the permit → the district transport bureau or transport branch office
  • A dispute if denied or sanctioned, and an individual legal outlook → a lawyer

Each field is on the premise that you contract separately with each window and qualified person, and our office receives no referral fee. We can receive your consultation at one window and organise and pass materials to each professional, but the engagements are separate. For the flow of engagement, see the Engagement Flow; for fees, the Fee Schedule; for the work handled, Services. Related transport permits are organised for freight in The permit for a general freight transport business (office and garage requirements) and The registration/permit for a freight forwarding business (first and second class), and for passengers in The permit for a nursing-care taxi (welfare transport) and garage requirements.

FAQ

Q. Do I need a permit even just to transfer my own employees or hotel guests by bus?
A. Merely transferring your own officers and employees, or your own customers, by bus without taking a fare in principle needs no permit for a general charter passenger transport business. On the other hand, if you take a fare (consideration beyond actual cost) and carry passengers, or carry outside, unspecified customers, it can become subject to the permit under Article 4, paragraph 1 of the Road Transport Act. Paid transport by a private vehicle without a permit is in principle prohibited (Article 78). Whether the transfers stay within free own transport is judged by the substance of the contract and the consideration, so organise it at the design stage.

Q. How many vehicles does a charter bus permit require?
A. The number of vehicles is set in the examination standards published by the transport bureau you apply to; many publications show, in principle, 3 or more per operating area, and 5 or more when using large vehicles (3 or more but fewer than 5 generally carries a condition limiting to medium and small vehicles). This figure differs by bureau and may be revised, so confirm it in the latest publication of the transport branch office you apply to immediately before applying. Besides vehicles, you must also meet the requirements for the operations manager, the maintenance manager, the office, the garage, voluntary insurance and the required funds.

Q. Once I obtain the permit, can I continue without renewing it?
A. The permit for a general charter passenger transport business, under Article 8 of the Road Transport Act, loses its effect on the passage of time unless renewed every five years. Besides renewal, the appointment of the operations and maintenance managers, joining voluntary insurance, and managing drivers' working hours must continue to be met after transport begins, and are subject to audit and patrol guidance by the bureau and the compliance body. Confirm the renewal timing and the criteria to be maintained in the guidance of the transport bureau you apply to.

Q. Can I ask one office to handle everything from the permit application to drivers' labor and the garage property?
A. The preparation of the permit application, the business plan and the appointment notifications is for an administrative scrivener; working hours, rest periods, wages and social insurance for a labor and social security attorney; the office and garage property for Yotsuba Real Estate Co., Ltd., a separate business; vehicles and insurance for the applicant and the insurer; the final judgment on the permit for the transport bureau; and a dispute over a sanction for a lawyer — each contracted separately as an independent business. We can receive your consultation at one window and organise and pass materials to each professional, but the engagements are separate. Our office receives no referral fee.

Sources (Primary Information)

  • e-Gov Law Search, "Road Transport Act," Article 3, item 1, sub-item (ro) (general charter passenger transport business = a general passenger transport business carrying passengers in a vehicle of at least the seating capacity set by ministerial ordinance, hired out as a whole under a single contract), Article 4, paragraph 1 (permit for a general passenger transport business), Article 5, paragraph 1 (contents of the permit application = name/title/address, business category, and a business plan including the operating area, the office names and locations and the number of vehicles per office), Article 8 (the permit for a general charter passenger transport business loses its effect unless renewed every five years), Article 23 (appointment per office of an operations manager from holders of an operations manager qualification certificate), Article 23-2 (the operations manager qualification certificate = issued to those who pass the operations manager examination, etc.), Article 78 (paid transport by a private vehicle in principle prohibited) (accessed 2026-11-06)
  • e-Gov Law Search, "Road Transport Vehicle Act," Article 50 (appointment of a maintenance manager) (accessed 2026-11-06)
  • The "examination standards for permit applications and business-plan-change approval applications, etc., for a general charter passenger transport business" published by the Ministry of Land, Infrastructure, Transport and Tourism (district transport bureaus) (number of vehicles = in principle 3 or more per operating area, 5 or more for large vehicles, with a condition limiting 3-to-under-5 to medium and small vehicles; appointment of operations and maintenance managers; the garage within roughly 2 km in a straight line from the office; a right of use of 3 years or more for the office, garage and rest/sleep facility; liability capacity = voluntary insurance with unlimited bodily-injury cover and property cover of 2 million yen or more per accident; securing the required funds with own funds. The criteria are published per bureau and may be revised; confirm in the publications of the Kanto, Tohoku and other transport bureaus) (accessed 2026-11-06)
  • The standards for improving working hours, etc., of drivers of motor vehicles (the improvement-standards notice, as applied from 1 April 2024; working hours and rest periods, etc. = the design of driver labor is the field of a labor and social security attorney) (accessed 2026-11-06)

This article is general information and does not guarantee or judge whether an individual permit will be granted, the number of vehicles, funds or documents needed, or the outcome of a review. Because specific criteria such as the number of vehicles, insurance and funds differ by the transport bureau's publication and may be revised, confirm them in the latest publication and guidance of the transport branch office you apply to immediately before applying. The preparation and filing of the permit application, the business plan and the appointment notifications is for an administrative scrivener (us); drivers' labor — working hours, rest periods, wages and social insurance — for a labor and social security attorney; the review of conformity and the final judgment on the permit for the district transport bureau or transport branch office; and a dispute over a sanction for a lawyer — each contracted separately as an independent business. The office and garage property is handled by Yotsuba Real Estate Co., Ltd., a separate business, and our office receives no referral fee. A specific legal judgment is made, after an interview, by a qualified person such as an administrative scrivener. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.

Let's start by sorting out your situation.

Yotsuba Gyoseishoshi Office (Kohinata, Bunkyo-ku; a 5-minute walk from Myogadani Station on the Tokyo Metro Marunouchi Line) supports you from organizing the requirements through document preparation and application.

LINE connects you directly to our representative, Joji Uramatsu. Messages are accepted 24/7 and answered in order.

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