Requirements and flow of development permission (Article 29 of the City Planning Act): before you build in an urbanization control area

In short: when you carry out "development activity" that changes the shape or character (block or form) of land in order to build a building of a certain scale or larger, in principle you need development permission from the prefectural governor and others (Article 29, paragraph 1 of the City Planning Act). To obtain permission you must satisfy the technical standards that apply in all areas (Article 33 of the same Act), and in an urbanization control area you must, in addition, fall under one of the location standards (Article 34 of the same Act). Once the work is finished you undergo an inspection, and you may build a building only after the notice of completion of the work is given (Articles 36 and 37 of the same Act). This article is general information organising the requirements and flow of development permission; it does not make any individual legal judgement such as whether a particular permission will be granted or how the permission standards apply.

When is development permission (Article 29 of the City Planning Act) required?

The object of development permission is "development activity." Development activity means a change to the block or form of land carried out mainly for the purpose of building a building or constructing a specified structure (Article 4, paragraph 12 of the City Planning Act). Specified structures include first-class specified structures such as concrete plants that may worsen the surrounding environment, and second-class specified structures such as golf courses and exercise or leisure facilities of a certain scale or larger (paragraph 11 of the same Article). A mere rebuild of a building, or land use that does not involve any change to the block or form of the land, is not development activity.

Whether permission is required depends on the area in which the land is located and the scale of the development activity. The rough scale by area is as follows (Article 19 of the Order for Enforcement of the City Planning Act).

Area	Rough scale that requires development permission
Urbanization promotion area	1,000 square metres or more (a bylaw may lower the minimum to 300 square metres)
Certain areas of the existing urban areas and suburban development zones of the three major metropolitan areas	500 square metres or more
City planning areas without an area classification (non-line-drawn) and quasi-city planning areas	3,000 square metres or more
Outside city planning areas and quasi-city planning areas	1 hectare (10,000 square metres) or more
Urbanization control area	In principle required regardless of scale

The permitting authority is the prefectural governor, but in designated cities, core cities and the like, the head of that city holds the authority. Certain buildings used for agriculture, forestry or fisheries, some buildings that are necessary for public interest such as station buildings, libraries and substations, and development activity carried out as a city planning project or land readjustment project may be exempt so that permission is not required (each item of Article 29, paragraph 1 of the City Planning Act). Because which scale, area or exemption applies is operated differently by each municipality, please confirm at the counter of the municipality where you plan to build before you proceed.

What kinds of development can be built in an urbanization control area (Article 34)?

An urbanization control area is an area where urbanization should be restrained. To obtain development permission here, in addition to the technical standards (Article 33) you must fall under one of the items of the location standards (Article 34 of the City Planning Act). The main items are as follows.

Item	Examples of development activity covered
Item 1	Stores, etc. for the sale, processing or repair of goods necessary for the daily life of those residing around the development area
Item 9	Rest areas, service stations, etc. placed in appropriate positions to ensure smooth road traffic
Item 10	Development activity within a district plan or settlement district plan area that conforms to the plan
Item 11	Development activity within an area designated by bylaw as adjacent or close to an urbanization promotion area with roughly 50 or more buildings clustered together
Item 12	Development that, as something that does not risk promoting urbanization and is difficult or unsuitable to carry out within an urbanization promotion area, is defined by bylaw limiting the area, purpose or use
Item 14	Development that, through the deliberation of the development review board, is found not to risk promoting urbanization and difficult or unsuitable to carry out within an urbanization promotion area

Which item may apply differs greatly by municipality according to the scope of bylaw-designated areas and the review standards. Because Items 11 and 12 have areas and uses defined by bylaw, you need to confirm in advance, in the municipality's development permission standards and review guidelines, whether the target land falls within that area and whether the intended use of the building is permitted. Where no item can apply, it may not be possible to build in the urbanization control area.

What does satisfying the technical standards (Article 33) mean?

The technical standards (Article 33 of the City Planning Act) apply in common to all development activity, whether in an urbanization promotion area or an urbanization control area. The main items are as follows.

• The use of the planned building, etc. conforms to the use district, district plan, etc.
• Public open spaces such as roads, parks and squares are appropriately arranged according to the scale and shape of the development area
• Drainage facilities are provided with a structure and capacity that can appropriately treat sewage, rainwater and the like
• Water supply and other supply facilities are provided with a structure and capacity that do not hinder demand
• Measures to prevent disasters such as landslides and flooding are taken
• The consent of the administrator of public facilities within the development area is obtained, and consultation has been held with the party who will administer newly established public facilities (Article 32 of the same Act)
• The applicant has the resources and credit necessary to complete the development activity

These are technical and quantitative standards, and matters such as road width and drainage plans are set out in detail in the municipality's review guidelines. The design and drawings are usually prepared with the involvement of professionals such as architects, surveyors and civil engineering designers.

What is the flow and period from application to notice of completion?

The general flow of development permission is as follows.

Have a question about your situation?

Tell us about your residency, permit or administrative procedure enquiry.

Chat on LINEContact us

Stage	Content	Basis / notes
(1) Preliminary consultation	Confirm area classification, scale and applicability of location standards at the municipal counter	Depends on municipal operation
(2) Consent / consultation with public facility administrators	Consent of road and waterway administrators; consultation with the administrator of new public facilities	Article 32 of the City Planning Act
(3) Application	Apply with design documents and the consent of a substantial number of relevant right-holders	Article 30 of the City Planning Act
(4) Review and disposition	Review of technical standards and (in a control area) location standards; permission or refusal	Article 35 of the City Planning Act (disposition and notice without delay)
(5) Work	Carry out grading and other work in accordance with the permission	Changes require a change permission, etc.
(6) Notice of completion / inspection	Notify completion of the work; obtain a certificate of inspection after inspection	Article 36, paragraphs 1 and 2 of the City Planning Act
(7) Notice of completion of work	The governor, etc. gives notice of completion of the work	Article 36, paragraph 3 of the City Planning Act
(8) Building	The planned building may be built after the notice	Article 37 of the City Planning Act (in principle no building before the notice)

The standard period required for review is set by each municipality, and including preliminary consultation it may extend over several months, but no uniform number of days is given here (please confirm with the standard processing period of the municipality for the target land). In principle you cannot build or reconstruct a building before the notice of completion of the work (Article 37 of the City Planning Act). After the notice of completion, building any building other than the permitted planned building, etc. is restricted (Article 42 of the same Act).

Who should handle registration, surveying, tax and disputes?

Among the application forms and attached documents for development permission, the preparation and submission by proxy of application documents to administrative agencies can be supported within the scope of administrative-scrivener work. On the other hand, some of the procedures accompanying development are handled by qualified professionals other than an administrative scrivener.

• Where farmland is converted to residential or other land, permission or notification for farmland conversion is a procedure separate from development permission (see The flow of farmland conversion permission (Articles 4 and 5 of the Farmland Act)).
• Registration of description such as surveying, subdivision and change of land category is the work of a land and house surveyor.
• Registration of rights such as transfer of ownership and creation of a mortgage is the work of a judicial scrivener (where inheritance is involved, see also The flow of inheritance registration).
• Judgements on the income, expenditure and tax of the business plan are the work of a certified public tax accountant.
• Representation in disputes such as a request for administrative review or a revocation suit against a refusal of development permission is the work of a lawyer.

四葉行政書士事務所 is a separate business from 四葉不動産株式会社. The preparation of the development permission application documents is handled by an administrative scrivener; surveying, subdivision and change of land category by a land and house surveyor; registration of rights by a judicial scrivener; the tax of the business plan by a certified public tax accountant; and administrative appeals and disputes concerning city planning by a lawyer, each as an independent business under a separate contract. Our office receives no referral fee. For consultations on buying, selling and using property, go to The window for inheriting and selling real estate. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for our services, see Our Services.

FAQ

Q. Can you not build anything in an urbanization control area?
A. It is an area where urbanization should be restrained, but it is not that you cannot build at all. If, in addition to the technical standards (Article 33 of the City Planning Act), you fall under one of the location standards (Article 34 of the same Act), you may be able to build with development permission. However, whether an applicable item exists depends on the target land, the intended use and the municipality's bylaws and review standards, so please confirm individual eligibility with the municipal counter and a qualified professional.

Q. Is development permission unnecessary for a rebuild?
A. A mere rebuild that does not involve any change to the block or form of the land is not development activity in the first place (Article 4, paragraph 12 of the City Planning Act), and development permission is often unnecessary. However, the treatment changes depending on whether grading or a change of block is involved and whether the land is in an urbanization control area. Because the judgement starts from whether it amounts to development activity, please confirm with the municipality.

Q. Can I ask an administrative scrivener to prepare the development permission application documents?
A. The preparation and submission by proxy of application documents for permits and licences to administrative agencies can be supported within the scope of administrative-scrivener work. However, design documents are handled by an architect and others, surveying, subdivision and change of land category by a land and house surveyor, and registration of rights by a judicial scrivener, each contracting with you separately as an independent business.

Q. Once the work is finished, can I build immediately?
A. No. After you notify completion of the work, you undergo an inspection, obtain a certificate of inspection, and then the notice of completion of the work is given (Article 36 of the City Planning Act). Building the planned building can, in principle, be done after this notice of completion (Article 37 of the same Act). Building before the notice is, in principle, not permitted.

Sources (Primary Information)

• e-Gov Law Search, "City Planning Act" (Act No. 100 of 1968), Articles 4, 29, 32, 33, 34, 35, 36, 37 and 42 (accessed 2026-09-13)
• e-Gov Law Search, "Order for Enforcement of the City Planning Act" (Cabinet Order No. 158 of 1969), Article 19 and others (the scale of development activity not requiring development permission) (accessed 2026-09-13)
• Ministry of Land, Infrastructure, Transport and Tourism, "Guidelines for the Operation of the Development Permission System" (accessed 2026-09-13)
• The development permission standards and review guidelines of the municipality where you plan to build (each municipality's guidance, accessed 2026-09-13)

This article is general information and does not guarantee whether a particular development permission is required or will be granted, the applicability of the location standards, or the standard processing period. The preparation of development permission application documents is handled by an administrative scrivener; surveying, subdivision and change of land category by a land and house surveyor; registration of rights by a judicial scrivener; the tax of the business plan by a certified public tax accountant; and administrative appeals and disputes concerning city planning by a lawyer, each as an independent business under a separate contract. Our office receives no referral fee. Individual judgements are made by a qualified professional after a meeting. Written by Joji Uramatsu, Representative Certified Administrative Procedures Legal Specialist, 四葉行政書士事務所; Representative Director, 四葉不動産株式会社.