A simple lodging (kan'i shukusho) hotel-business permit: what conditions and what flow?

In short: to run a bare-stay guesthouse in a detached house or vacant building, you need a hotel-business permit under the Hotel Business Act. You obtain a permit as a simple-lodging (kan'i shukusho) operation from the prefectural governor (in cities and special wards with a public health centre, the mayor or ward head) (Hotel Business Act, Article 3, paragraph 1). The floor area of guest rooms, toilets, washbasins and other structural facilities have standards in the Order for Enforcement of the Hotel Business Act, Article 1, paragraph 2, and conformity with the use zone and change of use (Building Standards Act) and the fire laws is a prerequisite. Having no annual operating-day cap is a major difference from housing-accommodation-business "minpaku" (a notification system with a 180-day annual cap). This article organises the conditions and flow; eligibility is decided by the public health centre's review, and our office does not guarantee a permit.

What differs between a simple-lodging permit and a minpaku notification?

Even for the same "business of putting people up," the governing laws differ. Simple lodging is a "permit" under the Hotel Business Act; so-called minpaku is a "notification" under the Housing Accommodation Business Act, and the requirements and treatment of days differ.

	Simple-lodging operation	Housing accommodation business (minpaku)
Governing law	Hotel Business Act, Article 3, paragraph 1	Housing Accommodation Business Act (effective 15 June 2018)
Procedure	Permit	Notification
Operating days	No cap	Within 180 days a year
Structural facilities	Standards under Order Article 1, paragraph 2	Basically housing facilities

Minpaku under the Housing Accommodation Business Act is a notification system, with the annual days of accommodation provided limited to within 180 days. In contrast, a simple-lodging operation is a permit system: there is no cap on days, but requirements of structural-facility standards and conformity with the use zone and fire laws apply. To run lodging continuously through the year, the simple-lodging permit; to use a home within the day limit, the minpaku notification—that is the basic choice. The requirements for the minpaku notification are summarised in Housing accommodation business notification.

Simple lodging structural-facility standards (guest rooms, toilets, washbasins): how far are they required?

The structural-facility standards for a simple-lodging operation are set in the Order for Enforcement of the Hotel Business Act, Article 1, paragraph 2. Typical items are as follows. Prefectural and other ordinances may set additional standards on top of these.

Item	Outline of the standard
Total floor area of guest rooms	33㎡ or more. However, if the number of guests is set below 10, an area of 3.3㎡ multiplied by the number of guests or more
Tiered beds (bunk beds, etc.)	Roughly 1 m or more between the upper and lower berths
Ventilation, lighting, illumination, damp-proofing, drainage	Suitable equipment
Bathing facilities	A scale meeting guests' demand, except where a public bath, etc. is nearby
Washbasin facilities	A suitable scale meeting guests' demand
Toilets	A suitable number

Because simple lodging is an operation type that assumes shared rooms (dormitories), unlike hotel and inn operations, the standard is set by the total floor area of the guest rooms rather than the area per room. A front desk (genkan-chōba) is not uniformly required for simple lodging, but a system for keeping a guest register and confirming identity is needed in operation. Confirm the specific figures and layout with the public health centre's guide and a prior consultation.

Do the use zone and change of use of an existing building become issues?

A hotel business (hotel/inn) is restricted by use zone under the Building Standards Act, Appended Table 2. In category I and II low-rise exclusive residential zones, agricultural-residential zones, exclusive industrial zones and the like, it cannot in principle be built; whether it is allowed differs by zone. First confirm which use zone the intended location is in, with the specified administrative agency (the counter overseeing building).

When converting an existing building into a lodging facility, watch out for change of use. A hotel or inn is a special building under the Building Standards Act, and when you carry out a change of use so that the total floor area of the part used for that purpose exceeds 200㎡, a confirmation application is required (Building Standards Act, Article 87, paragraph 1; the amendment easing the threshold requiring confirmation from over 100㎡ to over 200㎡ took effect on 25 June 2019). Whether the use zone allows it, whether change of use is needed, and the handling of existing non-conforming buildings are the field of an architect and the specified administrative agency. Confirming the prospects for the use zone and change of use before signing the premises contract is important in practice.

Why is a fire-law conformity notice necessary?

For a hotel-business permit application, you are generally asked to attach a "fire-law conformity notice" showing conformity with the fire laws. This notice is issued when the fire station with jurisdiction over the facility carries out an on-site inspection and finds it conforms to the fire laws. Because lodging facilities are a use where unspecified people sleep, the standards for installing fire-fighting equipment (Fire Service Act) are stricter than for housing, and automatic fire alarms, guidance lights, extinguishers and the like may be required.

The necessary fire-fighting equipment varies with the building's scale, structure and capacity. Because the public health centre's permit review and the fire station's conformity check proceed at different counters, operation cannot start with only one of them in place. Consulting the fire station in advance and estimating the necessary equipment and works before deciding the interior and layout of the premises is important to avoid rework.

Who should you consult about building, fire and premises?

A simple-lodging permit crosses several fields of expertise. The roles are divided as follows.

• Preparation of the hotel-business (simple-lodging) application and attached documents, and support for prior consultation with the public health centre → Yotsuba Administrative Scrivener Office (administrative scrivener)
• Selection, lease and important-matters explanation of the business premises → Yotsuba Real Estate Co., Ltd.
• Building use, confirmation application, change of use, and checking the certificate of inspection → an architect and the specified administrative agency
• Design and works of fire-fighting equipment and application for the fire-law conformity notice → a fire-equipment engineer and the fire authority
• Accounting and tax of the building and business → a tax accountant
• Individual legal judgement on rights, obligations and disputes → an attorney

Yotsuba Administrative Scrivener Office and Yotsuba Real Estate Co., Ltd. are separate businesses. Our office handles only support for the hotel-business permit application as an independent business, and premises, building, fire and tax are contracted or consulted separately with each qualified professional and administrative counter. Our office receives no referral fee. For the whole picture of licensing, see Licensing and Permits; for the flow of engagement, see Engagement Flow; and for fees, see Fee Schedule. Eligibility itself is decided by the public health centre.

FAQ

Q. Which is more advantageous, simple lodging or minpaku?
A. It cannot be said in general. Simple lodging (Hotel Business Act, Article 3, paragraph 1) is a permit system with no cap on operating days, but requirements of structural facilities, use zone and fire laws apply. Minpaku (Housing Accommodation Business Act) is a notification system that is easier to start, but has a limit of within 180 days a year. Choose based on whether you want to operate continuously or within a day limit.

Q. Must guest rooms always be 33㎡ or more?
A. If the number of guests is set below 10, an area of 3.3㎡ multiplied by the number of guests or more is acceptable (Order for Enforcement of the Hotel Business Act, Article 1, paragraph 2). For a facility with up to 4 guests, for example, 3.3㎡ × 4 = 13.2㎡ or more is a guide for the total floor area of guest rooms. Because ordinances may add standards, confirm with the public health centre.

Q. Can you open simple lodging in a detached house in a residential area?
A. It depends on the use zone. A hotel or inn is restricted by use zone under Building Standards Act, Appended Table 2, and cannot in principle operate in category I and II low-rise exclusive residential zones and the like. First confirm the use zone of that location with the specified administrative agency. Confirmation before signing the premises contract is important.

Q. When should you obtain the fire-law conformity notice?
A. Because it is generally required as an attached document for the hotel-business permit application, apply to the fire station for issuance before the permit application, and receive it after an on-site inspection. Because works for the necessary fire-fighting equipment may be involved, consulting the fire station before interior works helps avoid rework.

Sources (Primary Information)

• e-Gov Law Search, "Hotel Business Act" (Act No. 138 of 1948), Article 3, paragraph 1 (accessed 2026-09-03)
• e-Gov Law Search, "Order for Enforcement of the Hotel Business Act" (Cabinet Order No. 152 of 1957), Article 1, paragraph 2 (structural-facility standards for simple-lodging operations) (accessed 2026-09-03)
• e-Gov Law Search, "Housing Accommodation Business Act" (Act No. 65 of 2017; effective 15 June 2018), Article 2, paragraph 3 (within 180 days of provision a year) (accessed 2026-09-03)
• e-Gov Law Search, "Building Standards Act" (Act No. 201 of 1950), Article 87, paragraph 1, and Appended Table 2 (accessed 2026-09-03)
• Guides to hotel-business (simple-lodging) permit applications published by the public health centre of the planned site (each municipality; accessed 2026-09-03)

This article is general information and does not guarantee individual eligibility for a permit or conformity with the structural-facility standards, use zone, change of use or fire laws. The final review of the hotel-business permit is made by the public health centre (prefecture, city with a public health centre, or special ward). Judgements on the use zone, change of use and existing non-conformity are made by the specified administrative agency and an architect, and the need for fire-fighting equipment by the fire authority and a fire-equipment engineer. Confirm the standards, forms and required documents for each facility on the relevant municipality's official page. Selection, lease and important-matters explanation of the business premises are handled by Yotsuba Real Estate Co., Ltd.; building confirmation and change of use by an architect and the specified administrative agency; design and works of fire-fighting equipment by a fire-equipment engineer and the fire authority; accounting and tax by a tax accountant; and individual legal judgement on rights, obligations and disputes by an attorney, each as an independent business under a separate contract or consultation. 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.