To sell local (destination) tours, do you need travel-agency registration? Sorting out the types and requirements

In short: if you plan, arrange or sell travel for others, repeatedly and for reward, you generally need registration under the Travel Agency Act (Act No. 239 of 1952), Article 3. Registration is split, by the scope of business, into first-class, second-class, third-class and region-limited; the registration authority is the Commissioner of the Japan Tourism Agency for first-class, and the prefectural governor with jurisdiction over the main office for second-class, third-class and region-limited. Registration requires a base asset amount as a financial foundation, a business deposit (Travel Agency Act, Article 7), and the appointment of at least one travel-service manager per office (Travel Agency Act, Article 11-2). This article is general information organising the types and requirements; eligibility is decided by the review of the Japan Tourism Agency or the prefecture, and our office does not guarantee registration.

Before selling your own tours, do you really need travel-agency registration?

Whether registration is needed depends on "for whom," "what," and whether you do it "repeatedly for reward." A travel agency business means, for reward, arranging travel services such as transport and accommodation, or planning and carrying out travel that combines them, as a business.

Assumed case	Need for registration (guide)
Selling only your own accommodation yourself	Field of the Hotel Business Act. In principle not a travel agency
Combining others' transport, accommodation and experiences and selling them as a planned destination tour	May amount to a travel agency
Arranging transport and accommodation on a traveller's request for reward (arranged travel)	May amount to a travel agency
Selling another travel agency's products as an agent	Separate registration as a travel-agency agent is required

An accommodation operator selling only its own lodging is not a travel agency, but planning and selling a destination tour that combines others' services may amount to one. The permit for accommodation itself is the field of the Hotel Business Act, summarised in The hotel-business permit for a simple lodging. Because the boundary shifts with the content of the product, confirming it for each plan is important in practice.

From first-class to region-limited, what can each do and where do you apply?

The registration types are divided by the scope of travel business handled. The registration authority also differs by type.

Type	Registration authority	Outline of scope
First-class	Commissioner of the Japan Tourism Agency	Travel business generally, including overseas and domestic package (advertised) tours
Second-class	Prefectural governor	Domestic package tours allowed. Overseas package tours not allowed
Third-class	Prefectural governor	Package tours in principle not allowed. However, if the area is limited to the office's municipality, etc., domestic package tours become possible. Order-made package tours and arranged travel have no area limit
Region-limited	Prefectural governor	Domestic package and arranged travel, limited to the area of the office's municipality and adjacent municipalities, etc.

To handle overseas package tours (overseas packages you advertise yourself), first-class is required. Even for inbound destination tours, if the design completes domestic day-trip or nearby tours within the area around the office, you may be able to start with region-limited or third-class. Which type fits depends on the scope of travel handled and the business plan.

The business deposit and the travel-service manager: how much and who is needed?

Registration requires a financial foundation (base asset amount) (Travel Agency Act, Article 6, paragraph 1), and you also deposit a business deposit at the deposit office nearest your main office (Travel Agency Act, Article 7).

Type	Base asset amount	Business deposit (minimum)
First-class	30 million yen	70 million yen
Second-class	7 million yen	11 million yen
Third-class	3 million yen	3 million yen
Region-limited	1 million yen	150,000 yen

The business deposit above is the minimum; it increases with the prior year's travel-business turnover. By joining the Japan Association of Travel Agents or the All Nippon Travel Agents Association and becoming a guarantee member, you may, instead of depositing the business deposit, pay a guarantee-service reserve contribution equal to one-fifth of it.

You must appoint at least one travel-service manager per office and have them carry out the duties (Travel Agency Act, Article 11-2). There are three qualifications—general, domestic and region-limited—and an office handling overseas travel needs a general travel-service manager. Borrowing a name only is not permitted.

How do you separate this from accommodation and transport permits?

Travel agency is registration for the "planning, arrangement and commissioned sale of travel," distinct from the permits for accommodation or transport themselves. A destination tour crosses several laws, so consider separately which act needs which procedure.

What you do	Governing law	Procedure
Planning, arranging and commissioned sale of travel	Travel Agency Act, Article 3	Registration
Accommodation (inn, hotel, simple lodging)	Hotel Business Act	Permit
Accommodation using a home (minpaku)	Housing Accommodation Business Act	Notification (within 180 days of provision a year)
Transporting for reward by your own chartered bus	Road Transportation Act (general chartered passenger car transport)	Permit

Accommodation is a permit under the Hotel Business Act (The hotel-business permit for a simple lodging); minpaku using a home is a notification under the Housing Accommodation Business Act, limited to within 180 days of provision a year. Transporting the tour's movement for reward by your own bus can become a separate permit issue under the Road Transportation Act. Because travel-agency registration does not also cover transport or accommodation permits, organising every needed procedure without omission is important.

Who handles registration, and where do terms and disputes go?

Launching a travel agency crosses several fields of expertise. The roles are divided as follows.

• Preparation of the travel-agency registration application and attached documents, and support for prior consultation with the prefecture and the Japan Tourism Agency → Yotsuba Administrative Scrivener Office (administrative scrivener)
• Selection, lease and important-matters explanation of the business premises (office) → Yotsuba Real Estate Co., Ltd.
• Individual legal judgement on travel-agency terms and consumer contracts, and disputes with travellers → an attorney
• Accounting and tax, and tax handling of the business deposit and transactions → a tax accountant

Yotsuba Administrative Scrivener Office and Yotsuba Real Estate Co., Ltd. are separate businesses. Our office handles only support for the travel-agency registration application as an independent business, and premises, legal and tax matters are contracted or consulted separately with each qualified professional. 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 Japan Tourism Agency or the prefecture.

FAQ

Q. Do I need travel-agency registration just to lodge guests at my own inn?
A. Providing your own inn's accommodation service is the field of the Hotel Business Act and in principle needs no travel-agency registration. However, combining others' transport, accommodation and experiences into a destination tour that you plan, advertise and sell for reward may amount to a travel agency. Because the boundary shifts with the content of the product, confirm it for each plan.

Q. Which type can I start with for an inbound destination tour?
A. It depends on the scope. For domestic day-trip or nearby tours within the area around the office, you may design it with region-limited or third-class; to handle overseas package tours, first-class is required. Because the base asset amount and business deposit also differ by type, choose the type together with the business plan.

Q. Must the business deposit always be deposited in cash?
A. The business deposit can be deposited in national government bonds and the like as well as money. Also, by becoming a guarantee member of the Japan Association of Travel Agents or the All Nippon Travel Agents Association, you may pay a guarantee-service reserve contribution equal to one-fifth of the deposit instead of depositing it (Travel Agency Act, Article 7 and others). Because the amount changes with the prior year's turnover, confirm with the latest figures.

Q. May the travel-service manager be outsourced?
A. You must appoint at least one travel-service manager per office and have them constantly carry out the duties (Travel Agency Act, Article 11-2). Borrowing a name only is not permitted. An office handling overseas travel needs a general travel-service manager, and who can be appointed depends on the office's scope.

Sources (Primary Information)

• e-Gov Law Search, "Travel Agency Act" (Act No. 239 of 1952), Article 3 (registration), Article 6, paragraph 1 (refusal of registration; financial foundation), Article 7 (business deposit), Article 11-2 (travel-service manager) (accessed 2026-09-09)
• e-Gov Law Search, "Order for Enforcement of the Travel Agency Act" (provisions on the base asset amount and the amount of the business deposit) (accessed 2026-09-09)
• Japan Tourism Agency, "Outline of the Travel Agency Act" (registration authority = first-class by the Commissioner of the Japan Tourism Agency, and second-class, third-class and region-limited by the prefectural governor; at least one travel-service manager per office) (accessed 2026-09-09)
• Prefectural guides to new travel-agency registration (second-class, third-class, region-limited): base asset amount = first-class 30 million yen, second-class 7 million yen, third-class 3 million yen, region-limited 1 million yen; minimum business deposit = first-class 70 million yen, second-class 11 million yen, third-class 3 million yen, region-limited 150,000 yen (accessed 2026-09-09)

This article is general information and does not guarantee individual eligibility for registration, the choice of type, or the specific amounts of the base asset amount or business deposit. The business deposit amount changes with the prior year's travel-business turnover, and the above are minimum guides. The final review of registration is made by the Japan Tourism Agency (first-class) or the prefecture (second-class, third-class, region-limited). Selection, lease and important-matters explanation of the business premises are handled by Yotsuba Real Estate Co., Ltd.; individual legal judgement on travel-agency terms and consumer contracts and disputes with travellers by an attorney; and accounting and tax by a tax accountant, each as an independent business under a separate contract or consultation. Our office receives no referral fee. The permit for accommodation itself is the field of the Hotel Business Act; please also see The hotel-business permit for a simple lodging. Individual judgements are made by a qualified professional after a meeting. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.