Opening a clinic: the notification under Medical Care Act Article 8, and how it differs from a hospital's licence

A clinic with no beds or 19 beds or fewer can start with a notification, not a licence. This article organises who files what, by when and where under Medical Care Act Article 8, how it differs from the hospital licence (Article 7), the insurance-medical-institution designation for insured care, and how the roles divide among the administrative scrivener, real estate, tax accountant and labour and social security attorney.

In short: a clinic with no beds or 19 beds or fewer can, unlike a hospital, start not by a "licence" but by a "notification." Where a physician who has completed clinical training (or a dentist who has completed clinical training) opens a clinic, they must notify the prefectural governor of the location of the clinic (or the mayor of a public-health-centre city or the head of a special ward) within 10 days after opening (Medical Care Act Article 8, paragraph 1). By contrast, a hospital, a clinic opened by a non-physician, and a clinic with beds require the prefectural governor's licence before opening (Medical Care Act Article 7). Hospitals and clinics are divided by the number of inpatient beds: a facility for 20 or more inpatients is a hospital, and 19 or fewer, or none, is a clinic (Medical Care Act Article 1-5). To start insured care, you need, separately from the opening notification, the designation as an insurance medical institution (Health Insurance Act Article 65, paragraph 1). Preparing and filing the opening notification, the designation application, the medical-corporation establishment approval and the like is handled by our office (Yotsuba Administrative Scrivener Office); the choice and lease of premises are by Yotsuba Real Estate Co., Ltd., a separate business; the tax and accounting tied to opening finance are by a tax accountant; and staff employment contracts, work rules and the new application of social insurance are by Yotsuba Labour and Social Security Attorney Office, each responding separately as an independent business. This article is general information organising the flow of the system, and any individual propriety or form depends on the review of the local authority of the location.

Why is a clinic allowed to start with a "notification" rather than a "licence"?

The Medical Care Act varies the opening hurdle by the character of the facility. Where a physician who has completed clinical training (or a dentist who has completed clinical training) opens, by themselves, a clinic with no inpatient beds, a post-opening notification suffices rather than a prior licence (Medical Care Act Article 8, paragraph 1). This is because the physician's qualification and completion of clinical training are considered to secure the quality of the facility to a certain degree.

By contrast, any of the following requires the licence of the prefectural governor (or the mayor of a public-health-centre city or the head of a special ward) before opening (Medical Care Act Article 7). First, opening a hospital. Second, opening a clinic by a person who is not a physician or dentist (such as a medical corporation or a local government). Third, placing beds (inpatient beds) at a clinic, or changing the number or type of beds (Medical Care Act Article 7, paragraph 3). In short, the case of an individual physician opening a bedless clinic is the typical one that requires only the lightest procedure, the "notification."

Facility / opener	Procedure	Basis
Individual physician, no beds	Notification within 10 days after opening	Medical Care Act Article 8, paragraph 1
Hospital (facility for 20 or more inpatients)	Licence before opening	Medical Care Act Article 7, paragraph 1
Clinic opened by a non-physician (medical corporation, etc.)	Licence before opening	Medical Care Act Article 7, paragraph 1
Placing or changing beds at a clinic	Prior licence	Medical Care Act Article 7, paragraph 3

A "licence" is a scheme where the administration reviews propriety in advance before you may open; a "notification" is a scheme where you may open once the requirements are met and you notify that fact. This difference directly affects the period and weight of preparation until opening.

What draws the line between a hospital and a clinic?

Medical Care Act Article 1-5 divides them by the number of inpatient beds. Among places where a physician or dentist practises medicine, one having a facility to admit 20 or more inpatients is a "hospital," and one having no inpatient facility, or a facility to admit 19 or fewer inpatients, is a "clinic." Both a clinic with 19 or fewer beds and a clinic with no inpatient facility at all are included in "clinic."

Category	Inpatient beds	Opening procedure	Basis
Hospital	20 or more	Licence before opening	Medical Care Act Article 1-5, paragraph 1 / Article 7
Clinic with beds	19 or fewer	Bed placement by licence; opening by notification (for an individual physician)	Medical Care Act Article 1-5, paragraph 2 / Article 7, paragraph 3 / Article 8
Clinic without beds	None	Notification within 10 days after opening (for an individual physician)	Medical Care Act Article 1-5, paragraph 2 / Article 8

Even when opening as a bedless clinic, placing beds later requires a separate licence at that time (Medical Care Act Article 7, paragraph 3). Whether to anticipate future inpatient facilities also bears on the review of the premises' floor area and structure, so organising it from the premises-selection stage reduces reworking. The view on selecting and leasing premises is the domain of Yotsuba Real Estate Co., Ltd., a separate business.

By when, where and what do you file for the opening notification?

Medical Care Act Article 8, paragraph 1 sets the deadline as "within 10 days after opening." The place of filing is the prefectural governor of the clinic's location. However, where that location is within a public-health-centre city or a special ward, in practice it is filed with that mayor or ward head (i.e., the public health centre). The window is commonly the public health centre.

Attached documents follow forms set by each authority, but generally the following are required: a copy of the opener's and manager's physician licences, a copy of the manager's clinical-training completion registration certificate, a floor plan of the site and building and a location map of the surroundings, the medical departments, the number of physicians and nurses and others engaged in the work, and a notification on diagnostic radiation such as an X-ray apparatus (where installed). Confirm the specific form, number of copies and attached documents on the official page of the public health centre of the location just before applying (this article does not assert the form of any particular authority).

Item	Content
Deadline	Within 10 days after opening (Medical Care Act Article 8, paragraph 1)
Filed with	The prefectural governor of the clinic's location (in a public-health-centre city or special ward, the mayor or ward head, i.e., the public-health-centre window)
Main attachments	Copy of physician licence, copy of clinical-training completion registration certificate, floor plan and location map, number of workers, radiation-related notification (when installed)
Confirming the form	Confirm the official page of the location's public health centre just before applying

Preparing and filing the clinic opening notification and these attachments can be handled by our office (Yotsuba Administrative Scrivener Office) as the preparation of documents submitted to public agencies. The opener may also file it themselves.

Besides the opening notification, what do you need to start insured care?

The opening notification is a notification under the Medical Care Act only. To provide insured care using health insurance or national health insurance, you separately need the "designation as an insurance medical institution." The designation is made by the Minister of Health, Labour and Welfare (Health Insurance Act Article 65, paragraph 1), and the application window is the Regional Bureau of Health and Welfare (prefectural office) that has jurisdiction over the clinic's location. The designation has a cycle of application deadlines and effective dates, so the opening date and the start date of insured care can differ.

Therefore, it is important to back-calculate by aligning the schedule of interior work, staffing and the opening notification with the timing of the insurance-medical-institution designation application. Missing the designation application timing can push the start of insured care to the following month or later, even though you can open.

Procedure	Basis / where filed	Purpose
Clinic opening notification	Medical Care Act Article 8, paragraph 1 / public health centre	To lawfully open a clinic under the Medical Care Act
Insurance-medical-institution designation application	Health Insurance Act Article 65, paragraph 1 / Regional Bureau of Health and Welfare	To be able to provide insured care (health insurance and national health insurance)
Designation under the Public Assistance Act, workers' accident insurance, etc.	Each system's governing law / competent authority	Needed where handling public funds or workers' accident cases

Preparing and filing the insurance-medical-institution designation application and its attachments can also be handled by our office. The claim practice for medical fees and the part of the facility-standard notifications that involves tax and accounting are the domain of a tax accountant. Our office does not give tax advice.

How does opening as an individual physician differ from opening as a medical corporation?

Where an individual physician opens, the entry point is the notification within 10 days after opening seen above (Medical Care Act Article 8, paragraph 1). By contrast, where you set up a medical corporation and open a clinic as the corporation, you must first obtain approval for the establishment of the medical corporation. A medical corporation cannot be established without the approval of the prefectural governor of the location of its principal office (Medical Care Act Article 44, paragraph 1). The approval often has set acceptance periods per prefecture (a few times a year), and because you go through corporation establishment, registration and the clinic opening licence (Medical Care Act Article 7) in order, the preparation period is longer than for an individual opening.

Category	Entry-point procedure	Feature
Opening as an individual physician	Notification within 10 days after opening (Medical Care Act Article 8, paragraph 1)	Relatively light procedure. You can start with the notification first
Opening as a medical corporation	Establishment approval (Medical Care Act Article 44, paragraph 1) → establishment registration → opening licence (Medical Care Act Article 7)	Aligned to the approval acceptance period. Longer preparation

Preparing and filing the medical-corporation establishment approval application, articles of incorporation, business plan and the like can be handled by our office. The establishment registration itself is the domain of a judicial scrivener, and the corporation's tax and accounting of a tax accountant. Our office does not represent registration applications, prepare registration applications, or give tax advice.

Who do you ask for premises, notification, tax and labour matters?

Opening a clinic spans several fields of expertise. The roles are as follows.

Preparing and filing the clinic opening notification, the insurance-medical-institution designation application, the medical-corporation establishment approval application and the like → Yotsuba Administrative Scrivener Office (administrative scrivener)
Selecting premises, brokering the lease, and the view on use and structure → Yotsuba Real Estate Co., Ltd. (real estate broker)
Registration of the medical corporation's establishment, and real-property registration → judicial scrivener
Tax and accounting tied to opening finance, estimating social insurance premiums, and accounting related to medical fees → tax accountant
Staff employment contracts, work rules and the new application of social insurance → Yotsuba Labour and Social Security Attorney Office (labour and social security attorney)

Yotsuba Real Estate Co., Ltd., a separate business from Yotsuba Administrative Scrivener Office, handles the selection of premises, the brokerage of the lease, and the view on use and structure, under a separate contract as an independent business. The registration of the medical corporation's establishment is by a judicial scrivener, the tax and accounting and the estimation of social insurance premiums by a tax accountant, and the employment contracts, work rules and new application of social insurance by Yotsuba Labour and Social Security Attorney Office; the roles divide. Each field is on the premise that you contract separately with each qualified professional and office as an independent business, and our office receives no referral fee. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; for the overall picture of the work, see Licensing and Application Services.

FAQ

Q. For a bedless clinic, is no licence needed from the authorities before opening?
A. Where an individual physician opens a clinic with no inpatient beds, a notification within 10 days after opening suffices rather than a prior licence (Medical Care Act Article 8, paragraph 1). However, where you place beds, where a non-physician such as a medical corporation opens, or where you open a hospital, the prefectural governor's licence is required before opening (Medical Care Act Article 7). The entry point is confirming which type your own facility falls under.

Q. Once I file the opening notification, can I start insured care right away?
A. The opening notification is a notification under the Medical Care Act and is separate from whether you may provide insured care. Insured care using health insurance or national health insurance separately requires the insurance-medical-institution designation (Health Insurance Act Article 65, paragraph 1), whose application window is the Regional Bureau of Health and Welfare. The designation has a cycle of deadlines and effective dates, so the opening date and the start of insured care can differ. Back-calculating by aligning the timing of the opening notification and the designation application is safe.

Q. Is the opening notification filed with the prefecture or the public health centre?
A. Medical Care Act Article 8, paragraph 1 sets the notification to "the prefectural governor of the clinic's location." That said, where the location is in a public-health-centre city or a special ward, in practice the mayor or ward head (the public health centre) is the window. The form, attachments and number of copies differ by authority, so confirm the official page of the location's public health centre just before applying.

Q. How do the procedures increase with a medical corporation?
A. Opening as a medical corporation goes through the establishment approval by the prefectural governor of the location of the principal office (Medical Care Act Article 44, paragraph 1), then the establishment registration, and then the clinic opening licence as the corporation (Medical Care Act Article 7). The approval acceptance period is often limited to a few times a year, so the preparation period is longer than for an individual opening. The approval application documents are by an administrative scrivener, the establishment registration by a judicial scrivener, and the tax by a tax accountant, each responding separately as an independent business.

Sources (Primary Information)

e-Gov Law Search, "Medical Care Act" (Act No. 205 of 1948), Article 1-5 (definitions of hospital and clinic), Article 7 (licence for opening), Article 8, paragraph 1 (notification of a clinic opening by a physician who has completed clinical training, etc. = within 10 days after opening), Article 44, paragraph 1 (approval for the establishment of a medical corporation) (accessed 2026-09-02)
e-Gov Law Search, "Health Insurance Act" (Act No. 70 of 1922), Article 65, paragraph 1 (designation as an insurance medical institution = the Minister of Health, Labour and Welfare; the application window is the Regional Bureau of Health and Welfare) (accessed 2026-09-02)
Ministry of Health, Labour and Welfare, "Designation application for insurance medical institutions and insurance pharmacies," and each Regional Bureau of Health and Welfare's guidance on acceptance and effective dates of designation applications (accessed 2026-09-02)
Guidance on the "clinic opening notification" form, attachments and filing deadline of each prefecture, public-health-centre city and special ward (public health centre) (confirm the official page of the location just before applying)

This article is general information and does not guarantee the acceptance of any individual opening notification, the propriety of the insurance-medical-institution designation, the required documents, the handling of the review, or the form. The acceptance and review of the clinic opening notification are decided by the prefectural governor, etc. (in a public-health-centre city or special ward, the mayor or ward head), and the insurance-medical-institution designation by the Minister of Health, Labour and Welfare (with the application window at the Regional Bureau of Health and Welfare). Confirm the form, attachments and filing deadline on the ordinance and official page of the clinic's location just before applying. The selection and lease brokerage of premises and the view on use and structure are by Yotsuba Real Estate Co., Ltd. (real estate broker), a separate business; the registration of the medical corporation's establishment by a judicial scrivener; the tax and accounting tied to opening finance and the estimation of social insurance premiums by a tax accountant; and the employment contracts, work rules and new application of social insurance by Yotsuba Labour and Social Security Attorney Office (labour and social security attorney), each contracting separately as an independent business. Our office does not represent registration applications, prepare registration applications, or give tax advice. 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.