What is a specified amusement restaurant business licence? Its difference from late-night alcohol service and the requirements to apply

To run a club or lounge that lets customers amuse themselves and serves food and alcohol late at night, you need the specified amusement restaurant business licence from the prefectural public safety commission under the Entertainment Business Act. This article organises the target, the permitted areas and hours, the application requirements, and how the roles divide among other professionals.
In short: to open a club or lounge that, late at night, lets customers dance or watch shows while serving them food and alcohol, the business falls under the "specified amusement restaurant business" in Article 2, paragraph 11 of the Act on Control and Improvement of Amusement Business (the Entertainment Business Act), and under Article 31-22 you must obtain the licence of the prefectural public safety commission with jurisdiction over the premises, for each premises. This is a relatively new "licence" system, created by the 2015 amendment to the Act and in force from 23 June 2016. It is distinct from a place that merely serves alcohol late at night (a notification) and from a place that entertains customers with hostess-style service (an amusement business licence). The business may only operate in the "permitted areas for premises" designated by prefectural ordinance, and the structure and grounds for disqualification are examined, so you must confirm before renting that the location and structure meet the requirements. This article is general information organising the target, areas and application requirements of the specified amusement restaurant business licence; it does not judge the outcome of any individual licence.
What kind of business is a specified amusement restaurant business?
Article 2, paragraph 11 of the Act defines a specified amusement restaurant business as "a nightclub or other business that, with equipment provided, lets customers enjoy amusement and lets them eat and drink (limited to those serving alcohol to customers)," excluding "those operated only during the hours after 6 a.m. and before midnight of the following day (and excluding those falling under an amusement business)." In plain terms, the target is a business that meets all four of the following.
- (1) It lets customers enjoy "amusement" (yūkyō)
- (2) It lets customers eat and drink
- (3) It serves alcohol to customers
- (4) It also operates during late-night hours (midnight to 6 a.m.)
Point (4) is key: a business operated only from daytime until before midnight is not a specified amusement restaurant business, even if it lets customers amuse themselves. Operating across midnight while letting customers amuse themselves is the heart of this business. There is no statutory definition of "amusement"; the concept is set out in the National Police Agency's interpretation and operation standards. It means the operator actively prompting customers so that they amuse themselves — examples given include showing shows, performances or live music to unspecified customers, letting them dance, encouraging them to sing with karaoke equipment, and letting them play games. By contrast, merely placing karaoke equipment or a television that customers use on their own, without the operator actively encouraging it, is generally treated as not amounting to amusement, but it is judged on the actual situation. The individual judgement is made by the police station with jurisdiction.
How does it differ from a late-night alcohol-serving restaurant or a hostess-style restaurant?
Restaurants that serve alcohol late at night divide into three procedures according to whether there is "entertainment" (hostess-style service) and whether there is "amusement." Mistaking one for another risks operating without the licence you actually need.
| Business content | Required procedure | Basis |
|---|---|---|
| Entertaining (hostess-style) and serving food (snack bar, club, etc.) | Amusement business (entertaining food-and-drink business) licence | Act Art. 2(1)(i), Art. 3(1) |
| Letting customers amuse themselves late at night and serving alcohol (no entertaining) | Specified amusement restaurant business licence | Act Art. 2(11), Art. 31-22 |
| Serving alcohol as the main offering late at night (no entertaining, no amusement) | Late-night alcohol-serving restaurant business notification | Act Art. 33(1) |
If there is "entertaining," it becomes a question of an amusement business licence regardless of amusement (we organise entertaining in A restaurant with hostess-style service (Entertainment Business Act, type 1): what premises can get the licence?). If there is no entertaining but amusement late at night, it is a specified amusement restaurant business; if there is neither amusement nor entertaining and you only serve alcohol late at night, a notification suffices (see Serving alcohol after midnight: what notification do you need?). Note that a place with equipment for customer amusement that operates with illumination of 10 lux or less may instead fall under an amusement business (low-illumination restaurant; Art. 2(1)(iii)). A specified amusement restaurant business presupposes illumination above 10 lux.
What restrictions apply to the areas and hours of operation?
For a specified amusement restaurant business, "location" most affects property choice. In principle this business may be operated only in the "permitted areas for premises" designated by prefectural ordinance. The designation follows standards set by cabinet order, one of which is that the area must not fall within a zone of up to roughly 100 metres around the site of a protected facility such as a school, library, child welfare facility, hospital or clinic. As an exception, premises within a hotel or similar facility that meet the standards of National Public Safety Commission rules (a "conforming premises within a hotel, etc.") may operate even outside the permitted areas.
| Item | Principle |
|---|---|
| Permitted operating areas | Limited to the permitted areas for premises designated by ordinance (a conforming premises within a hotel, etc. is an exception) |
| Distance from protected facilities | The Enforcement Order sets a limit of up to roughly 100 metres around the site, designated by ordinance (the actual figure differs by ordinance) |
| Operating hours | No uniform late-night operating ban under the Act, but prohibited hours may be set by prefectural ordinance |
Unlike an amusement business, there is no uniform late-night operating ban, but prefectural ordinances sometimes set prohibited hours. The scope of permitted areas, the distances and the prohibited hours differ greatly by prefecture and change block by block even along the same street. Before deciding on a property, it is essential to check with the police station with jurisdiction (community safety division) and the ordinance whether the location falls within a permitted area and what the prohibited hours are (accessed 2026-10-09). Because there are also restrictions on minors entering late at night and on serving them alcohol, confirm these together with your method of operation in advance.
What documents and structural requirements does the licence application need?
The application is made to the public safety commission through the police station with jurisdiction over the premises. The documents differ by prefecture, but the following are generally required (always confirm the latest forms with the official guidance of the police station with jurisdiction).
| Category | Examples of documents |
|---|---|
| Basics of the application | Licence application form, a document describing the method of operation, a document describing the method of letting customers amuse themselves |
| Premises | Floor plan and area-calculation drawing, lighting and sound equipment drawings, materials proving the right to use the premises (lease, etc.) |
| Applicant | Residence certificate, written oath; for a company, articles of incorporation and certificate of registered matters, etc. |
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As for structure and equipment, Article 31-23 of the Act applies by reference the provisions on the amusement business licence (the licence standards of Article 4, i.e. grounds for disqualification and the location and structural standards), and the details of the technical standards are set by the Enforcement Regulation and prefectural ordinances. The structure of guest rooms — such as not installing equipment that may harm public morals or a clean public-morals environment, and standards on sight lines and lighting — is examined. Because a mismatch between the drawings and the actual state will be flagged at the on-site inspection, it is safer to settle the area-calculation drawing and floor plan with an architect or interior contractor from the design stage. You contract for these separately with them as an independent business from our office.
How does the process run, and how are roles divided among other professionals?
Opening a specified amusement restaurant business spans several specialist fields. The roles are as follows.
- Confirming requirements, preparing the application documents, and acting as agent for the specified amusement restaurant business licence application → Yotsuba Administrative Scrivener Office (administrative scrivener)
- The lease of the shop property and advance checking of the location (permitted areas, land-use zone, distance from protected facilities) → Yotsuba Real Estate Co., Ltd. (licensed real estate broker)
- Preparing the floor plan and area-calculation drawing, and the guest-room structure, interior design and work → architects and interior contractors
- Labour matters such as late-night premium wages and shifts for employees → Yotsuba Labour and Social Security Attorney Office (labour and social security attorney)
- The restaurant business permit (Food Sanitation Act) → the public health centre
Yotsuba Real Estate Co., Ltd., a separate business from Yotsuba Administrative Scrivener Office, handles the property search, the lease, and the advance check of the permitted areas and distance from protected facilities under a separate contract as an independent business. The floor plan and area-calculation drawing are for architects and interior contractors, labour matters for Yotsuba Labour and Social Security Attorney Office, and the restaurant business permit for the public health centre, each contracted and handled separately as an independent business or jurisdiction. Each field is on the premise that you contract separately with each counter or qualified professional, and our office receives no referral fee. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for the whole picture of our services, see Permits and Applications. The outcome and examination of the licence are decided by the prefectural public safety commission (police station with jurisdiction).
FAQ
Q. If I do not operate late at night, do I not need the specified amusement licence?
A. That is correct. Article 2, paragraph 11 of the Act excludes those operated only during the hours after 6 a.m. and before midnight of the following day from the specified amusement restaurant business. A place that lets customers amuse themselves only from daytime until before midnight is not the target of this licence. The heart of the specified amusement business is letting customers amuse themselves and serving alcohol across midnight. The individual judgement is made by the police station with jurisdiction.
Q. What specifically does "letting customers amuse themselves" mean?
A. There is no statutory definition; the concept is set out in the National Police Agency's interpretation and operation standards. It means the operator actively prompting customers so that they amuse themselves, with examples including showing shows or live music to unspecified customers, letting them dance, encouraging them to sing karaoke, and letting them play games. Merely placing karaoke equipment that customers use freely, without the operator encouraging it, is generally treated as not amounting to amusement, but it is judged on the actual situation.
Q. How does the procedure differ from a hostess-style place or a place that only serves alcohol late at night?
A. If you entertain (hostess-style), it is an amusement business licence; if there is no entertaining but amusement late at night, it is a specified amusement restaurant business licence; if there is neither amusement nor entertaining and you only serve alcohol late at night, it is a late-night alcohol-serving restaurant business notification. Because the procedure changes according to whether it is amusement or entertaining, it is important to organise the method of operation concretely before choosing a property.
Q. What kind of property can get a specified amusement licence?
A. In principle, only a property within the permitted areas for premises designated by prefectural ordinance (a conforming premises within a hotel, etc. is an exception). The permitted areas are designated by ordinance avoiding, for example, zones of up to roughly 100 metres around the site of a protected facility, and the distances and scope differ by prefecture. Before deciding on a property, confirm with the police station with jurisdiction (community safety division) whether the location falls within a permitted area.
Sources (Primary Information)
- e-Gov Law Search, "Act on Control and Improvement of Amusement Business" (Act No. 122 of 1948), Article 2, paragraph 1, item 1 and paragraph 3; Article 2, paragraph 11; Article 3, paragraph 1; Article 13, paragraph 1; Article 31-22; Article 31-23; Article 33, paragraph 1 (accessed 2026-10-09)
- Enforcement Regulation of the Act on Control and Improvement of Amusement Business (National Public Safety Commission Rule No. 1 of 1985) (technical standards for structure and equipment; application documents) (accessed 2026-10-09)
- National Police Agency, Community Safety Bureau, "Standards for the interpretation and operation of the Act on Control and Improvement of Amusement Business, etc." (the concept of "amusement") (accessed 2026-10-09)
- Each prefecture's regulation ordinance under the Entertainment Business Act (permitted areas for premises; prohibited operating hours; distance from protected facilities) (accessed 2026-10-09)
- Act partially amending the Act on Control and Improvement of Amusement Business (Act No. 45 of 2015; creation of the specified amusement restaurant business, in force from 23 June 2016) (accessed 2026-10-09)
This article is general information and does not guarantee the outcome of any individual licence, whether a location falls within the permitted areas, compliance with the structural standards, the required documents, the examination period, or the applicability of grounds for disqualification. Because the permitted areas, distances, prohibited hours and forms differ by prefecture, always check the ordinance for the premises' location and the official guidance of the police station with jurisdiction (community safety division). The outcome and examination of the specified amusement restaurant business licence are decided by the prefectural public safety commission (police station with jurisdiction). The lease and location check are handled by Yotsuba Real Estate Co., Ltd. (licensed real estate broker), the floor plan and area-calculation drawing by architects and interior contractors, labour matters by Yotsuba Labour and Social Security Attorney Office (labour and social security attorney), and the restaurant permit by the public health centre, each as an independent business or jurisdiction, under separate contracts and procedures. 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.
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