Practical Checklist to Comply with the 180-day Cap in Minpaku Operations

2025.10.10

INDEX

In short-term rental investing, excluding Tokku Minpaku, compliance with the 180-day cap under the Housing Accommodation Business Act, plus solid filing and operations, determines both upside and risk. This is a concise, numbers-first checklist. Note that this article focuses on the notification-based scheme; Tokku Minpaku and Hotel Business Act permit-based operations are out of scope because their limits differ.

1. Filing and Operating Structure

Complete the administrative notification (filing) before launch and display the required sign at the entrance. For remote or multi-unit operations, contract a nationally registered minpaku management company and specify the complaint desk, cleaning, and key management. Standardize guest ID verification and a guest registry from day one.

2. Managing the Rules by Numbers

Total offering days must stay within 180 days per year. Use a calendar with automatic day-counting and pause sales when the remaining days fall below 10, or raise the minimum stay. Keep the guest registry for 3 years and verify IDs at check-in. For fire safety, link checks of smoke alarms, extinguishers, and evacuation signage to the cleaning checklist and record them in the ops log.

3. Revenue Planning and Taxes

With the 180-day cap, model revenue using ADR and assumed occupancy. Example: ADR ¥12,000, offering 180 days, 70% occupancy ⇒ 126 nights sold and ~¥1,512,000 annual revenue (¥12,000 × 126). Tax treatment may be real estate income or business income depending on service level. Set up books to qualify for the ¥650,000 blue return deduction from the first year.

4. Example (Studio Unit)

Publish the calendar mostly on weekends, using weekdays for cleaning and maintenance. With ADR ¥14,000, 150 days open, 85% occupancy ⇒ 127 nights and ~¥1,778,000 revenue (¥14,000 × 127). Charge ¥4,000 per turnover to guests, and when 15 days remain, stop long-stay discounts to protect ADR.

5. Takeaway

The main constraint is 180 days. Build on automated day tracking, 3-year registry retention, and proper fire and signage compliance, then optimize profit by allocating offering days and lifting ADR. Put the system in place early, and compliance and performance can go hand in hand.

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