Up until recently, you could easily sign up as a host on Airbnb Japan, which launched in 2013. All you had to do was to set up your profile, set up the accommodation, add your listings, and you were good to go. Unfortunately, that is no longer the case thanks to the new Minpaku Law. Now, a bunch of careful steps need to be taken before you can (re)open your listing as an Airbnb host in Japan, if you still want to be a host. Here's an overview of what the process entails, with a few insider tips and caveats.  

Getting your “notification number for minpaku registration” as an Airbnb host in Japan

Definitely the easiest, and probably the fastest, though a very expensive, way to do this is to consult and outsource the whole complex process to an administrative scrivener, or gyousei-shoshi, who can take care of the paperwork for you. Companies like Minpaku Brothers can handle it for you in English, as they have English-speaking staff. Alternatively, you may want to contact a nearby realtor or arrange an introduction to one through a friend.

To be honest, there don't seem to be very many businesses openly saying they can help hosts figure out the registration process in English. That means it's pricey. According to the Minpaku Brothers website, depending on your case, it may cost anywhere between JPY 300,000 and JPY 2,500,000 to complete the process to get your registration number for Airbnb or another homesharing platform.

From what I can see, there are many cases where even the professionals cannot achieve successful registration for various reasons: they couldn’t bend the rules for the apartment building that prohibits Airbnb, or the listing didn’t pass the fire department regulations for safety, or the building standards law. But their efforts and research will still cost you JPY 70,000 or so on average.

It's also important to remember, before you talk to legal professionals, that your city or ward may have recently put restrictions on Airbnb and the like. For instance, in Shinjuku, Nerima and Bunkyo in Tokyo, and Yokohama City in Kanagawa, it seems you can only operate your Airbnb on weekends and holidays, with rules varying slightly depending on whether the owner is on or offsite.

For Kyoto, you are only allowed to operate in the months of January and February. And in Ota in Tokyo, all Airbnb and other minpaku in residential districts are already illegal!

Up until now, the fines for running an illegal minpaku were no more than JPY 30,000, but under the new law, it is said that you can be fined up to JPY 1,000,000 or even get jail time. So, first and foremost, before you think about outsourcing to professionals to help you get the minpaku licence, you need to check with your local government on what kind of regulations there are for the location of your listing.

But it's not all doom and gloom, and it is possible to get listed legally. For example, a non-Japanese person from New Zealand seems to have successfully obtained her private lodging notification number for registration in accordance with the new law in late May. She did so with the help of a Japanese real estate agent, and it took about a month and a half. She has written about her experience, down to the details of how backed up local government offices are with piles of applications at the moment.

Reading it will give you a good idea of how tedious and stressful the process can be, including the part where you have to prove that you are not bankrupt or mentally handicapped. The Japanese government issues documents proving this for Japanese nationals, but not for foreigners, so you will have to make a visit or two to the embassy of your country to get these points confirmed. The Airbnb host has included images of all 10 forms that she had to submit, with some consisting of several pages.

One more thing to consider before embarking on the process: once registered, an Airbnb host is capped at 180 days out of a year, and they need to report details of all guests once every two months, including which countries they were from and how many nights they stayed.

If “Special Zone Private Lodging” applies to you 

It is important to note as a host/potential host that depending on location, and as long the space dedicated to each guest is over 25 sq m, your listing can be certified for “Special Zone Private Lodging”, such as in Ota, which is where Haneda Airport is located.

Special Zones are areas that the government sees as important locations because more tourists use them, and parts of Tokyo, Osaka, Niigata and prefectures on Kyushu are among the areas included. Apparently the process is not as strict as getting a private lodging registration number, and you are not capped at 180 days. However, guests need to stay a minimum of two nights at a time, and can only stay up to nine nights in total.

Basically, getting certified for Special Zone Private Lodging requires the same process of consulting the Environmental Health Division of your location, clearing fire safety regulations, notifying the neighbours, passing a field survey and submitting other required documents in regards to your listing. It is a very similar process to getting a private lodging registration number — but it seems to be a bit easier. 

Obtaining a small hotels business permit (kan-i shukusho) as an alternative

You can also try to get a hotel permit to be an Airbnb host — again, no easy task for an individual, no doubt, and it pretty much goes through the same long, detailed process. But they seem to have (very slightly) loosened up on the regulations for this licence, and it’s no longer mandatory for you to have a physical reception desk that a traditional hotel would require.

It's not impossible to try to take care of all the paperwork yourself, but remember, most people at your local government office are not going to speak English (or any other language other than Japanese), so you may want to hire professional help if you go down this path.

An option for farmers

There is also a small hotels permit that can be obtained if you can provide some farming experience for your guests. For this, you will need to be a certified farmer yourself (another long, crazy bureaucratic process you need to go through), or collaborate with a certified farmer in close proximity to the location you want to host, to make this a reality.

Even so, the process is a marathon of running around to different departments of the local government, from the fire department to the health centre, forestry and environmental department, and the architectural department, after they give you a 65-page manual on how to get this small hotels permit. Aside from submitting a beautifully drawn-up 2D and 3D layout of your place (preferably by an architect, unless you know how to use the software to do it yourself), you need to provide lots of information related to water, which is explained in a 64-page manual (location of pipes, numbers and types of septic tanks, how much water you use on average, etc.), and also a detailed plan of the farming experience you will provide, broken down by month.

Oh, and you may also need to attend a two-day seminar on fire safety to get a Fire Management Specialist Licence for a small fee, if your property is over a certain size, and also install fire multiple fire alarms and one of those big green exit signs over your door — which must be installed by certain vendors (you cannot just go on Amazon, buy them, and install them). The equipment for fire safety alone will cost you roughly JPY 150,000 or more.

Apparently, passing the test with the fire department is usually the toughest part in either getting a registration number, certification, or the permit, which is actually understandable, as no one wants casualties from a fire.

I have a friend who has been trying to get a small hotels permit as a farmer since right after the March 15th announcement, when all the official information about the new Airbnb Japan regulations went out on the government-operated minpaku information site; my friend is still not done completing the process, and their listing has already been taken down from Airbnb.

Becoming a private lodging administrator, aka real estate broker

This is probably an unrealistic option unless you plan to manage multiple listings full time, already have a licence as a real estate broker in Japan, and also speak fluent Japanese.

To be licensed, you need to have passed the national examination that only 15% of native speakers of Japanese pass on a yearly average. Plus, you need to keep renewing your registration every five years and pay JPY 90,000 to keep your status. This is probably the last choice out of the four possibilities for hosting for most individuals.

Summary

In short, it is a very tough time to get into (re)hosting your Airbnb in Japan at the moment. If you are thinking long-term and really want to get into this business, obtaining the small hotel permit might be preferable, since once you have the permit, there is no need to renew it, or to provide detailed reports to the government on as regular a basis as a regular Airbnb host.

Keep in mind though that as of June 8th, 2018, out of a reported 724 applicants who submitted documents for one type of home-sharing or another, only 152 had apparently been approved, and even in popular areas of Tokyo, the number approved seems to be in the single digits.

Those numbers alone should tell you that this is not something you want to get into lightheartedly as an individual. However, many hotel businesses and real estate companies who already have permits are definitely not complaining about the new law, and BPO (business process outsourcing) services for cleaning, rental wifi, rental furniture, guest communication and so on are flourishing.

There are even businesses that help people “clear out” soon-to-be-illegal homesharing locations, and of course, numerous companies with administrative scriveners and other legal professionals who are happily accepting calls from individuals desperately trying to comply with the new regulations to continue hosting.

By Kaori Kitagawa

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