The 2018 minpaku law's 180-night cap: text and aftermath

Search "Tokyo Shibuya 60 nights" on the three main lodging platforms and you will see three different listings at three different price ranges. The same square footage at three rates. Most travelers assume the gap reflects quality or location. It mostly does not. The gap is regulatory. Most of it traces back to a single 2018 statute. The statute capped one product category at exactly half the calendar.

The statute is 住宅宿泊事業法 (jūtaku shukuhaku jigyō-hō — the Housing Accommodation Business Act, Act No. 65 of 2017, in force from 15 June 2018). The bill created what most people call "minpaku." It is the registered short-term lodging tier that runs in residential buildings under noise-and-neighbor constraints. The act's full text is at the e-Gov portal under Act ID 429AC0000000065. MLIT keeps a consolidated reading version at minpaku.mlit.go.jp.

The article you are reading walks the statute backward from market effect. Where the prices come from. Which articles do the pricing work. What the cap means in practice. What the residential market the same reader will end up booking looks like as a downstream effect of the law.

What the three platform tiers actually map to

The three price ranges on platforms like Airbnb, Booking, and Vrbo each correspond to a different Japanese license tier.

The cheapest tier is the unlicensed listing operating outside the act entirely. That listing has no notification number on its page, no placard at the building, and runs on a wager that no neighbor will report it. Tokyo wards in 2025 are reporting more of these than they did in 2020. The platforms have grown more aggressive about delisting unlicensed inventory but the floor is still leaky.

The middle tier is the licensed minpaku — a registered residence operating under jūtaku shukuhaku jigyō-hō. The notification number appears on the listing and on a placard at the entrance to the building. The unit can take paying guests for up to 180 nights a year. Not 181.

The top tier is the licensed serviced apartment or aparthotel operating under 旅館業法 (ryokan-gyō-hō — the Hotel Business Act). These pay annual hotel-license fees and absorb periodic hokenjo (保健所 — the public health office that licenses lodging) inspections. They sell every night of the year. The cost of the license is in the per-night price.

The three tiers are not just price points. They are different products with different legal frameworks and different cost structures. The 2018 minpaku law sits on top of the middle tier. It pushes units toward the hotel-licensed top end and toward unlicensed listings at the bottom. The middle tier is the thinnest of the three.

What Article 2 actually says, and what 180 nights means in practice

Article 2, paragraph 3 of the act defines a private lodging business. The English translation maintained by the Ministry of Justice's Japanese Law Translation database reads:

"The term 'private lodging business' (...) means a business (...) [that] accommodates persons in a residence (...) and the number of days (...) does not exceed 180 days in a year."

Read the wording carefully. The cap is on "days," not on "stays" or "weekends." One night counts as one day. One double-booked night across two units in the same registration counts as one day per unit, not pooled.

The 180-day count runs from noon on April 1 to noon on April 1 of the following year. The window is set in 住宅宿泊事業法施行規則 (jūtaku shukuhaku jigyō-hō shikō kisoku — the Enforcement Rules, joint MHLW–MLIT Order No. 2 of 2017). A "day" is the noon-to-noon period. A check-in at 3pm and a check-out at 11am the next morning counts as one accommodated day.

The operator files a monthly report to the prefectural governor under Article 14. The report has to reconcile to that calendar. Over-reporting under Article 14 is a compliance penalty under Article 17. Under-reporting is a worse one. Operators tend to report tight.

That 180-day count is the federal ceiling. The actual sellable number is almost always lower. The reason is Article 18.

Article 18: the local-ordinance amplifier

The act gives prefectures and special-ward governments the power to add restrictions on top of the federal cap. Article 18, paragraph 1:

"Prefectures (...) may stipulate (...) the area and period of business by ordinance."

In practice, the local ordinance is the binding number, not the federal 180.

Shibuya's ordinance allows minpaku operation only during weeks when local public schools are in session. The window is Friday noon to Monday noon. A typical school calendar produces around 40 to 60 sellable corridors per year, depending on the exam schedule. The federal 180-day allowance gets compressed into those corridors. That works out to roughly 60 sellable nights, not 180.

Bunkyō's ordinance is similar. Chūō's is stricter in a different direction. Downtown commercial bands carve out exceptions, but residential zones are restricted. Setagaya bans minpaku entirely in buildings zoned 第一種低層住居専用地域 (dai-isshu teisō jūkyo senyō chiiki — the residential low-rise zone, which covers most of the ward).

A traveler comparing a Shibuya minpaku price to a Setagaya residential price is comparing two different sellable-night counts. The Shibuya operator has roughly 60 sellable nights per unit per year. The Setagaya residential operator has 365. The price has to absorb that ratio before the operator breaks even on the unit's master lease.

The other articles add cost on top of the 180-or-lower cap

The 180-day cap is the headline. The rest of the act is the cost.

Article 3 sets up the registration regime. The operator files a notification with the prefectural governor before the first guest. The notification carries seven items including floor plans, owner consent, and the company registration of any entity behind the operation. Once accepted, a notification number issues. In Tokyo this is the 10-character M130-prefix string that has to appear on every public listing.
Article 5 covers lodger-hygiene measures including bedding rotation, ventilation, and cleaning to a defined cadence. Failure to comply triggers Article 17 citations.
Article 7 forces multilingual guidance. Emergency-evacuation signage has to be in English and at least one other appropriate language. Fire-extinguisher labeling has to match. A printed guide to the ward's garbage-sorting rules has to be on hand. A solo operator running one Setagaya unit has to maintain signage in two languages. They also have to update it when the ward changes its garbage rules.
Article 8 mandates a guest register. The register captures each guest's full name, nationality, passport number for non-Japanese guests, arrival date, and departure date. Retention is three years. The prefecture audits these on demand.
Article 9 is the one operators in residential buildings find heaviest. The operator must explain particulars necessary for preventing adverse effects on the surrounding area. In practice this means a written notice to every resident in the same building. It also reaches neighboring buildings within the radius the prefecture sets, usually 10 meters in Tokyo wards. Each affected resident gets an annual notice with the operator's name, phone number, and noise policy.
Article 11 is the entrustment requirement. If the operator does not live in the building, the act forces entrustment to a registered 住宅宿泊管理業者 (jūtaku shukuhaku kanri gyōsha — a registered manager licensed under the same act). The registered manager carries a ¥30,000 application fee, ongoing reporting, and a yearly compliance audit. A small operator running three Suginami minpaku units already crosses the entrustment threshold for absentee operations.
Article 13 is the signage rule. A physical placard with the notification number, the operator's name, and the prefectural seal has to appear at the building's entrance. A guest at a Shibuya address who sees no placard is at a unit operating outside the act. Whatever the platform's listing page claimed does not matter.
Article 14 is the reporting layer. The operator files monthly with the prefectural governor on nights accommodated, nationalities of guests, and any complaints received.

Stack the articles up and the per-unit compliance overhead runs roughly ¥184,000 a year. That number assumes a single-unit absentee operator using a vendor digital tool for the Article 8 register. The cost falls on roughly 180 sellable nights at best, often closer to 60 under Article 18 local ordinances.

What the cap does to operator economics, walked at three horizons

Take a 22-square-meter studio in Setagaya at a ¥125,000 monthly master-lease cost (see master-lease economics for the underlying cost structure). The operator has to clear that rent somehow. Compare three operating models.

Model one. Full residential, 30-plus-night stays only.

The unit takes 365 sellable nights a year. At ¥6,500 per night equivalent for a 30-day stay (working out to ¥195,000 a month all-in) and 80% utilization, annual gross runs ¥1,898,000. Cleaning: one ¥18,000 turnover per stay, about 12 stays a year, ¥216,000. Net of master lease and cleaning: ¥1,898,000 minus ¥1,500,000 minus ¥216,000, or about ¥182,000 in operator margin. The unit covers the master lease comfortably.

Model two. Licensed minpaku with the federal 180-day cap, no Article 18 restrictions.

The operator clears ¥14,000 per night at 80% utilization across 180 nights. Annual gross: 180 × 0.80 × ¥14,000 = ¥2,016,000. Cleaning is heavier because the average minpaku stay in Tokyo runs about 2.8 nights. Roughly 51 cleanings a year at ¥6,000 per faster turn equals ¥306,000. Compliance: ¥184,000. Net of master lease, cleaning, and compliance: ¥2,016,000 minus ¥1,500,000 minus ¥306,000 minus ¥184,000, or about ¥26,000 in operator margin. The unit barely covers itself.

Model three. Licensed minpaku in Shibuya with Article 18 restrictions limiting sellable nights to roughly 60.

Gross at the same ¥14,000 rate and 80% utilization: 60 × 0.80 × ¥14,000 = ¥672,000. Cleaning drops proportionally to about ¥100,000. Compliance stays at ¥184,000 because it does not scale with nights. Allocating master-lease cost only to the weekend corridors comes to about ¥500,000. Net: ¥672,000 minus ¥500,000 minus ¥100,000 minus ¥184,000, or about negative ¥112,000. The unit cannot cover itself.

A rational operator picks model one. The market knows this. Since 2020, most nightly bookings have moved into licensed hotel-style brands like Mimaru and Tokyu Stay. The residential 30-plus-night segment has absorbed the rest.

What that consolidation does to residential asking rents

The Tokyo 23-ward asking-rent index ran a 6.4% year-on-year increase in Q4 2024. That is the strongest residential rent growth in Japan since the 1990s. A 20-square-meter studio in Bunkyō that listed for ¥120,000 in early 2019 lists at ¥140,000 in 2025. The nominal increase ran roughly 17%, against a cumulative CPI of about 3% over the same window.

The minpaku law is not the only cause of that shift. Inbound tourism is up. The yen depreciated against the dollar. Tokyo's central-ward population grew. But the 2018 act is one of the levers. Removing residential units from nightly-listing supply pushed the price of the residential nights that remain.

The national count of registered minpaku properties grew from about 18,670 in early 2023 to 33,618 by July 2025. Most of that growth happened outside Tokyo. The Tokyo 23-ward share of the count fell over the same window. Tokyo wards passed the strictest of the local-ordinance restrictions Article 18 allowed. Operators who would have run residential minpaku in Tokyo moved elsewhere or moved into the residential 30-plus-night segment.

This is the part the digital nomad searching for a 60-night Tokyo base ends up reading on the page. The asking rent on the Setagaya studio is paying for the supply that left.

What the cap looks like from the building owner's side

The act does not only constrain the operator. It also reshapes the building owner's decision about whether to allow minpaku in their building at all.

A landlord whose unit is empty 185 nights a year is no longer producing residential rent for those nights. They are producing minpaku rent instead, but only on 180 of the days, and only at a higher per-night number that has to cover the compliance pile described above. The math has to work for the landlord, not just the operator who holds the master lease.

Many condominium associations 管理組合 (kanri kumiai — the building's owner-association, which votes on the by-laws governing the property) have responded by adding minpaku-prohibition clauses to their by-laws. The grounds: the noise-and-trash problems that Articles 7, 9, and 13 try to mitigate are still real in practice. Other owners in the same building do not want the noise and trash even when the minpaku operator is following the rules.

A building that could host minpaku often cannot, because the kanri kumiai voted against it. A building that can host minpaku has to allocate the regulatory burden across the half-calendar the act permits. Either way, the residential rent that the unit could have produced for the full calendar is the alternative cost the minpaku math has to beat.

What other regulators are doing alongside Article 18

Article 18 lets prefectures and special-ward governments add restrictions on the operating side. But the act is also stacked on top of several other regulatory layers that affect the same physical units.

Fire-safety law. A residential building hosting minpaku has to meet fire-safety standards that approach hotel-grade for the rooms in active use. The cost of the upgrade (sprinklers, fire-rated doors, evacuation signage) can run several million yen for a small building. The cost falls on the operator or the landlord, not the platform.

Zoning law. The 都市計画法 (toshi keikaku-hō — the City Planning Act) sets land-use zones. Residential-only zones (the dai-isshu teisō and dai-isshu chūsō series) restrict business use. Some Tokyo wards have read those restrictions to exclude minpaku operation regardless of what the local Article 18 ordinance says. Setagaya is the cleanest example.

Tax law. A minpaku operation produces business income, not rental income, for tax purposes. The operator files a tax return as a business under the consumption-tax registration threshold, which kicks in at ¥10 million in taxable sales. Below the threshold, no consumption tax is owed but income tax is still due on the net.

The 2018 act is the loudest piece of the regulatory pile. It is not the only piece. Any operator running compliant minpaku in Tokyo is sitting on top of all four layers at once. The visible compliance overhead in the math above is one rough approximation. The actual overhead per unit varies by ward, by building, and by operator history.

A platform listing cannot show you those layers. The listing shows you a price. The price is what the operator needs to clear after the layers are paid for.

How to read the notification number on a listing

A minpaku listing on Airbnb or Booking that operates legally in Tokyo carries a 10-character notification number starting with M130. The number appears in the listing description. Some platforms put it in a dedicated field; others bury it in the body text.

The number is verifiable. The Tokyo Metropolitan Government maintains a minpaku registration database where you can search by notification number. The database returns the registered operator name, the operator's contact information, and the date of registration.

If a listing claims to be a minpaku but has no notification number on the page, the listing is unlicensed. If the listing has a number that does not appear in the database, the listing has either expired registration or never had one. Either way, the legal status is the same: unlicensed.

The verification takes about 30 seconds. It is the single most useful check a reader can do before booking a sub-30-night stay in Tokyo.

What this means if you are booking now

For a sub-30-night stay in Tokyo with a legitimate minpaku listing, expect a ¥4,000 to ¥10,000 per-night extra cost over the same address's 30-night residential rate. That extra cost is the regulatory tax that flows from the act.

For a sub-30-night stay with a listing that has no notification number on the page and no placard at the building, the listing is unlicensed. The prefecture can shut it down at any time. Your refund schedule is the platform's, not the operator's. The risk is real and increasing as Tokyo wards step up enforcement.

For a stay of 30 nights or longer, the minpaku tier becomes irrelevant. You will rent a residential unit at a residential rate from a residential operator. The act does not apply to that operator at all. The 180-day cap is a feature of the supply side you are not directly touching.

The cap lives in Article 2. The compliance lives in Articles 3 through 14. The local restrictions live in Article 18. The asking-rent shift in central Tokyo lives downstream of all three. The market you read on the platform is the law translated into price.

— HalfKey runs furnished Tokyo apartments on residential 30+ leases, not under the 2018 minpaku act. Browse listings for your dates.