The 180-Day Minpaku Law: The Limit That Makes Airbnb in Japan Hard to Profit From and How to Run the Numbers
A detailed analysis of Japan’s 180-day minpaku law, weekday restrictions in Shinjuku, a simulated revenue calculation, and when it makes sense to upgrade to a ryokan license.
Aug 7, 2026·✍️ olablog·⏱ 11 min read
A detailed analysis of Japan’s 180-day minpaku law, weekday restrictions in Shinjuku, a simulated revenue calculation, and when it makes sense to upgrade to a ryokan license.
Many Vietnamese people living in Japan—from engineers and international students to families who have settled there—have considered renting an apartment and operating it as an Airbnb (minpaku) business to earn passive income as the wave of international tourism continues to grow. The prospect of pocketing a few hundred thousand yen in profit every month sounds highly appealing. However, many are shocked only after paying the security deposit 敷金 (shikikin) and key money 礼金 (reikin) to discover that the number of days they are allowed to rent out the property is limited, operating costs have ballooned, and actual revenue may not even cover the monthly rent 家賃 (yachin). The biggest obstacle is the 180-night-per-year cap under the Residential Accommodation Business Act. This article takes an in-depth look at the legal landscape, works through the actual financial numbers, and explains the legal paths available to optimize cash flow when operating short-term accommodation in Japan.
What Is the 180-Day Minpaku Law (住宅宿泊事業法)?
Minpaku (民泊) is a term used for short-term rentals of private homes or condominium apartments to tourists. Before 2018, this business model operated in a legal “gray area.” To bring it under a formal legal framework, the Japanese government enacted the Residential Accommodation Business Act 住宅宿泊事業法 (Jūtaku Shukuhaku Jigyō Hō—commonly known as the New Minpaku Law / 民泊新法 Minpaku Shinpō).
Under the national framework (as of August 2026):
- 180-day-per-year limit: Each property may operate for a maximum of 180 nights in a fiscal year (from 12:00 noon on 1/4 to 12:00 noon on 1/4 of the following year).
- Notification procedure (届出 - Todokede): The property owner must submit a notification to the local government authority (usually the ward or city office) and receive a registration number beginning with the letter M. This number must be publicly displayed on Airbnb or Booking.com listings.
- Management delegation (住宅宿泊管理業者 - Jūtaku Shukuhaku Kanri Gyōsha): If the owner does not live at the property (家主不在型 - yanushi fuzai gata), they must sign a management delegation agreement with a minpaku management company licensed by Japan’s Ministry of Land, Infrastructure, Transport and Tourism (MLIT).
- Safety standards & guest management: Rooms must provide at least 3.3 m² per guest and be equipped with emergency lights, fire extinguishers, and evacuation maps. Operators must maintain a guest register 宿泊者名簿 (shukukaksha meibo), including scanned passport copies, and submit reports to the authorities every 2 months.
The law has made guests feel more secure, but the 180-day limit is a “glass ceiling” that makes it very difficult for individual investors to reach the break-even point.
Local “Traps”: Stricter Regulations (上乗せ条例) in Shinjuku and Tokyo’s Wards
If you think buying or renting an apartment in Tokyo automatically means you can operate for the full 180 days per year, that is an expensive misconception. National law allows up to 180 days, but it also gives local governments the authority to enact additional regulations 上乗せ条例 (Uwonose Jōrei), imposing further restrictions based on security, garbage, and noise concerns in residential neighborhoods.
Here is the regulatory situation as of August 2026 in several key areas of Tokyo:
1. Shinjuku Ward (新宿区)
Shinjuku has one of the highest concentrations of minpaku properties in Tokyo, but it also receives a large number of complaints about noise and garbage.
- Commercial districts (商業地域): Allowed to operate for the full 180 days/year.
- Exclusively residential districts (住居専用地域 - Jūkyō Sen'yō Chiiki): Operations are BANNED from 12:00 noon on Monday to 12:00 noon on Friday. This means guests may only check in from Friday noon until the following Monday noon (the weekend). As a result, the actual number of operating days in these areas is squeezed down to only around 80 – 90 days/year, completely undermining the financial plan if you do not check the zoning classification (用途地域 - yōto chiiki) before signing the contract.
2. Other Tokyo Wards
- Shibuya Ward (渋谷区): In residential areas, minpaku operations are generally allowed only during students’ school holidays (spring break, summer break, and winter break), for a total of only around 50 – 60 actual days/year.
- Chuo Ward (中央区 - Ginza, Tsukishima area): The entire ward applies a rule allowing guest check-ins only from 12:00 noon on Saturday to 12:00 noon on Monday.
- Chiyoda Ward (千代田区): Applies regulations that virtually prohibit the model when the owner does not live on-site.
In addition, around 80% – 90% of condominium buildings (マンション) in Tokyo have management bylaws 管理規約 (kanri kiyaku) that explicitly BAN short-term accommodation businesses. If you secretly operate without approval from the management association (組合 - kumiai), you risk having your contract terminated, being fined, or facing a lawsuit.
A Simulated Financial Analysis: Why Is 180-Day Minpaku Hard to Make Profitable?
To make this more concrete, let’s create a simulated financial table for a one-bedroom apartment (1DK/1LDK) in Shinjuku Ward (in a commercial district, operating for the full 180 days/year).
The prices, costs, and tax rates below were surveyed and updated as of August 2026:
1. Monthly Fixed and Operating Costs
- Rent 家賃 (yachin) + management fee 管理費 (kanrihi): 140,000 JPY/month (~23.5 million VND).
- Utilities and internet 光熱費 (kōnetsuhi): 20,000 JPY/month.
- Minpaku management company fee (15% of revenue): Approximately ~33,750 JPY/month on average.
- Platform fees (Airbnb/Booking 3% - 15%): Approximately ~10,000 JPY/month on average.
- Supplies, linen replacement, and depreciation: 10,000 JPY/month.
- Total apartment maintenance costs: approximately 213,750 JPY/month (~2,565,000 JPY/year).
2. Projected Revenue Under the 180-Day Cap
- Average daily rate (ADR): 15,000 JPY/night (~2.5 million VND).
- Occupancy rate during the permitted 180 days: Assumed to be 83% (equivalent to 150 nights rented per year).
- Total annual revenue (150 nights x 15,000 JPY): 2,250,000 JPY (~378 million VND).
3. The Result
- Annual revenue: 2,250,000 JPY
- Total annual costs: 2,565,000 JPY
- Net profit (before tax): -315,000 JPY (a LOSS of ~53 million VND/year)
A note from experienced operators: Even if you fill all 180 nights (180 nights x 15,000 JPY = 2,700,000 JPY), your annual profit would be only around 135,000 JPY (~22.6 million VND), or less than 12,000 JPY/month! If you also factor in the initial investment (furniture, electricity meters, fire-safety equipment, and the 敷金 juminhyo/shikikin deposit of approximately 500,000 – 800,000 JPY), it could take 4–5 years to break even.
That is why the “rent and sublet as an 180-day minpaku” model (Sublease Minpaku) is now almost economically unviable in Japan’s major cities if operated solely under the New Minpaku Law.
Comparison Table of 3 Short-Term Accommodation Business Models in Japan
To solve the 180-day problem, investors in Japan are now shifting toward other licensing options. Below is a comparison of 3 common models today (figures as of August 2026):
| Criteria | New Minpaku Law (住宅宿泊事業法) | Simple Lodging / Ryokan (旅館業法 - 簡易宿所) | Special Zone Minpaku (国家戦略特区民泊) |
|---|---|---|---|
| Operating-day limit | Maximum 180 nights/year | 365 days/year (No limit) | 365 days/year (No limit) |
| Zoning (用途地域) | Most areas (unless restricted by the ward) | Only commercial and quasi-industrial areas | Depends on the designation by the special-zone local government |
| Minimum guest stay | 1 night | 1 night | Minimum 2 – 3 nights (depending on the ward/city) |
| Permit and fire-safety upgrade costs | Low (approximately 100,000 – 300,000 JPY) | High (approximately 800,000 – 2,000,000+ JPY) | Moderate (approximately 300,000 – 600,000 JPY) |
| Typical areas of application | Nationwide | Nationwide | Ota Ward (Tokyo), Osaka, Kitakyushu... |
| Financial suitability | Suitable for combining with a residence and renting out spare space | Best suited to professional investors | Good for purchasing an entire house in Osaka/Ota-ku |
When Should You “Upgrade” to a Ryokan Gyo License (旅館業法)?
If you decide to treat accommodation as a serious investment channel in Japan, stopping at 180-day minpaku is not enough. You should consider upgrading to a hotel/simple-lodging business license under the Hotel Business Act 旅館業法 (Ryokan Gyōhō—the 簡易宿所 Kan'i Shukusho category) in the following situations:
1. You Own an Entire House (戸建て - Kodate) or a Standalone Building
If you purchase a detached house or a small building located in a commercial district (商業地域) or quasi-industrial district (準工業地域), obtaining a Ryokan Gyo license will allow you to operate for the full 365 days/year. Revenue can then increase by 2 to 2.5 times compared with the 180-day cap, enough to cover all costs and generate an annual return of 8% – 12%.
2. Fast Capital Recovery Is Your Top Priority
As of August 2026, the cost of upgrading a house to Ryokan Gyo standards—including installing an interconnected automatic fire-alarm system 🧯, fire doors, emergency exits, and working with the public health center 保健所 Hokenjo—ranges from 800,000 JPY to 2,000,000 JPY. Although the initial cost is high, operating year-round generally results in a much shorter payback period than the 180-day minpaku model, which leaves the property vacant for half the year.
3. You Want to Combine It with Monthly Rentals (Monthly Lease)
If you retain a 180-day Minpaku license, one solution many property owners use today is: Operate as minpaku during the 180 peak tourist days (March–April during cherry blossom season, October–November during the fall foliage season, and Christmas/New Year). During the remaining 185 days, switch to monthly short-term rentals (マンスリー Monthly rentals) for engineers, international students, or business travelers. This hybrid approach fills the revenue gap while remaining fully compliant with the law.
Frequently Asked Questions
Q. Will I get caught if I secretly rent out the property for more than 180 days or operate without an M registration number? It is extremely easy to get caught. Starting in 2026, Japan’s Ministry of Tourism and platforms such as Airbnb and Booking have automatically synchronized registration-number data. In addition, Japanese neighbors are highly sensitive to noise and improper garbage disposal. A single call to the ward office is enough for the police and health inspectors to conduct a surprise inspection. Illegal operations can result in fines of up to 1,000,000 JPY, imprisonment, or a direct impact on your status of residence in Japan (for example, your visa or permanent-resident status).
Q. Can a foreigner with an engineer visa or family visa register a minpaku business in their own name? You may own real estate, but when it comes to operating a business, you need to check the scope of activities permitted under your status of residence (在留資格 - zairyū shikaku). An engineer or family visa does not allow you to directly operate a commercial business earning substantial profits unless you have registered for “Permission to Engage in Activity Other Than That Permitted” (資格外活動許可 - shikakugaikatsu dōkyoka), or you must delegate the entire operation to a professional minpaku management company (住宅宿泊管理業者).
Q. Can I clean the minpaku room myself to save money? If you register as a live-in host (家主居住型 - yanushi kyojū gata) and the apartment has fewer than 5 rental rooms, you may manage and clean it yourself. However, if you do not live there (家主不在型), you must sign a contract with a licensed management company. Whether you clean the property yourself or outsource the work then depends on the terms of your agreement with that management company.
Summary and Advice for Vietnamese Residents in Japan
Running an Airbnb in Japan is not a rosy “easy money” opportunity. The New Minpaku Law’s 180-day-per-year limit, combined with stricter ward-level regulations in places such as Shinjuku and Chuo, makes the rent-and-sublet minpaku model highly risky.
To succeed, you need to:
- Always carefully check the zoning classification (用途地域) and the ward’s additional regulations (上乗せ条例) before renting or buying a property.
- Make sure the building’s management bylaws 管理規約 allow accommodation businesses.
- If you plan to operate long term, calculate whether applying for a 365-day Ryokan Gyo license (旅館業法) would optimize your cash flow.
Recommended further reading:
- Learn more about renting a home, administrative procedures, and practical money-saving tips at Blog OlaChill.
- Book trips exploring Japan with Vietnamese-speaking guides through Day Tours from Tokyo.
- Find more useful information about daily life, culture, and services on the OlaChill homepage.
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