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Can You Operate Minpaku or Ryokan Businesses in Shibuya Ward? Overview of Smart Key Requirements, Briefings, and Water Facilities Standards

17 min readBy Takanobu Ezaki

Ryokan businesses (simple lodging businesses) in Shibuya Ward do not require a front desk or permanent staff presence. They can be operated unmanned as long as there is a system to respond within 10 minutes. However, keys are limited to smart keys only; key boxes are not allowed. A briefing session for neighbors is also required before application.

Under the New Minpaku Law (住宅宿泊事業, Private Lodging Business Act), operation periods are restricted by ward ordinance in residential-only areas and educational districts. Because Shibuya Ward is not a designated National Strategic Special Zone for Minpaku, the available systems are the New Minpaku Law and the Ryokan Business Act.

Note that the ward’s materials show ordinance changes effective from July 1, Reiwa 8 (2026) (as of the time of this article’s research). For the status of enforcement and detailed operation after the amendment, please check the ward’s latest guide.

The regulatory information in this article was organized by our company based on confirmation with the public health center and the ward’s public materials (as of August 2026).

Shibuya Ward Minpaku and Ryokan Business Regulations Quick Reference Table

CategoryItemDetails
Ryokan Business (Simple Lodging Business)Front DeskNot required
Response TimeWithin 10 minutes
Notice to NeighborsBriefing session
Key HandingKey boxes not allowed
New Minpaku Law (Private Lodging Business Act)Ward’s Additional OrdinanceOperation period restrictions in residential-only and educational districts

Ryokan Business (Simple Lodging): Unmanned Operation Allowed, With Conditions on Keys and Notices

The ryokan business requires permission and has no limit on the number of operational days per year. The operational requirements related to management in Shibuya Ward are as follows.

  • Front Desk: Installation is not required
  • Response: A system to arrive at the facility within 10 minutes in case of trouble or inquiries
  • Keys: Only smart keys can be used. Key boxes are prohibited to prevent uncontrolled unmanned access by unspecified persons.
  • Signage: Display a sign at the facility and report it to the public health center
  • Notification to Neighbors: Notify the targeted parties by distributing documents or similar means about the date and place of the briefing session, and hold the briefing

Key boxes are not allowed because anyone who knows the code can take out the key. Smart keys vary by model regarding features such as whether the access code can be changed for each guest or whether usage history is recorded. To avoid setbacks, confirm with the public health center which models and operations are acceptable before purchasing equipment.

The briefing session venue should be chosen where target participants can easily gather. The ward’s guide cites the facility planned for application or nearby rental conference rooms as examples. Compared to wards where flyer distribution alone suffices, notification through document distribution, venue arrangement, and day-of management add to the process, so allow sufficient time in your application schedule.

Standards for Bathrooms, Toilets, and Washbasins

Shibuya Ward’s guide also specifies standards for water facilities. If installing a bathroom or shower room, they should, in principle, be separated by gender with at least one facility each. For toilets and shared washbasins, the standard is one fixture per 5 guests.

Number of GuestsToiletsShared Washbasin Faucets
Up to 511
6 to 1022
11 to 1533

The above table is a simple application of “1 per 5 guests”; for how to handle remainders, confirm with the public health center. When converting a single-family house, if there is only one bathroom in the original layout, how to fulfill the gender separation requirement becomes an initial point of discussion. The more guests accommodated, the more additional water facility works will be required, so consider this together with guest room layout.

New Minpaku Law (Private Lodging Business Act): Operation Period Restrictions in Residential-Only and Educational Districts

The New Minpaku Law uses a notification system, with a national uniform limit of 180 days per year. For absentee owner-type management, contracting a lodging management business operator is mandatory.

Shibuya Ward additionally restricts operating periods by ordinance in residential-only and educational districts. The applicable periods vary depending on the property’s location, so check with the ward’s relevant section before submitting notification. Properties outside these districts are limited only by the national 180-day rule.

Property Market Prices in Shibuya Ward (August 2026)

IndicatorShibuya WardRank among 23 Wards
Listed Detached House Price (Median)164.8 million yen (44 listings, total floor area 91 m²)2nd highest / 21 wards
Rental Detached House Asking Rent (Median)375,000 yen/month (53 listings, 85 m²)3rd highest / 21 wards
Whole Building Income Property Gross Yield (Median)3.5% (55 listings)21st highest / 23 wards

Source: Urbalytics Market Report (Shibuya Ward). Median of properties listed or rented in August 2026. Indicators with fewer than 10 listings are not shown.

Prices for listed detached houses are among the highest in the 23 wards, making acquisition costs for whole-building Minpaku business high. Rental detached house asking rents are also high, so monthly fixed costs are considerable even when leasing and subleasing.

On the other hand, the gross yield for whole-building income properties ranks low among the 23 wards. Because yields for ordinary rental operations are hard to generate, some may consider earning more with lodging business. However, the New Minpaku Law’s 180-day limit combined with the ward’s period restrictions caps revenues. To remove day limits under the ryokan business, a property must meet the conditions of the land use zone described next.

The Available System Changes Depending on Property Location

In Shibuya Ward, the options differ significantly depending on whether the property is in a residential-only area. Ryokans and hotels are basically not allowed to be built in residential-only zones, so it is not possible to obtain ryokan business permission for properties in those areas. For the remaining New Minpaku Law system, the ward’s period restrictions apply, making lodging operations less suitable in residential-only zones.

Property LocationRyokan Business (Simple Lodging)New Minpaku Law
Residential-only zones (First and Second Low-Rise Residential / Mid/High-Rise Residential, Rural Residential)Not allowedPeriod restrictions by the ward apply
First-Class Residential DistrictBuildings under 3,000 m² only180 days (educational districts have period restrictions)
Commercial, Quasi-Residential, and Other Zones Except Those AboveAllowed (excluding industrial and exclusively industrial zones)180 days (educational districts have period restrictions)

Even in zones where the ryokan business is allowed, conversion from residential use requires confirmation of use-change and compliance with the Building Standards Act and Fire Service Act. Because educational district designation should be checked separately from use districts, do not rely solely on address but check both on the city planning map.

Points to Check When Considering Properties in Shibuya Ward

  • Confirm use district and educational district designation on city planning maps to decide in advance which system (ryokan or New Minpaku Law) applies
  • If applying for ryokan business, check whether you can secure a base or outsource partner to respond within 10 minutes
  • Pre-consult with the public health center about the smart key model and operation to be adopted
  • Check whether the layout can accommodate gender-separated bathrooms and required numbers of toilets and faucets in conjunction with guest capacity
  • Schedule briefing session venue and date into your application plan
  • For condominiums, check management rules, and for rentals, confirm written sublease consent from the lessor

Because no front desk or permanent staff is required, the ryokan business in Shibuya Ward relies directly on the response system and smart key operation for operation quality. For how to entrust operations including cleaning and guest response, see our page on Minpaku operation agency.

Frequently Asked Questions

Can key boxes be used for simple lodging businesses in Shibuya Ward?

No. Only smart keys are allowed in Shibuya Ward to prevent uncontrolled unmanned access by unspecified persons. Unmanned operation itself is allowed when a response system is in place to arrive within 10 minutes.

Is flyer distribution sufficient for notifying neighbors?

Shibuya Ward requires holding a briefing session. Target parties must be notified of the date and place via document distribution or similar, then a briefing session is held at a location easy to gather such as the facility planned for application or nearby rental conference rooms.

Can Minpaku be operated in residential-only detached houses?

Ryokan business permission cannot be obtained, but notification under the New Minpaku Law is possible. However, since the ward restricts operation periods in residential-only areas by ordinance, check the applicable period with the ward office before calculating profitability.

Contact and Reference Materials

Compare with Other Wards

Ordinances and operations may change due to amendments or public health center decisions. Before acquiring properties or applying, consult in advance with the responsible public health center.

Featured photo: Yuya Uzu / Unsplash

About this article

Author
Takanobu Ezaki(Accommodation Business Manager)Qualifications: Type A Fire Prevention Manager, Type 1 Health Officer, Hazardous Materials Engineer, Class B-4, Class 2 Boiler Engineer

Has held the posts of manager, general manager, and director at hotels, ryokan, and golf courses across more than 30 years, taking charge of overall facility operations along with P&L management, liaison with government authorities, licensing and permits, and large-scale renovation projects. Work spans launching new glamping facilities through to repositioning existing ryokan, consistently covering everything from pre-opening preparation to stabilizing operations. At TLL, oversees accommodation business operations and leads pre-opening preparation for new properties.

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Publisher
TLL合同会社宅地建物取引業 東京都知事(1)第108202号住宅宿泊管理業 国土交通大臣(01)第F03424号

Data in this article cite their source and as-of date. Market conditions and regulations change, so check the latest information and consult a professional before deciding. Translated from the Japanese original.

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Minpaku and ryokan rules in other wards

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