Is Minpaku and Ryokan Business Possible in Toshima Ward? Planned Revision to 120 Days for Minpaku and Face-to-Face Key Handover for Simplified Lodging
In Toshima Ward, moves are underway to strengthen regulations for both the Minpaku New Law (Residential Lodging Business Act) and ryokan business (simplified lodging under the Ryokan Business Act [旅館業法]). According to materials published by the ward, the ordinance revision scheduled to take effect on December 16, 2026, will reduce the annual operating days for minpaku from 180 days to 120 days, concentrating the periods during which operation is allowed around summer vacation and year-end to New Year holidays.
This revision will apply not only to new facilities but also retroactively to facilities already in operation. Those operating minpaku in Toshima Ward or considering purchasing such properties currently in operation need to reassess their revenue and expenses based on the revised number of days.
For ryokan business, in addition to the currently required installation of a front desk and face-to-face key handover, resident staffing is expected to be required by the end of 2026. Since Toshima Ward is not a designated area for the National Strategic Special Zone Minpaku (国家戦略特区民泊), only these two systems are available to choose from.
The regulatory information in this article is organized based on our confirmation with the health center and publicly available ward materials (as of July 2026).
Quick Reference for Toshima Ward Minpaku and Ryokan Business Regulations
| Category | Item | Content |
|---|---|---|
| Ryokan Business (Simplified Lodging) | Front Desk (Entrance Reception) | Required |
| On-site Response Requirement | Within 10 minutes → Resident staff (by end of 2026) | |
| Notification to Neighbors | Flyers (Posting door-to-door) | |
| Key Handover | Face-to-face | |
| Minpaku New Law (Residential Lodging Business) | Additional Ward Ordinance | [Enforcement from 2026/12/16] Annual operating days limited from 180 to 120. Operating periods concentrated during 7/1–8/31, 12/20–1/10, etc. Applies retroactively to existing facilities |
Minpaku New Law (Residential Lodging Business): Planned Revision to 120 Days Annually
The Minpaku New Law operates under a notification system with a nationwide limit of 180 days annually. For absentee homeowners, entrusting a residential lodging management operator (住宅宿泊管理業者) is mandatory. Toshima Ward plans to further restrict this limit by ordinance, with the contents shown in the ward’s public comment draft as follows.
| Item | Revised Content (Scheduled Enforcement December 16, 2026) |
|---|---|
| Annual Operating Limit | 180 days (nationwide rule) → 120 days |
| Permitted Operating Period | Concentrated around July 1–August 31, December 20–January 10, etc. |
| Applicable Facilities | Applies not only to new but also existing facilities |
The two example periods cited in the materials are 62 days for summer and 22 days for year-end/New Year holidays, totaling 84 days. Please check the finalized ordinance for details on how the remaining 36 days are allocated.
The impact on profitability will be greater than the reduction in days alone. Since the operation period is concentrated during busy seasons, there is an advantage in raising unit prices, but cleaning and operational staffing must also be concentrated in this period, leaving the property vacant at other times. In the case of leasing and subleasing, rent is paid for 12 months, while revenue may only be generated for about a third of the year.
The content may be revised following public comments. Confirm the latest enforcement status and any transitional measures with the ward’s relevant department.
Ryokan Business (Simplified Lodging): Front Desk and Face-to-Face Key Handover Required
Ryokan business requires permission (permit system) and there is no annual limit on operating days. When the Minpaku New Law days are restricted to 120, ryokan business will be the only option for year-round operation in Toshima Ward. However, the operational requirements are not light.
- Entrance reception (front desk): Required installation
- Key handover: Must be done face-to-face with guests. Non-face-to-face handover by key box or smart lock is not envisaged
- On-site response: Currently within 10 minutes. Confirmation with the health center found that using a nearby rental office as an on-site response base is allowed, and a 24-hour response system is required
- Notification to neighbors: Flyers distributed door-to-door are the standard. In some locations within the ward, explanatory meetings may be necessary
Because face-to-face key handover is required, staff will leave the base to meet guests during check-in times. If accepting late-night arrivals, it is easier to manage if the base is located very close to the facility.
Moreover, an ordinance revision expected within 2026 requires resident staffing, which will necessitate establishing a resident room inside the facility (as of the investigation for this article). The reservation of space for a resident room reduces the number of guest rooms and adds labor costs as fixed expenses, making profitability more difficult for small-scale facilities. Please confirm the timing and details of the revision with the ward.
Toshima Ward Property Market Prices (August 2026)
| Indicator | Toshima Ward | Ranking among 23 Wards |
|---|---|---|
| Median Price of Houses on Sale | 94.8 million yen (61 listings, total floor area 86㎡) | 10th highest out of 21 wards |
| Median Rental Price for Houses | 290,000 yen/month (49 listings, 78㎡) | 6th highest out of 21 wards |
| Median Gross Yield for Entire Income Properties | 4.8% (97 listings) | 11th highest out of 23 wards |
Source: Urbalytics Market Report (Toshima Ward). Median values of properties listed for sale or rent as of August 2026. Indicators with fewer than 10 listings are not shown.
The rental asking price for houses in Toshima Ward ranks high among the 23 wards, which increases fixed costs for leased-and-subleased type minpaku. As mentioned above, the revised Minpaku New Law limits revenue-generating periods to about one-third of the year, making it difficult to balance income and expenses for the sublease type minpaku.
The median listing price for houses and the gross yield of entire income properties are both mid-ranking among the 23 wards. When comparing owning and do year-round operation as ryokan business or running normal rentals, please calculate whether the rental yield after adding labor costs for front desk and resident staff is exceeded.
Points to Check When Considering Properties in Light of the Revision
- If considering under the Minpaku New Law, estimate revenues and expenses assuming 120 days annually and concentrated operation periods
- If purchasing a minpaku property currently in operation, do not judge the price assuming the same revenue will continue after the revision
- For ryokan business, check the land-use zone on the city planning map. Commercial operations are not allowed in exclusively residential, industrial, or industrial-exclusive zones; Class 1 Residential Zones (第一種住居地域) allow operation only for properties under 3,000㎡
- Check if the floor area allows securing guest rooms even after installing front desk and resident rooms
- If converting a residence, check for required changes of use and estimate costs to comply with Building Standards Act and Fire Service Act
- For condominiums, verify the management rules; for rental units, obtain written consent from the lessor for subleasing
In wards where minpaku operation days are restricted, whether to operate with concentrated busy-season earnings or year-round under ryokan business greatly changes the necessary system. The setup for operation including cleaning, guest support, and key handover is introduced on the Minpaku Operation Agency page.
Frequently Asked Questions
Will minpaku that has already been registered also be subject to the 120-day limit?
Documents from the ward state that the revised restrictions will also apply to existing facilities. The enforcement date is scheduled for December 16, 2026, but the content may be revised after public comments, so please confirm the finalized details with the ward department.
Can key boxes be used in simplified lodging in Toshima Ward?
No, they cannot. Toshima Ward requires installation of a front desk and face-to-face key handover to guests. Using a nearby rental office as an on-site response base is permitted, but a 24-hour response system is required.
When will resident staffing be required for ryokan business?
At the time of investigation for this article, it was expected that an ordinance revision within 2026 will require resident staffing. Please confirm the enforcement date and treatment of existing facilities with the ward before applying for permission.
Contact Points and Reference Materials
- Reference material: Public Materials from Toshima Ward
Compare with Other Wards
- Overview of Minpaku and Ryokan Regulations in Tokyo’s 23 Wards
- Suginami Ward Minpaku and Ryokan Regulations
- Kita Ward Minpaku and Ryokan Regulations
Ordinances and enforcement may change due to revisions and health center rulings. Please consult the relevant health center in advance before acquiring properties or making applications.
Featured image: MaedaAkihiko / Wikimedia Commons (CC BY-SA 4.0, cropped)
About this article
- Author
- Xingkai Luo（New Business）
A business development specialist with over 10 years of experience in urban real estate development and infrastructure investment. At Alibaba and Honeywell, he led large-scale redevelopment projects for major Chinese state-owned transportation operators and oversaw the implementation of smart building solutions. He is deeply familiar with the full development value chain, from due diligence, land acquisition, and structuring through post-completion asset management. At TLL, he leads new business development and project formation for overseas investors, advancing hotel, residential, and mixed-use developments.
View profile → - 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.
