Statutory operations for minpaku owners

Minpaku operating duties are divided between the owner and the manager

Do not bundle guest records, signage, periodic reports, hygiene, safety, and complaints together. Confirm who is responsible and where each record goes.

After notification, a minpaku still requires guest records, hygiene and safety measures, guidance for foreign guests, neighborhood notices, complaint handling, signage, and a report of accommodation results every two months. The same party does not perform every duty.

Bottom line: when management is entrusted under Article 11, work under Articles 5–10 is performed under the manager's responsibility. Signage at the notified residence and the bi-monthly report to the prefectural governor or other authority remain with the owner as the residential accommodation operator.

This guide uses Japan Tourism Agency's Minpaku Portal to map responsibilities and reporting paths. Also confirm the property's notification, local rules, and management contract with the authority for its location or a qualified professional.

First separate owner duties from management work

Where entrustment is required, the registered residential accommodation manager handles Articles 5–10 duties and contracted property maintenance. The owner retains operator duties such as notification details, signage, accommodation-day control, and government reporting. If the manager holds reporting data, the contract should define how it is provided to the owner.

Main responsibilities to assign

  • Owner: maintain notification details and the 180-day limit for each notified residence
  • Owner: display and maintain the required sign at the notified residence
  • Owner: report the preceding two months of accommodation results by the 15th of each even-numbered month
  • Manager: hygiene, safety, and guidance for foreign guests at the contracted residence
  • Manager: guest identity checks and creation and maintenance of the guest register
  • Manager: required explanations to guests and response to neighborhood complaints
  • Both: define the records, frequency, and format the manager provides to the owner

Five continuing duties by responsible party

1

Guest register and identity checks

For an entrusted property, the manager is responsible for identity checks and creating and maintaining the guest register. The contract should also state how data required for the owner's government report is shared.

2

Sign at the notified residence

The owner, as residential accommodation operator, displays the prescribed sign at each notified residence and keeps the notification number and contact details current. This is separate from the sign the manager displays at its office.

3

Bi-monthly accommodation report

By the 15th of each even-numbered month, the owner reports the preceding two months' accommodation days, guest count, total guest-nights, and breakdown by nationality. The manager provides source records as agreed in the contract.

4

Hygiene, safety, and foreign-guest guidance

At an entrusted property, the manager is responsible for cleaning and ventilation, occupancy, safety equipment, evacuation information, and required multilingual facility and transport guidance. Methods and costs are set in the contract.

5

Guest explanations and complaint response

Guests must receive necessary information on noise and waste, and neighborhood complaints must be handled. Reception hours, contact channels, onsite dispatch, and extra charges are separate contract conditions.

Four boundaries owners often confuse

The same words—report, sign, and response—can refer to different recipients and responsible parties. Separate these boundaries before contract.

Government report vs manager's report to the owner

The owner submits accommodation results every two months to the authority. The manager reports management performance to the owner after the owner's fiscal year and after the management contract ends.

Record the recipient, deadline, preparer, and submitter separately.

180-day control vs reservation data

The 180-day limit applies to each notified residence. Reconcile reservations with actual accommodation dates and assign who totals the data and who gives final approval.

Reflect cancellations and date changes and use the same source records for the government report.

Residence sign vs manager's office sign

The owner displays the operator sign at the notified residence. A registered manager displays a different registration sign at its registered office.

Do not treat the property sign and the management company's office sign as the same document.

Complaint response vs emergency onsite dispatch

A statutory complaint-response structure is not the same as sending someone onsite for a night incident or equipment failure. StayJP's emergency local response is confirmed under contract for the 30%+ plan.

Separate reception hours, dispatch conditions, service area, approval, and extra cost in the contract.

Six steps to align responsibility and records

1

Confirm notification and whether entrustment is required

Check the notified residence, owner presence, number of rooms, and current management contract.

2

Write management work and methods into the contract

Confirm how hygiene, safety, foreign-guest guidance, the register, guest explanations, complaints, and property maintenance will be performed.

3

Record identity checks and the guest register

Verify guests and record name, address, occupation, and required information for foreign guests.

4

Reconcile accommodation days and reporting data

Match reservations, changes, cancellations, and actual stays to confirm days and guests for each notified residence.

5

Owner submits the bi-monthly report

By the 15th of each even-numbered month, the owner reports the preceding two months to the prefectural governor or other authority.

6

Update signs, contracts, and permissions

When contacts or managers change, check whether notifications, signs, OTA permissions, and the management contract must also change.

Key deadlines and standards

Three standards to track during operation

Every 2 months

Owner reports accommodation results to the authority

180 days

Limit from noon April 1 to noon the following April 1

Defined by contract

Manager's work and owner's remaining submissions and approvals

Confirm responsibilities and deadlines in official sources

Responsibilities are mapped from Japan Tourism Agency's Minpaku Portal. Laws and government guidance may change, so check the current versions during operation.

Checked: August 20, 2026

Common questions about ongoing duties

1. What goes into the guest register?

Record each guest's name, address, occupation, and other required details. For foreign guests without an address in Japan, confirm nationality and passport information. Check the current rules and management contract for identity checks, entries, and storage.

2. Who submits the report every two months?

The owner, as residential accommodation operator, reports the preceding two months to the prefectural governor or other authority by the 15th of each even-numbered month. If the manager holds the guest and stay data, define delivery timing and format in the contract.

3. Who maintains the sign at the notified residence?

The owner displays the prescribed sign at the notified residence while operating the business. It is separate from the registration sign displayed by the management company at its office.

4. Can the owner perform individual tasks for an owner-absent minpaku?

Where entrustment is required, the entire residential accommodation management work is entrusted to one registered manager. Individual tasks may then be performed by the owner under the manager's responsibility, so define the executor, instructor, records, and costs in the management contract.

5. What if the owner wants to operate for more than 180 days?

A notification under the Private Lodging Business Act does not allow operation beyond 180 days. Hotel-business and special-zone systems are separate and require the property to meet their conditions and obtain the necessary permit or certification. StayJP does not file permit or notification applications.

Summary: manage each duty with its responsible party and recipient

Guest registers, signage, periodic reports, hygiene, safety, and complaints are all minpaku operations, but they have different responsible parties and recipients. After entrustment, confirm the owner's remaining filings, displays, approvals, and costs in the contract and operating sheet.

  • The manager performs Articles 5–10 work under its responsibility
  • The owner handles residence signage and bi-monthly government reporting
  • The contract defines how the manager supplies data to the owner
  • Complaint response and emergency onsite dispatch have separate conditions
  • The 180-day limit is tracked from actual results for each notified residence

As a registered residential accommodation manager, StayJP accepts statutory management work only after confirming the property and delivery method in the management contract. We also identify the owner's remaining reports, signage, approvals, and cost responsibility.

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