The Legal Duties That 'Keep Going' — Filing Is the Start, Not the Finish
A minpaku doesn't end at filing. Guest registry, signage, periodic reports, and hygiene and safety measures continue throughout operation. Neglect them and you risk administrative guidance or a suspension order.
Once your housing accommodation notification is accepted, you can begin operating — and from there, continuing legal duties as an operator kick in. Creating and retaining a guest registry, posting signage, filing periodic reports, and ensuring guest safety and hygiene all must be maintained throughout operation.
The short answer: the main operating duties are four pillars — the guest registry, signage, periodic reports (every 2 months), and hygiene/safety/foreign-guest measures. Host-absent operators can delegate these to a housing accommodation manager, substantially reducing the owner's burden.
This article organizes the full picture of operating duties and where people stumble. For pre-filing procedures, see the Startup & Permits series (parts 1-3) on this site.
What Are the Continuing Duties During Operation?
The Housing Accommodation Business Act imposes continuing duties on operators even after filing: keeping a guest registry, posting signage, filing periodic reports to the prefectural governor, ensuring guest hygiene and safety, ensuring comfort and convenience for foreign guests, and considering neighboring residents. In host-absent operation, the manager performs the duties defined by law under delegation.
Main continuing duties during operation
- Create, keep, and retain the guest registry (contents and retention period set by law)
- Post signage (notification number, etc.)
- Periodic reports (every 2 months; by the 15th of even months, covering the prior 2 months)
- Hygiene measures (capacity management by room floor area, cleaning, etc.)
- Safety measures (emergency lighting, marked escape routes, response to fire and emergencies)
- Comfort and convenience for foreign guests (facility guidance in foreign languages, etc.)
- Handling complaints from neighboring residents
The Operating Duties — The 4 Pillars in Detail
Guest registry
Create a registry recording each guest's name, address, occupation, etc., and retain it for the period set by law. For foreign guests, nationality and passport-number verification is also required. Keep it in a state you can present on request from the authorities.
Signage
You must post signage bearing the notification number and contact details in a place visible to the public. In host-absent operation, the manager's information is also relevant. Follow the format set by law and municipal guidance.
Periodic reports
Report the number of days the dwelling was provided, guest count, total guest-nights, and nationality breakdown to the prefectural governor every 2 months (by the 15th of even months, covering the prior 2 months). This ties directly into managing the 180-day cap.
Hygiene, safety, and foreign-guest measures
Maintain, throughout operation, guest-count management by room floor area and cleaning (hygiene), emergency lighting, escape-route marking, and emergency response (safety), and foreign-language facility guidance (comfort).
Neighbor consideration and complaint handling
You must maintain consideration for neighbors regarding noise and garbage, and a system for handling complaints and inquiries. In host-absent operation, the manager serves as the first point of contact, reducing the owner's burden.
Where Operators Stumble
Operating duties are not 'set up once and done' — they must be maintained in daily operation. The following need particular care. Verify the formal contents, formats, and retention periods against the latest law and municipal guidance.
Identity verification and foreign-guest handling in the registry
Verify each guest's identity at check-in and record it accurately in the registry. Foreign guests require passport verification. In host-absent operation where in-person is difficult, ICT-based identity verification (e.g., video calls) becomes important in practice.
Don't skip identity verification even with unmanned check-in — build it into the flow.
180-day day management linked to periodic reports
Housing accommodation is capped at 180 days a year. Record daily operating results accurately and reflect them in the bimonthly report. Neglecting day management risks exceeding the cap (illegal operation).
Unify reservation management and day counting, and close out backward from the report deadline (15th of even months).
Posting signage and keeping its contents current
Signage isn't done once posted — its contents (notification number, contact, manager information) must be kept current. Update promptly when contacts change.
If the manager or contact changes, update the signage too.
Maintaining complaint and emergency response
Maintain a system that can respond appropriately to guests, neighbors, and authorities in late-night noise complaints, equipment trouble, or fire/sudden-illness emergencies. In host-absent operation, the manager handles this first response.
Secure a 24-hour contact/response route and state it clearly on signage and guidance.
6 Steps to Run the Legal Duties During Operation
Identity verification and registry entry at check-in
Verify the guest's identity and record name, address, occupation, etc. For foreign guests, verify nationality and passport number.
Record operating days and manage the 180-day cap
Record the days provided daily and track remaining days against the annual 180-day cap.
Maintain hygiene and safety measures
Maintain hygiene measures such as cleaning and capacity management, and safety measures such as escape-route marking and emergency response, throughout operation.
Complaint and emergency response
Provide first response to neighbor complaints and guest emergencies. In host-absent operation, the manager serves as the contact point.
Submit periodic reports (every 2 months)
By the 15th of even months, report the prior 2 months' operating results (days, headcount, nationality breakdown, etc.) to the prefectural governor.
Retain the registry and maintain the signage
Retain the guest registry for the period set by law and keep the signage contents current.
Basic Numbers of Operating Duties
Three numbers to remember
Periodic-report frequency (by the 15th of even months, covering the prior 2 months)
Annual operating cap (kept via daily registry and day management)
The period for which registry, signage, and safety-measure duties continue
Frequently Asked Questions
1. What goes into the guest registry?
Each guest's name, address, occupation, etc., with nationality and passport-number verification also required for foreign guests. Retain the registry for the period set by law and keep it presentable on request. Verify the exact contents and retention period against the latest law and municipal guidance.
2. How often are periodic reports?
Every 2 months. By the 15th of even months (Feb, Apr, Jun, Aug, Oct, Dec), report the prior 2 months' operating days, guest count, total guest-nights, and nationality breakdown to the prefectural governor (in principle via the Minpaku Operating System).
3. Must I post signage?
Yes. You must post signage bearing the notification number and contact details in a place visible to the public, and keep its contents (contact, manager information, etc.) current. Follow the format set by law and municipal guidance.
4. Must I perform these duties myself in host-absent operation?
In host-absent operation, you delegate the duties defined by law to a housing accommodation manager. We handle guest-registry management, periodic reports, hygiene/safety measures, and first-response to complaints as practical work, greatly reducing the owner's burden. StayJP accepts delegation as MLIT-registered manager No. F05636.
5. How do I keep from exceeding 180 days?
Record daily operating results accurately and reflect them in the bimonthly report. Unifying reservation management and day counting prevents overruns. To run year-round beyond 180 days, you must switch to ryokan or Special Zone Minpaku (see the Startup & Permits series / 180-day-rule article).
Takeaway: Filing Is the Start — Run Operating Duties as a System
Even after filing, housing accommodation carries continuing duties throughout operation: guest registry, signage, periodic reports (every 2 months), and hygiene/safety measures. Building them into daily operation as a system is the only way to avoid administrative guidance or a suspension order.
- Create and retain the guest registry; verify passports for foreign guests
- Post signage and keep its contents current
- Periodic reports are every 2 months (by the 15th of even months, prior 2 months)
- Maintain hygiene, safety, foreign-guest, and complaint response throughout operation
- Strictly keep the 180-day cap via daily day management
These operating duties can be delegated to a housing accommodation manager in host-absent operation. As MLIT-registered manager No. F05636, StayJP continuously accepts the operating legal duties — guest-registry management, periodic reports, hygiene and safety measures, and first-response to complaints.