The Air BnB host community in Japan will have recently received an email from Air BnB saying that they have until the 14th of June, 2018 to notify Air BnB of their hotel business license number. Failure to provide this number will mean that they are no longer able to rent out their properties using the platform. It is expected that this will dramatically reduce the number of private operators on the platform and ultimately, that the space they leave in the market will be taken up by commercial operators and hotel chains. Aside from increasing the concerns about what happens to the glut of new hotels and hostels after the Olympics has finished, many view the requirements to qualify for the license to be unreasonably hard to meet. Tellingly, the information outlining requirements is not available in English at this time. At present they are as follows:
Notify The Local Government
To receive your 住宅宿泊事業 (hotel operator) business license you will have to send a notification to your local government. To be approved you will have to meet certain requirements; submitting a floor plan of your property, illustrating that it has all of the necessary components to be livable (e.g, no bath = no go). You are also required to show how you are marketing the property, to ensure that the representations being made are truthful. At present, there are 20 pieces of information required in the application.
Meeting The Requirements
(1) Health Guarantees
 There must be 3.3㎡ or more of floor space available for each guest.
 The property must be regularly cleaned and ventilated (refer to the Hotel Operator health and safety guidelines (衛生等管理要領) for further clarification)
(2) Safety Guarantees
 You must provide emergency lighting equipment (e.g. torches) in the property
 You must provide a diagram documenting the way to exit the unit & building during an emergency (you’ve probably seen these on the back of your hotel room door before…)
 You must indicate what safety measures have been taken to protect the well-being of guests during emergencies other than fire
(3) Appropriateness For Foreign Visitors
Where your guests are tourists from overseas, you must be able to demonstrate the following:
 All equipment and facilities are available in the language of the guests
 Information regarding travel & access must be made available in the language of the guests (e.g getting to the property from the train station)
 Information regarding who to contact (and their contact details) during an emergency (fire, earthquake etc.) must be made available in the language of the guests
(4) Guest Registration
 Guest identity must be recorded after verification using a valid photo ID
 This information must be retained for 3 years after their stay
 Guest name, address & occupation must be included in records
 If the guest does not maintain a Japanese address, their passport number must also be recorded
(5) Local Area Trouble Prevention
The following explanations must be made to all guests prior to commencing their stay:
 Noise should not be made to the extent that it affects other residents
 The acceptable treatment and procedure for disposal of rubbish
 Necessary preventative measures to avoid a fire emergency
(6) Complaints Procedure
The Air BnB operator must respond to complaints and inquiries from other local residents within a reasonable time-frame
(7) Operator Responsibilities
Any hotel business operator must abide by the above rules if:
– they are operating more than 5 rental units/rooms
– they are not physically present at the property themselves during the period of stay. Absence for short periods of time, as would be reasonable under the conditions of “daily life” are acceptable, but the operator should otherwise remain on-site full-time if looking to avoid 住宅宿泊事業者 classification under the above guidelines.
(8) Third Party Agents
Where an operator has out-sourced or subcontracted a third-party to be involved with the business, these third parties must also adhere to the rules above.
Authorized properties must clearly display their authorisations so as to be visible from the outside.
(10) Intermittent Reporting
Operators must make declarations every two months (starting February), no later than the 15th of each month, to their local governments with updates on the following:
- how many days the property(/properties) have been rented out during the period
how many guests have been housed during the period
- how many guests are currently staying, extending beyond the current period
- what nationalities (including numbers) of guest have stayed during the period
Last year we asked “Is Air BnB in Japan Easy Money?”. The answer was “compared to what..?“. Air BnB operators are essentially independent business owners, so any profit must be weighed up against the expense and time inputted. What has become overwhelmingly apparent in the new regulations is that if somebody wishes to run what is essentially a private hotel business, then they are going to have to be held to the same standards and regulations as commercial hotel businesses. If these standards are outside of the scope of what a private operator is willing to do, then they are likely not providing the level of comfort and safety that Japan legally requires of its operators. In short, if it was “easy money” before, it certainly isn’t now.