AIAIG观点
The 180-day cap has not been abolished, but in practice, it is often reshaped by 'system path switching' and 'stricter local rules,' leading many investors to perceive the restrictions as weakened. This article uses a three-tier model (national law → local regulations → building rules) to explain the sources of differences and provides a reusable compliance checklist and investment strategies.
Many investors have observed a contradiction in Tokyo, Osaka, and Kyoto: legally, it's up to 180 nights per year, but the market is flooded with listings and operational models that 'appear to operate year-round.' Is it regulatory relaxation, insufficient enforcement, or have operators found ways to 'circumvent' it through compliant paths and local rule differences? This article uses institutional patchwork + local implementation variations to break down the issue clearly and provides actionable judgment methods for cross-border investors.
The so-called "180-day restriction" refers to the annual limit of 180 days (180 nights) for providing accommodation under the "Housing Accommodation Business Act" (commonly known as the "Minpaku New Law").
The key point is: short-term rentals/guesthouses in Japan are not limited to this single path.
In practice, common compliant accommodation supply paths in Japan include at least:
Therefore, the first-level answer to "whether the 180-day restriction is being weakened" is: The restriction remains, but many operators are not operating under the same legal framework.
When the investment goal is "more stable annual cash flow," the most common practice is to switch to a Hotel Business Law permit (e.g., simple lodging). This shifts the operational logic from "residential-type shared accommodation" to something closer to "accommodation business operation," thereby in most cases no longer being directly constrained by the 180-night limit, but compliance costs, property conditions, and operational difficulty significantly increase.
Many local governments impose stricter operational time/area restrictions on top of the Minpaku New Law, resulting in actual available operating windows being far below 180 nights.
Enforcement is not absent but increasingly manifests as a governance chain of "complaint – verification – rectification/delisting." Media reports show that relevant authorities request platforms to delist illegal/non-compliant property information, meaning compliance information disclosure and platform rules are becoming part of the substantive constraints.
Conclusion: The perceived "weakening" by investors is usually not the disappearance of the 180-night rule but rather its reshaping by "path switching + stricter local regulations + platform governance."
Understanding Japan's minpaku (private lodging) regulation as a three-layer overlay allows you to quickly assess the 'real operational space' for a city, a district, or even a building.
Local governments can impose further restrictions on operating areas and times based on factors such as residential environment, proximity to schools, and residential zoning. The result is that different areas within the same city may have completely different operational windows.
Even if national and local regulations permit it, apartment management regulations may prohibit short-term rentals; this can shift you from 'compliant and feasible' directly to 'practically impossible'. This is the risk most easily overlooked by cross-border investors.
Key to Investment Judgment: Don't ask 'Is Japan 180 days?', ask what is the final outcome for your asset after considering the three-layer overlay.
By following the sequence below for verification, you can essentially filter out most projects that 'look good on paper':
Is the 180-day limit being abolished?
Why do many listings appear to be able to "operate year-round"?
How significant are the differences in local enforcement?
How do platform removals and complaint management affect investments?