Ryokan Business Facility Standards Explained: Ventilation, Lighting, and Guest Registry Requirements for Simple Lodgings

Facility Standards Under the Hotels and Inns Business Act: The Big Picture for Simple Lodging Requirements

Facility standards under the Hotels and Inns Business Act and the licensing process for simple lodging (kan’i shukusho) are often the first hurdle owners face when starting a minpaku business. The Hotels and Inns Business Act (officially the “Ryokan Gyōhō,” Act No. 138 of 1948) sets out minimum structural and facility standards for each category of business, and “simple lodging operations”—the category most minpaku properties aim for—comes with its own specific requirements. This is a completely separate licensing framework from the Private Lodging Business Act (the so-called “minpaku shinpō”), and confusing the two during the application process is a common reason applications get sent back by the local health center.

Facility Standards for Simple Lodging: Ventilation, Lighting, and Guest Room Size Requirements

Total Floor Area of Guest Rooms

Article 1 of the Enforcement Order of the Hotels and Inns Business Act sets the minimum total floor area for guest rooms in simple lodging operations at 33 square meters or more. However, there’s a relaxation clause: if the property accommodates fewer than 10 guests, the requirement can instead be calculated as 3.3 square meters multiplied by the maximum guest capacity. In practice, many local governments impose even stricter standards through their own ordinances, so it’s essential to check directly with the relevant health center before proceeding.

Ventilation Facilities

The Enforcement Order requires guest rooms, hallways, restrooms, and similar spaces to be equipped with adequate ventilation systems. The specific figures for air exchange rate and airflow volume are assessed in line with the ventilation requirements under the Building Standards Act (generally, a ventilation opening equal to at least 1/20 of the floor area, or mechanical ventilation as an alternative). In one case we handled, an older detached house relied solely on natural ventilation for the bathroom fan, which was flagged during the health center’s on-site inspection—requiring the retrofit of a mechanical ventilation system. Construction costs for this kind of fix can range from tens of thousands to several hundred thousand yen depending on the building’s structure, and can significantly delay your timeline. Skipping a thorough pre-application survey can push back your opening date considerably.

Natural Lighting Facilities

Guest rooms must have proper lighting facilities, such as windows that allow natural light from outside. The Enforcement Order requires “lighting and illumination facilities” to be in place, and this is cross-checked against the natural lighting rules under Article 28 of the Building Standards Act (generally, an effective lighting area equal to at least 1/7 of the room’s floor area). If you try to count a room with no window providing natural light as a guest room, it may be excluded during the health center’s review.

Other Facility Requirements

Fire-fighting equipment is governed separately under the Fire Service Act, so consulting and coordinating with the local fire department is a required step alongside your hotels and inns business license application. Standards for the number of wash basins and toilets, based on guest capacity, are also set out in the Enforcement Order. Additionally, some local ordinances add further requirements, such as rules regarding front desk operations or key management.

Legal Requirements and Practical Management of the Guest Register

Required Entries and Retention Obligations

Article 6 of the Hotels and Inns Business Act requires operators to maintain a guest register and record certain information. The main items that must be recorded are the guest’s name, address, occupation, and dates of stay. For foreign guests, nationality and passport number are also required. Under the Enforcement Regulations, records must be retained for three years, and can be kept either on paper or electronically.

Managing This With Unstaffed Operations and Smart Locks

Now that self-check-in has become the norm, deciding who collects guest register information—and at what point—is a critical operational issue. Since information entered through online booking platforms alone doesn’t satisfy the requirements in some jurisdictions, more properties are setting up dedicated forms or identity verification systems to collect the necessary details before check-in. For properties we manage on our clients’ behalf, we’ve standardized a process where, once a booking is confirmed, we send guests a message asking them to complete the required information at least 24 hours before check-in. This prevents gaps in the guest register while keeping the workload on owners to a minimum.

Local Government Add-On Requirements to Check Before Applying

The facility standards under the Hotels and Inns Business Act represent only the nationwide baseline—many prefectures and municipalities add their own extra requirements through local ordinances and guidelines. For example, you’ll also need to check for things like a change-of-use notification under the Fire Service Act, and restrictions based on zoning (in some zoning categories under the City Planning Act, operating a hotels and inns business isn’t permitted at all). Applications are submitted to the health center of the relevant prefecture, government-designated city, or core city, but consulting in advance with the fire department, building department, and city planning department can help reduce the risk of your application being rejected or sent back.

Free Consultation With Stay Buddy Inc.

Facility standards for the hotels and inns business and the licensing process for simple lodging require checks across multiple agencies—health centers, fire departments, and building authorities—and the right approach varies significantly depending on the specifics of each property. We regularly hear from owners who tell us, “I don’t know who to even ask,” or “I can’t tell what’s missing from our facilities.”

At Stay Buddy Inc., we provide end-to-end support, from helping with license applications to handling day-to-day operations, cleaning coordination, and guest support once you’re up and running. If you’re already operating a property and have concerns about your guest register management or facility compliance, we can help you start by simply assessing your current situation.

In your first free consultation, we’ll ask about your property’s situation and give you clear, concrete guidance on what to tackle first. Feel free to reach out through the contact form on our website or by phone—we’re happy to help.