As the minpaku (vacation rental) market continues to expand, more property owners and management companies are looking to leverage the “Special Zone Minpaku” framework to operate properties with fewer legal restrictions.
Osaka City, in particular, adopted the Special Zone Minpaku system relatively early, making it an attractive option for hosts by allowing minpaku operations without the 180-day annual limit. However, Special Zone Minpaku differs from the standard Private Lodging Business Act (the so-called “Minpaku New Law”) in several key requirements, and a major point to note is that operators must satisfy unique building code and fire safety conditions.
In particular, when it comes to building code requirements, many people wonder things like “What kind of property qualifies for Special Zone Minpaku certification?” or “How strict are the fire prevention and structural requirements?” This article provides an easy-to-understand explanation of the main building code requirements that must be met to operate Special Zone Minpaku in Osaka City. Since ordinances and guidelines can change over time, you should always confirm the latest details with the relevant government authority. That said, understanding the overview here should help your property selection and renovation planning go more smoothly.
1. What Is Special Zone Minpaku in Osaka City?
1-1. A Framework Based on National Strategic Special Zones
Special Zone Minpaku is a lodging business format that operates within National Strategic Special Zones designated by the national government.
In Osaka City, this framework allows for more flexible minpaku operations by establishing its own ordinance and requirements, freeing operators from the 180-day annual operating limit imposed under the Minpaku New Law (Private Lodging Business Act). However, this greater flexibility comes with the need to fully satisfy building, fire safety, and sanitation standards—and if these requirements are not met, the property cannot receive Special Zone Minpaku approval (certification).
1-2. Differences from the New Law
Under the New Law (Private Lodging Business Act), the assumed model is one where a residence is used as a home while also providing short-term lodging, and operation is prohibited beyond 180 days per year. In contrast, Osaka City’s Special Zone Minpaku framework exempts properties from the 180-day operating restriction as long as the standards set out in the ordinance are met, making essentially year-round lodging operations possible.
This makes it an extremely appealing framework for hosts seeking to maximize profitability in Osaka City, where tourism demand is high.
1-3. Compliance with Building Codes Is Mandatory
However, Special Zone Minpaku requires not only compliance with “residential regulations” but also a degree of consideration for fire prevention and other requirements similar to those for the hotel and inn business (ryokan gyo), which tends to raise the bar for meeting building code requirements. To determine whether a given building is suitable for Special Zone Minpaku when selecting a property, it’s essential to have a solid understanding of the building requirements set forth in the ordinance.
2. Key Building Code Requirements for Special Zone Minpaku
2-1. Zoning and Structural Requirements
For Special Zone Minpaku in Osaka City, it’s necessary to check whether the zoning designation of the property falls within the eligible area, and whether the building’s structure and number of floors meet the required standards. For example, in fire prevention districts or quasi-fire prevention districts, additional fireproof structural requirements may apply depending on the location, so caution is needed.
- Building use: Since the building is expected to be used both as a residence and as lodging facility, consultation with the local building authority (specified administrative agency) may be required
- Number of floors and floor area: For buildings above a certain size, safety measures at a level comparable to the hotel and inn business are often required, such as mandatory installation of evacuation routes and emergency exits
2-2. Minimum Floor Area and Room Size
Under Special Zone Minpaku rules, there are cases where a minimum size and level of facilities are required for guests to stay overnight. Specifically, it is common for ordinances to specify a minimum, such as a floor area of at least XX square meters per room. If a small property does not meet this threshold, it may be difficult to apply for Special Zone Minpaku certification without renovation or expansion.
2-3. Sanitation Facilities and Water/Sewer Requirements
To accept guests as a minpaku property, you must satisfy requirements regarding the appropriate number of toilets and bathrooms, hot water facilities, and connection status to the sewer system. For older properties where plumbing renovations have been neglected, investment in remodeling may be necessary in order to meet Special Zone Minpaku requirements.
3. Fire Prevention and Fire Safety Requirements to Meet
3-1. Fire Extinguishing Equipment and Evacuation Routes
Even under Special Zone Minpaku, since guests will be staying overnight, it’s essential to comply with the Fire Service Act and fire prevention standards. The following points are commonly checked in particular.
- Installation of fire extinguishers: The required number and placement are determined based on the building’s size, number of floors, and intended use
- Automatic fire alarms: Even for small properties, fire alarms may be required in bedrooms, stairwells, and other locations
- Evacuation hatches and emergency exits: If the second floor or above is used for lodging purposes, an evacuation hatch or an escape route via a balcony may also be required
3-2. Interior Restrictions and Flame-Resistant Treatment
Additionally, from the perspective of the Building Standards Act and Fire Service Act, flame-resistant treatment may be required for interior materials and fabric items such as curtains and carpets. In particular, for properties accommodating a large number of guests, or those with extensive common areas outside the guest rooms, measures such as using flame-resistant products or installing fire compartments may be required.
3-3. Fireproof and Quasi-Fireproof Building Structure
For large-scale properties that fall under specific use categories (i.e., those with substantial total floor area or many stories), or in cases where the building’s usage is judged to be similar to the hotel and inn business, the building itself may be required to have a fireproof or quasi-fireproof structure. In many cases, simply renovating a detached house is not sufficient, and structural remodeling may be necessary.
4. Consideration for Noise and Odor, and Measures for Neighboring Residents
4-1. Noise Impact and Soundproofing
Detached house-type properties are often assumed to have fewer noise problems than apartment buildings, since there are no shared walls, floors, or ceilings with other residents’ units. However, when the property is located close to neighboring homes, sound leakage issues can still remain a concern. Even if you’re within the bounds of the ordinance and building code, prolonged loud noise at night carries a risk of complaints from neighbors.
- Sound-insulating sashes and windows: Installing double-glazed sashes or soundproof curtains
- Rules for indoor parties: Providing guidance to keep noise down after 10 PM
4-2. Odor Issues and Ventilation
While this may not be directly included in the Special Zone Minpaku requirements, when guests frequently cook in the kitchen, inadequate ventilation equipment can allow odors to build up and cause inconvenience to nearby residents. Particularly for detached houses in densely populated areas, it’s important to take measures such as considering exhaust direction and ducting during operation.
5. Application Process Flow and Important Considerations
5-1. Preliminary Consultation and Drawing Preparation
When applying for Special Zone Minpaku, the first step is to consult with the relevant city hall department or a specialist to confirm whether your property meets the applicable requirements. After that, you’ll need to gather the necessary documents, such as the building’s floor plans and elevation drawings and a fire safety plan. When requirements are strict, it’s common to enlist the help of an architecture firm or an administrative scrivener (gyoseishoshi) to support document preparation.
5-2. On-Site Inspection and Review
Once the document review has progressed to a certain stage, an on-site inspection may be conducted. This checks whether the property complies with building codes and fire safety equipment requirements, and if issues are found, you may be asked to make corrections or install additional equipment. It’s important to prepare your property thoroughly in advance and be ready to explain things smoothly in person.
5-3. Operations and Renewal After Certification
Once certified, you can begin operating as a minpaku property, but neglecting facility maintenance after starting operations carries the risk of having your certification revoked. In particular, you must continue to comply with the ordinance on an ongoing basis, including regular inspections of fire safety equipment and reapplication if the building undergoes expansion or remodeling.
6. Conclusion: Understanding Building Codes Is Key to Success with Special Zone Minpaku
Unlike the New Law, Osaka City’s Special Zone Minpaku framework has no limit on annual operating days, making it an appealing option for hosts hoping for higher earnings. However, this comes with building code and fire safety hurdles that are far from trivial. You’ll need to check off a wide range of requirements one by one—fire prevention district rules, room size requirements, sanitation facilities, evacuation routes, and more—and carry out renovations or remodeling as needed in order to create a safe, legally compliant Special Zone Minpaku property.
Above all, in order for guests to stay with peace of mind, an environment with properly installed fireproofing, evacuation equipment, and sanitation management is indispensable. Rather than treating building codes as mere paperwork requirements, approach them as the foundation for ensuring guest safety and satisfaction—doing so properly will ultimately lead to better reviews, more repeat guests, and higher revenue. If you’re considering Special Zone Minpaku, we recommend consulting with government authorities and specialists as early as possible, and preparing thoroughly based on your property’s characteristics and renovation plans so that you can obtain certification smoothly.
For Special Zone Minpaku Consultations, Contact Stay Buddy Inc.!
If you’re an owner or management company with questions about building codes, fire safety measures, cleaning, staff management, or any other aspect of Special Zone Minpaku or minpaku operations in general, please don’t hesitate to contact Stay Buddy Inc.
Drawing on our track record of leading numerous minpaku properties to success, we provide comprehensive consulting services—including renovation proposals tailored to building and fire safety requirements, support with document preparation, and sharing of operational know-how. Let’s work together to leverage Special Zone Minpaku in Osaka City and pursue stable, year-round profitability.
