How to Calculate the 180-Day Minpaku Limit and the Risks of Violating It

One rule that no minpaku (private lodging) operator can avoid is the 180-day annual operating limit set out under the Private Lodging Business Act (the “minpaku law”). If you don’t correctly understand how the 180-day limit is calculated, you could unknowingly end up violating the law and face administrative penalties as a result.

In this article, we’ll walk you through exactly how the 180-day limit is calculated, step by step, explain the penalties that apply if you exceed this limit, and share practical strategies for maximizing your revenue within the allowed days. Whether you’re just starting out in minpaku or already running an operation, this is essential information to review.

What Is the Minpaku 180-Day Limit?

The Operating Day Cap Under the Private Lodging Business Act

The Private Lodging Business Act, which came into effect in June 2018, limits the number of days a registered residence can be used for lodging services to 180 days per year. This figure is explicitly stated in Article 2, Paragraph 3 of the law and applies to every operator running a minpaku business under the registration system. Facilities that hold a license under the Hotel Business Act are not subject to this restriction, but registered minpaku properties must comply with it without exception.

The 180-day limit exists because of concerns that if minpaku properties were allowed to operate as full-scale hotels or inns, they would lose their character as residential dwellings. To preserve the idea that these are “homes” being used temporarily for lodging, the rule restricts operation to less than half the year.

Additional Restrictions Imposed by Local Ordinances

While the Private Lodging Business Act sets the cap at 180 days, local municipalities are permitted to impose even stricter limits through their own ordinances. For example, Shinjuku Ward in Tokyo prohibits operation in exclusively residential zones from Monday noon to Friday noon, which effectively limits annual operation to only about 52 days. Kyoto City similarly restricts operation in residential zones to roughly 60 days, from January 15 to March 15.

In other words, even though the law allows up to 180 days, local ordinances can significantly reduce the actual number of days you can operate. It’s essential to check the ordinances of the municipality where your property is located before acquiring or leasing it. Ordinance details can usually be found on the municipality’s website or by contacting the relevant department directly.

How to Calculate the Minpaku 180-Day Limit

The Counting Period Runs from April 1 to March 31 of the Following Year

The 180-day counting period runs for one year, from April 1 to March 31 of the following year. Note that this is not the calendar year (January to December). For instance, the period from April 1, 2024 to March 31, 2025 constitutes a single counting period, and the total number of days guests stay during that period cannot exceed 180. The count resets to zero when the new period begins on April 1.

Even if you register partway through the year, the starting point of the counting period doesn’t change. For example, if you register and begin operating on October 1, you have approximately six months, until March 31 of the following year, within which you must stay under 180 days. However, since there are effectively only about 180 days remaining in that window, operating every single day rarely causes you to exceed the limit. The situation that’s more likely to cause problems is when you’ve been operating since the first half of the fiscal year.

A “Day” Is Counted from Noon to Noon the Next Day

Under the 180-day rule, a single “day” is counted from noon (12:00 PM) to noon the following day. This is based on the concept of nights stayed, and the count is based on the number of nights a guest actually stays, not the check-in date. For example, if a guest checks in at 3:00 PM on Monday and checks out at 10:00 AM on Wednesday, this counts as one day from Monday noon to Tuesday noon, and another day from Tuesday noon to Wednesday noon, for a total of two days.

An important point here is that even if multiple guests turn over on the same day, that day is still counted as just one day. For example, if Guest A checks out at 10:00 AM on Tuesday and Guest B checks in that same day at 4:00 PM, the period from Tuesday noon to Wednesday noon still counts as only one day. There is no double counting.

How Counting Works for Properties with Multiple Rooms

For a single registered residence, the day count applies to the property as a whole, regardless of how many rooms it has. On the other hand, if you operate multiple properties with separate registration numbers, the 180-day limit applies individually to each property. For example, if Property A and Property B are registered separately, you can operate Property A for 180 days and Property B for 180 days, for a combined total of 360 operating days.

However, if multiple rooms within the same building are covered under a single registration, then as long as even one guest stays in any one of the rooms, that day counts as one operating day. In other words, having more rooms doesn’t increase your allowed number of operating days. To maximize revenue, you need to focus on increasing occupancy rate and room rates on the days you do operate.

A Practical Calculation Example

Let’s look at concrete numbers. Suppose you begin operating on April 1 and offer guests a two-night stay every Friday and Saturday. At two operating days per week, over roughly 52 weeks in the year, that comes to 2 days × 52 weeks = 104 days, which comfortably falls within the 180-day limit. If you add operation on holidays and weekdays during peak seasons to bring the annual total to around 150 days, you’d still have a 30-day buffer for safe operation.

On the other hand, if you operate every single day, you’ll hit the 180-day limit around the end of September, counting from April 1. This means you’d be completely unable to operate for roughly the second half of the fiscal year, from October onward, missing out on peak seasons like the year-end/New Year holidays and cherry blossom season (March). As this shows, how you allocate your 180 days across the year has a major impact on your revenue.

Risks and Penalties for Operating Beyond 180 Days

Administrative Business Suspension Orders and Registration Revocation

If you operate beyond the 180-day limit, the prefectural governor (or the head of a designated city or core city) may issue a business improvement order. If you fail to comply with the improvement order, you could face more severe penalties, such as a business suspension order or revocation of your registration. Once your registration is revoked, re-registering takes a certain amount of time, during which your income would be completely cut off.

The government tracks the number of operating days at each property through the minpaku registration system. Operators are required to submit periodic reports every two months, reporting the number of operating days and guests to the prefectural governor. Failing to submit this report, or submitting false information, can result in a fine of up to 300,000 yen.

Potential Penalties Under the Hotel Business Act

Providing lodging services beyond the 180-day limit falls outside the scope of the Private Lodging Business Act and may be treated as unlicensed operation under the Hotel Business Act. Unlicensed operation under the Hotel Business Act carries a penalty of up to six months’ imprisonment, a fine of up to 1 million yen, or both — a much harsher penalty than that under the minpaku law.

There have actually been reported cases where properties that were registered but significantly exceeded the 180-day limit received guidance for violating the Hotel Business Act. The assumption that “it’s fine because I’ve registered” is a mistake — you need to understand that compliance with the 180-day limit is exactly what makes a registered minpaku property legally recognized as such.

Account Suspension on Booking Platforms

Major minpaku platforms like Airbnb and Booking.com verify registration numbers in accordance with Japanese law. Properties that have received administrative penalties may have their listings removed from these platforms, and once a listing is removed, all accumulated reviews and ratings are lost. If you have to start over with a new account, you’re back to zero track record, which deals a serious blow to your ability to attract guests.

In addition, it’s not uncommon for administrative investigations to be triggered by complaints from neighboring residents. When excessive operating days are discovered alongside issues like noise or trash problems, this is treated as a compound violation and tends to result in stricter enforcement. Compliance with the law is the bare minimum requirement for maintaining stable, long-term minpaku operations.

How to Maximize Revenue Within the 180-Day Limit

Concentrate Your Operating Days During Peak Seasons

To make the most of your limited 180 operating days, it’s effective to concentrate operation during peak seasons when nightly rates are higher. Generally, cherry blossom season (late March to early April), Golden Week, summer vacation, the autumn foliage season, and the year-end/New Year holidays see high lodging demand, allowing you to set rates 1.5 to 2 times higher than during the off-season. By using weekdays during the slow season as non-operating days, you can optimize your annual allocation of days.

For example, take a property with an average nightly rate of 10,000 yen during the regular season. If you operate for 120 days at 15,000 yen per night during peak season and 60 days at 10,000 yen per night during the regular season, your annual revenue would be 1.8 million yen + 600,000 yen = 2.4 million yen. In contrast, if you operated evenly across all 180 days at a flat 10,000 yen, you’d only earn 1.8 million yen — a difference of 600,000 yen achieved purely through strategic allocation.

Fill the Gaps with Monthly Rentals

During the periods when you’re not operating as a minpaku, you can fill the income gap by offering the property as a monthly rental (a lease of 30 days or more). Monthly rentals are not subject to regulation under the Hotel Business Act or the Private Lodging Business Act, and therefore aren’t subject to any day limits. Many operators adopt a “double-cropping” approach, using the remaining 185 days after exhausting their 180 minpaku days for monthly rental instead.

Monthly rental rates typically fall somewhere between standard long-term lease rates and minpaku rates. For example, in an area where standard monthly rent is 80,000 yen, a monthly rental could bring in around 120,000 to 150,000 yen per month. Operating as a monthly rental for six months would generate 720,000 to 900,000 yen, which, combined with minpaku income, can help build a stable revenue structure throughout the year.

Consider Switching to a Hotel Business Act License

If you want to operate your minpaku without any day-count restrictions, it may be worth considering obtaining a simple lodging (kan’i shukusho) license under the Hotel Business Act. With this license, you can operate 365 days a year, completely freeing yourself from the 180-day limit. However, obtaining this license comes with higher hurdles than the registration system, including requirements related to zoning, fire safety equipment, and compliance with structural and facility standards.

As a rough estimate, obtaining the license involves costs such as 300,000 to 1,000,000 yen for fire safety equipment installation, 500,000 to 2,000,000 yen for interior renovation, and around 20,000 yen in application fees. While the initial investment is higher, being able to operate year-round can significantly increase your revenue. Compared to an annual revenue of 2.4 million yen for a 180-day minpaku operation, a 365-day simple lodging facility could bring in 4.8 million yen or more in some cases, making the investment well worth recovering.

Have Questions About Minpaku Management? Consult Stay Buddy Inc.

Calculating and managing the 180-day limit, strategically allocating operating days, and combining minpaku with monthly rentals all require specialized knowledge and hands-on experience. To maximize revenue while staying fully compliant with the law, having support from professionals who thoroughly understand the system can make all the difference.

Stay Buddy Inc. is a minpaku management company that provides one-stop support, from registration procedures to operational management and revenue-maximization consulting. We offer tailored solutions for each owner’s situation, including day-count management aligned with the 180-day limit, support for switching to monthly rentals during the off-season, and assistance transitioning to a Hotel Business Act license.

To avoid the legal risks that come from mismanaging your operating days, and to secure the maximum possible profit within your limited operating days, we encourage you to reach out for a consultation. We’ll also prepare a free, concrete revenue simulation tailored to your property’s location and conditions.

Please feel free to get in touch through the Stay Buddy Inc. website. Our experienced staff are ready to fully support your minpaku operations.