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100% Free Online ConsultationMaintaining a guest register is a legal obligation for anyone operating a minpaku (vacation rental) business, and failing to do so properly can lead to administrative penalties. Handling foreign guests on the register is often where hosts run into trouble, since the required entries and identity-verification methods differ from those for Japanese guests. This article walks you through, step by step, what must be recorded in the legally mandated guest register, how long records must be kept, and exactly how to handle foreign guests in practice.
Operators who have filed notification under the Private Lodging Business Act (the “Minpaku Act”) are required to keep a guest register and must report or present it upon request from the prefectural government. While there’s some flexibility in format, the required entries and retention period are clearly defined by law—so a casual, “just jot something down” approach creates real legal risk.
As inbound tourism demand continues to recover, more minpaku operators are hosting foreign guests, and many are unsure how to verify passport information or record nationality and address correctly. Below, we break down the practical knowledge you need for day-to-day operations.
Legal Basis and Core Obligations for Foreign Guests in the Guest Register
Article 8 of the Private Lodging Business Act requires operators to “keep a guest register and submit it upon request from the prefectural governor.” The accompanying ministerial ordinance (the Enforcement Regulations of the Private Lodging Business Act) specifies in detail the items to be recorded, sample formats, and the retention period. While this shares the same underlying purpose as the guest register requirement under the Hotel Business Act, the Minpaku Act has its own distinct requirements—so operators relying solely on hotel-business knowledge should be careful not to assume the rules are identical.
Note that even when management is outsourced to a licensed property management company, the obligation to maintain the register legally rests with the operator (the party who filed the notification). Even if a management company handles the day-to-day work, ultimate responsibility always stays with the minpaku owner—make sure you’re clear on that.
Mandatory Entries in the Guest Register
Under the Enforcement Regulations of the Private Lodging Business Act, the required entries are the guest’s name, address, occupation, and dates of stay. For foreign guests, two additional items are required: nationality and passport number. In other words, foreign guests require more fields than Japanese guests, and checking the guest’s passport to transcribe this information is mandatory.
For the occupation field, a general description such as “office worker,” “student,” or “self-employed” is acceptable. For the address field, foreign guests may list either their home-country address or their address while staying in Japan. The passport number must be transcribed accurately—this is the personal identification number on the passport, typically nine alphanumeric characters. Missing entries can expose you to administrative guidance or corrective action if the prefecture requests the register and finds gaps.
Retention Period and Storage Methods for the Guest Register
Under the Enforcement Regulations of the Private Lodging Business Act, guest register records must be kept for three years from the date of stay. Once three years have passed, there’s no further legal obligation to retain the records, though some operators choose to keep them for around five years anyway, since they can serve as useful evidence if a dispute arises.
As for format, both paper registers and digital records are legally acceptable. However, if you store records digitally, they should be kept in a tamper-resistant format (such as PDF or a dedicated management system) and must be readily retrievable whenever requested. If you’re using a cloud-based property management system, be sure to check how long it’s configured to retain guest data. If the system is set to auto-delete data before the three-year mark, that constitutes a legal violation.
Practical Steps for Verifying Foreign Guests and Completing the Register
The practical workflow for maintaining a compliant register for foreign guests starts with requesting a passport at check-in. For face-to-face check-in, you can ask to see it directly. For self-check-in setups (such as smart locks), it’s common practice to have guests send a photo of their identification document before check-in.
The typical process looks like this: send the guest a message the day before or on the day of check-in, asking for a photo of their passport’s data page (the page showing their photo, name, passport number, and nationality). From that image, transcribe the name, nationality, passport number, and address into the guest register, and store the image linked to that register entry for three years. Entries don’t need to be in Japanese, but it’s advisable to attach a Japanese translation when submitting the register to the prefecture if requested. Note that operators have the right to refuse accommodation to any guest who declines to provide the information needed for the register.
Key Considerations for Self-Check-In with Foreign Guests
For properties using self-check-in, the lack of face-to-face verification raises the question of how to reliably confirm a guest’s identity. Guidelines from the Ministry of Land, Infrastructure, Transport and Tourism permit IT-based, non-face-to-face identity verification as long as certain requirements are met, and sending a passport photo is recognized as a standard method for meeting them.
One commonly used approach is leveraging the identity-verification features built into OTAs (such as Airbnb or Booking.com). Airbnb, for example, has a feature that requires guests to submit government-issued ID, which can supplement your own verification process. That said, OTA verification does not exempt you from your own obligation to maintain the guest register. Even if a guest has already been verified through an OTA, the responsibility to record and retain the required information in your register still rests with you—don’t confuse the two. Build a workflow (whether for your team or just for yourself) that ensures passport details are transcribed into the register promptly once received.
Comparison with the Hotel Business Act: Differences in Record-Keeping Requirements
The Hotel Business Act also requires operators to maintain a guest register (Article 6), and its required entries closely mirror those under the Private Lodging Business Act—including the requirement to record passport numbers and nationality for foreign guests. The retention period under the Hotel Business Act is also three years, matching the Minpaku Act.
The key difference is that the Hotel Business Act operates under a licensing system, while the Private Lodging Business Act operates under a notification system—and the two laws differ in the types of properties and regulations they cover. It’s not necessarily wrong for a minpaku operator who has filed notification under the new law to reuse a register format from the hotel-business world, but it’s essential to individually verify that it fully satisfies every entry required under the Minpaku Act’s enforcement regulations. Since the relevant authority can vary—prefecture, public health center, or municipal government, depending on the type of business—it’s a good idea to check with whichever office you filed your notification with if anything is unclear.
Streamlining Register Management and Protecting Personal Information
Because the guest register contains sensitive personal information—passport numbers, addresses, nationality—it must be managed in accordance with the Act on the Protection of Personal Information. Paper registers should be kept in a lockable location, and digital records should be password-protected with limited access permissions; be sure to also review the terms of service of any cloud service you use. Register data should only be shared with third parties with the guest’s consent or when required by law.
For efficiency, a dedicated property management system (PMS) for minpaku operations can be a great help. Systems like Smoobu, Hostaway, and Lodgify offer centralized guest-information management and can automatically import booking details from OTAs, reducing transcription errors. That said, passport numbers and nationality for foreign guests generally can’t be captured automatically, so the step of receiving a passport photo and manually entering the data is still necessary. Turning this step into a checklist you follow consistently can significantly reduce the risk of missing entries.
Risks of Failing to Meet Record-Keeping Obligations
If an operator fails to maintain a guest register, or falsifies entries, they may be subject to a request for reports or an on-site inspection by the prefectural governor under Article 17 of the Private Lodging Business Act. Failure to comply with a corrective order can result in a business suspension order, and in serious cases, the notification itself may be suspended. Penalties include fines of up to ¥1 million—a level that shouldn’t be taken lightly.
Cases involving administrative action are sometimes made public by the relevant prefecture, which can also mean serious reputational damage from having your business name disclosed. Operators who actively host foreign guests tend to be more prone to omitting passport numbers from their registers, so documenting a clear, written workflow for handling foreign guests is the most effective way to prevent violations.
For Questions About Minpaku Operations, Talk to Stay Buddy
Managing a guest register and handling foreign guests properly requires a solid grasp of legal requirements translated into a practical, day-to-day workflow. Whether you want to confirm your register format is correct, build out an identity-verification process for self-check-in, or you’re simply unsure about how to manage retention periods, Stay Buddy Co., Ltd.—a full-service minpaku management company—is here to help.
Stay Buddy offers comprehensive operational support for minpaku businesses, from notification support to day-to-day management and guest communication. We specialize in solving hands-on operational challenges, including multilingual support for foreign guests and building out passport-verification workflows, so that owners can run their business with confidence and without exposure to legal risk.
Even simply starting by reviewing and improving your current guest register practices can substantially reduce your future risk of administrative guidance or penalties. Whether you’re concerned about your current setup or you’re just getting started with minpaku, feel free to reach out to Stay Buddy anytime. Your first consultation is completely free.
