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Many property owners researching the application requirements for National Strategic Special Zone minpaku find themselves confused when trying to choose between this system and the two other main frameworks: the Minpaku Act (Private Lodging Business Act) and the Hotel Business Act. At Stay Buddy, we handle application support and operational management across all three systems, and in this article we share the practical, real-world differences between them based on our direct experience at application counters and in day-to-day operations after launch.
What Is the National Strategic Special Zone Minpaku System?
Officially called the “National Strategic Special Zone Foreign Visitor Accommodation Business,” and commonly known as Tokku Minpaku (Special Zone Minpaku), this system is based on the National Strategic Special Zones Act (enacted in 2013). It’s a lodging framework designed to meet inbound tourism demand, and it can only be operated within designated special zones. It effectively exempts operators from the Hotel Business Act, with local municipalities setting their own rules for implementation.
While the national government establishes the overall framework, actual certification and operation are left to each special zone municipality. As of 2025, the main municipalities running this system are limited to Osaka Prefecture/Osaka City, Niigata City, and Chiba City — this is the single most important precondition to understand, since this is not a nationwide system you can use anywhere.
3 Key Differences from the Minpaku Act and Hotel Business Act
Difference #1: Maximum Operating Days
Under the Private Lodging Business Act (Minpaku Act), operators are legally capped at 180 days of operation per year, and some municipalities impose even stricter limits through local ordinances. By contrast, simple lodging operations under the Hotel Business Act have no day limit at all — you can operate 365 days a year. Since Tokku Minpaku is positioned as an exemption from the Hotel Business Act, day limits depend entirely on the rules of each special zone. However, most zones instead require a minimum stay of “2 nights/3 days or longer,” and in exchange, many don’t impose any annual cap on operating days.
Difference #2: Minimum Stay Requirements
Neither the Minpaku Act nor the Hotel Business Act has a legal minimum-stay requirement, but it’s standard practice for Tokku Minpaku municipalities to mandate stays of “2 nights/3 days or more.” This condition directly affects how you configure your OTA (booking platform) listings, since you can’t accept single-night bookings — naturally, this makes the business better suited to long-term stayers and business travelers rather than short-term tourists. When Stay Buddy took over management of a Tokku Minpaku property in Osaka, we found that the previous operator had repeatedly misconfigured the minimum-stay settings, and on more than one occasion we discovered a one-night booking had slipped through the night before check-in, forcing us to cancel it. This setting needs to be locked in from day one by cross-checking the OTA configuration against the conditions stated on the certification.
Difference #3: Application Counters and Requirements
The Minpaku Act requires notification to the prefectural government (or to the city, for some designated and core cities), with the main requirements being fire safety equipment verification under the Fire Service Act and the appointment of a registered residential accommodation business operator. For simple lodging under the Hotel Business Act, the local public health center serves as the licensing authority, and the property must meet standards for room size, ventilation, and natural lighting. Tokku Minpaku, meanwhile, requires certification from the special zone municipality, with requirements set out in the Enforcement Regulations of the National Strategic Special Zones Act — including “structure and facilities suited to foreign visitors’ stays,” “conclusion of a contract similar to a lease agreement,” and “provision of daily living support services during the stay.” Since the application counters, required documents, and review processes differ completely across all three systems, it’s extremely common for owners to have to go back and re-verify requirements after they’ve already chosen a system.
A Detailed Breakdown of National Strategic Special Zone Minpaku Application Requirements
Based on the National Strategic Special Zones Act and each municipality’s implementation guidelines, here are the main conditions commonly required for application:
The Property Must Be Located Within a Designated Zone
The property must be located within a designated zone of a municipality that operates this system. Even within the same city — such as Osaka — eligibility can vary by ward or city block, so you need to verify this at the individual address level.
A Lease-Like Contractual Arrangement
Because Tokku Minpaku is legally framed as “leasing a facility” rather than “staying at a hotel,” you’re required to enter into a stay agreement (similar to a lease contract) with each guest. You’ll need to design how this contract is exchanged with guests separately from your OTA booking flow, and have this process set up in advance.
Structural and Facility Standards
The property must have a kitchen, bathroom, toilet, and washing facilities, and overall must offer a standard of comfort suitable for foreign visitors’ daily living needs. Requirements for fire safety equipment (such as automatic fire alarms and emergency lighting) under the Fire Service Act vary depending on whether a change of building use is involved and on the scale of the building — and in some cases, these fire safety requirements end up being stricter than under the Minpaku Act.
Signage and Guest ID Verification
Certified properties are required to display a designated sign. Operators are also obligated to verify guests’ identities and keep records — in a different format from what’s required under the Hotel Business Act, but a legal obligation nonetheless.
Choosing the Right System: When Tokku Minpaku Makes Sense
Tokku Minpaku becomes a strong option when several conditions align: the property is located within a designated zone, longer stays are expected, and obtaining a Hotel Business Act license would be difficult due to the building’s structure. In practical terms, its advantages are that there’s no annual day limit, and in some cases the application process is less demanding than getting a hotel business license. That said, since only a limited number of municipalities operate this system, it’s only realistically an option for owners in certain locations.
The Minpaku Act can be used to file notification anywhere in the country, but the 180-day annual cap puts a ceiling on your revenue potential. Simple lodging under the Hotel Business Act is the most versatile option since there’s no day limit, but it comes with a higher bar for meeting fire safety and building code requirements, along with ongoing management obligations once licensed. Rather than asking “which one is most profitable,” the practical approach is to choose based on your property’s location, structure, and target guest demographic.
Free Consultation with Minpaku Management Specialist Stay Buddy Inc.
At Stay Buddy, we offer free consultations covering all three systems — National Strategic Special Zone Minpaku, the Minpaku Act (Private Lodging Business Act), and the Hotel Business Act — where we review your property’s location and structure together with you to figure out which option is realistically viable. We’re also happy to hear from owners who’ve started preparing application documents but have gotten stuck, or who’ve chosen a system but aren’t confident it’s the right one.
We provide end-to-end support, from helping you obtain your license or certification through to full operational management — OTA setup, guest communication, cleaning coordination, and revenue reporting — with a design approach that considers the operational phase right from the application stage. When it comes to occupancy rates and revenue projections, we’ll give you realistic figures grounded in your location, property type, and the conditions of your chosen system (we never promise numbers we can’t back up).
Please feel free to reach out using the form below. Our team will review your inquiry and typically respond within 3 business days.
