Shinjuku Minpaku Rules 2027: What the Proposed Airbnb Ban and Hotel License Rules Mean for STR Investors

Shinjuku City has proposed banning new minpaku in residential areas, extending that ban to existing listings after two years, and imposing much stricter building standards on new hotel-license applicants. In our view, if the proposals pass as drafted, year-round short-term rental operation in Shinjuku will become largely limited to properties that already hold a hotel business license, making existing licenses scarcer and more valuable and putting the exit value of minpaku-only properties at risk.

1. The Short Answer

On October 15, 2026, Shinjuku City in Tokyo opened a public comment period on two proposals. The first is a revision of the ward's ordinance on minpaku (private lodging under the Housing Accommodation Business Act, a notification-based system capped at 180 nights per year). The second revises the ward's ordinance implementing the Hotel Business Act (Ryokan-gyo-ho). Comments must arrive by November 13, 2026.

In one sentence: for minpaku, the proposals sharply limit where and on how many days you can operate; for hotel-licensed lodging, they sharply limit which buildings can obtain a new license.

• Minpaku: new operations would be banned in principle in residential and certain other zones, and the ban would apply to existing notified properties two years after the ordinance takes effect. Even in commercial zones, minpaku would be limited to 120 nights a year, and only during spring, summer and winter holiday periods.
• Hotel business license: new applicants would need more than 200 m² of total floor area in lodging use, a front desk and other facilities. These structural standards would not apply to existing licensed facilities.

In our view, if the proposals pass in their current form, lodging that can operate year-round in Shinjuku will be increasingly limited to properties that already hold a hotel business license. New small-scale licensed lodging will be hard to add, existing licenses will become scarcer, and minpaku-notified properties face a risk of lower value at exit. For anyone buying in Shinjuku now, we think the key question shifts from "Can this be notified as a minpaku?" to "Does it already have a hotel license, or can it meet the new standards to get one?"

These are draft ordinances at the public-comment stage, and their content may change. The ward's materials give no effective date. According to press reports, the ward plans to submit the revised ordinances to the ward assembly in 2027 and to put them into effect in June of that year (Kumamoto Nichinichi Shimbun / Kyodo).

2. Why Shinjuku Is Going This Far

According to the ward's minpaku summary document, Shinjuku had 3,749 notified minpaku facilities as of the end of fiscal 2025 (March 31, 2026), the most of any municipality in Japan. Hotel-licensed facilities rose by 228 over the past three years, and the ward says most of them are small facilities such as detached houses.

Complaints about minpaku and hotel-licensed lodging combined totaled 1,525 in fiscal 2025, mostly about living-environment issues such as garbage, noise and smoking. The ward already bans minpaku operation on weekdays (Monday to Thursday) in exclusively residential zones, and from fiscal 2025 it began taking administrative action against repeat violators. So far it has issued business improvement orders to 163 facilities, suspension orders to 67 and abolition orders to 15 (as of the ward's October 2026 materials).

Complaints have continued anyway, and that is the stated reason for the revision. According to press reports, the ward believes the new rules could leave about 2,000 facilities unable to operate (Akita Sakigake Shimpo / Kyodo). For the broader trend across Tokyo, see our earlier article, STR Regulatory Tightening Across Tokyo's 23 Wards: Changes from April 2022 to April 2026. This article focuses on what the Shinjuku proposals say and how they affect investment decisions.

3. What the Proposals Say

Minpaku by zoning district

A zoning district (yoto chiiki) is the land-use category set by city planning, such as residential, commercial or industrial. Under the proposals, the zone a property sits in determines whether it can run as a minpaku. The table also includes educational districts (bunkyo chiku), a type of special-use district designated to restrict uses considered unsuitable for culture and education, including lodging (general definition, City of Kobe).

Figure 1. Minpaku operation by zoning district: current rules vs. proposals

Source: Shinjuku City, minpaku summary and minpaku ordinance outline. *"Other zones" is our reading, based on the fact that the ward's materials do not list them as restricted areas.

The 120 nights fall in three windows: spring holidays (noon March 15 to noon April 11), summer holidays (noon July 1 to noon September 1) and winter holidays (noon December 15 to noon January 15). Operation outside these windows would not be allowed.

The "special-exception home" must meet all of the following and be certified by the ward: the operator (a person able to converse in Japanese) has lived in the notified home, or the home next door, as their principal residence for at least three years; the operator owns the home; and if the host lives on site, bedrooms are separate and individually lockable. In our reading, investment-type minpaku owned or operated by overseas investors or companies will almost never qualify for this exception.

Minpaku vs. hotel license, and when rules hit existing facilities

A hotel business license (ryokan-gyo kyoka) is a permit-based lodging business under Article 3 of the Hotel Business Act, and the law sets no annual cap on operating days the way the minpaku system does. (For the differences between the two systems, see Hotel Business Act vs. Housing Accommodation Business Act.) Here is how the two proposals compare.

Figure 2. Minpaku vs. hotel business license under the proposals

Source: Shinjuku City, minpaku summary, minpaku ordinance outline and Hotel Business Act ordinance outline.

The building confirmation certificate (kakunin sumisho) proves that the building plan was found compliant with the Building Standards Act before construction; the inspection certificate (kensa sumisho) proves the completed building passed inspection. The ward says it will require these so that compliance is confirmed when a house is converted into lodging. For buildings without an inspection certificate, the Ministry of Land, Infrastructure, Transport and Tourism (MLIT) has issued guidelines for surveying compliance, which suggests a meaningful number of existing buildings lack complete paperwork. In our view, older detached houses will have the hardest time assembling these documents, and this requirement alone raises the bar for new licenses. (We cover the architect's certification issue in Japan's 2026 Ryokan License Rule: Why an Architect's Signature Will Reshape the STR Market.)

4. Market Impact: How Supply and Competition May Shift

This section is our view, assuming the proposals pass as currently drafted.

New supply: small licensed lodging largely stops

A threshold of more than 200 m² with a front desk, staff room and parking is hard for a typical central-Tokyo detached house or a single apartment unit to meet. The ward says most of the hotel-licensed facilities added over the past three years were small properties such as detached houses; we expect that supply route to close almost entirely. New entrants will mostly be operators converting or developing mid-sized or larger buildings for hotel use, which takes capital and time, so supply growth should slow.

Minpaku exits: residential-zone listings leave the market

We believe most of the roughly 2,000 facilities reported as potentially unable to operate are existing minpaku in residential zones, and that they will leave the market two years after the effective date. Commercial-zone minpaku will be limited to 120 nights in holiday periods, making year-round business plans hard to build. In our view, the low- to mid-priced segment of Shinjuku's lodging stock that minpaku has supplied will shrink in stages.

Figure 3. Expected impact by property type (our view)

Source: our analysis based on Shinjuku City's proposals.

As minpaku exit and room counts fall, some demand will move to neighboring wards (Nakano, Shibuya, Toshima and others) or to large hotels. But we expect much of the demand to stay in Shinjuku, which would benefit facilities that can keep operating (more on this in the final section). Higher-priced whole-building rentals serve group and family travel, where substitutes are few, so we think they are especially likely to benefit from tighter supply.

Note that stricter oversight reaches existing licensed properties from the effective date. If an existing facility without a front desk does not maintain its on-call or office-staffing arrangements, it can receive a corrective order, published with the operator's name. In our view, a license alone does not guarantee value; the license and a sound operating setup together create it.

5. What Investors Need to Decide

If you are buying: look for a hotel license, not a minpaku notification

Under the proposals, it becomes hard to justify a Shinjuku STR purchase on the basis that the property is (or can be) notified as a minpaku. The safer approach is to value a residential-zone property assuming it stops operating two years after the effective date, a commercial-zone property assuming 120 nights, and either one at its price without STR income.

We think two questions now matter most:

• Does the property already hold a hotel business license? Because the structural standards would not apply to existing facilities, licenses on properties of 200 m² or less are expected to remain valid. However, which facilities count as "existing" (for example, whether applications pending on the effective date are included) will be set in the supplementary provisions, which have not yet been published.
• Can the property meet the new standards and obtain a new license? On top of more than 200 m², a front desk, staff room and parking, copies of the building confirmation and inspection certificates will be needed. Whether the paperwork is complete becomes a precondition for price negotiation.

For owners considering a switch from minpaku to a hotel license, we think the deciding factor is whether the license can be secured before the effective date.

Buying a licensed property: succession and neighbor notice

A hotel business license is held by the operator (a person or company), not by the property. When a business is transferred, the operator's status can be succeeded if both the transferor and transferee obtain government approval (Ministry of Health, Labour and Welfare). The ordinance outline would also require written notice to neighbors at least 30 days before applying for this succession approval. That can affect the acquisition timeline and when operations can resume after handover, so it should be built into price and closing terms.

If you take over the whole company (by acquiring its shares), the operator itself does not change, so succession approval is likely unnecessary, but treatment depends on the facts of each case. Choosing the right acquisition structure involves tax and legal judgments; please confirm with qualified professionals such as an administrative scrivener (gyoseishoshi), lawyer or tax accountant.

If you already own a minpaku: fix operations first

Existing minpaku would face in-person identity checks and explanations, on-site response within about 30 minutes and contracts with licensed waste haulers from the effective date. Operations that rely only on self check-in and remote support will need to be rebuilt before the zoning and day limits even arrive. For residential-zone properties, now is the time to decide whether to sell, convert to long-term rental or convert to a hotel license during the remaining transition period.

6. What Is Still Undecided

• Effective date: not stated in the ward's materials. Press reports point to June 2027. In that case, the zoning and day limits for existing minpaku would start around June 2029 (our estimate).
• Supplementary provisions and regulations: treatment of applications pending on the effective date, the scope of neighbors to be notified (10 m in the outline, to be set by regulation) and document details are still to be decided.
• Differences between documents: on corrective orders for existing hotel-licensed facilities, the ordinance outline lists both "on-site response within 10 minutes" and "office staffing," while the hotel-license summary document lists only office staffing.
• Amendments: the content may change after public comment and ward assembly deliberation. Press reports say the ward plans to submit the ordinances at the first regular assembly session of 2027.

This article summarizes draft ordinances and is not legal advice on any specific property or transaction. Please consult professionals such as an administrative scrivener or lawyer before making decisions.

7. Our View: Minpaku Exits Could Create a Windfall for Those Who Stay

Shinjuku's proposals mark the end of an era in which minpaku and small licensed lodging were easy to start. For overseas investors, "buy because it can be notified" will no longer work, while properties with a proper license and solid operations will, in our view, become relatively more valuable.

We also think the revision is an opportunity to go on the offensive, not just a reason to play defense. From what we see in practice, many Shinjuku minpaku are run as sublets: the operator rents a unit from the owner and runs it as lodging. A sublet operator paying rent cannot continue once residential-zone operation is banned, and in our view many commercial-zone sublets cannot cover rent on 120 nights in holiday periods either. Press reports say the ward expects about 2,000 facilities may be unable to operate. Beyond that, we expect many sublets in commercial zones to exit as well, and we estimate that at least half of existing minpaku will stop operating by the end of the two-year transition period. Based on the current 3,749 notifications (end of fiscal 2025), half is about 1,900 facilities. Assuming one room per facility, we estimate that roughly 1,900 to 2,000 rooms would leave the Shinjuku market at around the same time, at the end of the transition (our calculation: 3,749 × 0.5 ≈ 1,875).

Figure 4. Shinjuku minpaku: notified facilities, reported impact and our estimate of exits

Source: Shinjuku City (3,749); Kyodo News reports (about 2,000). The third row is our own estimate, not an official figure, and is a separate estimate from the reported 2,000 facilities. Bars are rounded to the nearest ■; each ■ represents 125 facilities.

If lodging demand in Shinjuku does not change much, we think supply and demand will tighten and the change is likely to become a windfall for operators who can keep running. In other words, rather than avoiding Shinjuku because of tighter rules, we see buying properties with an existing hotel license, or properties that can meet the new standards, in Shinjuku now, before the transition ends, as an offensive investment. That said, the scarcity of existing licensed properties may already be starting to show up in prices, so it is essential to check whether the purchase price is justified by the income. And because the draft may still change, any decision should be checked against the final ordinance.

The Room specializes in selling and operating higher-priced whole-building rentals that hold a hotel business license and reflect serious investment in the building and facilities. If you are considering year-round properties that are less exposed to regulatory change, in Tokyo including Shinjuku, Hakone or the Fuji Five Lakes area, please feel free to contact us. For our broader view of the city market, see Tokyo STR Market Analysis and Investment Strategy.