[Expert Commentary] Shibuya Ward's Amendment to Private Lodging Ordinance: Restrictions on "Residential Areas" and "Special Exemption Requirements" will be Significantly Stricter from July 2026.
In order to protect the living environment of residents and the safety of children, Shibuya Ward has drastically strengthened the operating rules for short-term rentals (private lodging). The biggest change in this revision is the expansion of the restricted area, as well as the removal of the office requirements for management companies from the "exception (special provision) that allows for 180 days of operation per year."
This article explains key practical points based on the latest available materials.
1. Expansion of restricted areas and the "63 days per year" restriction.
In Shibuya Ward, in addition to the existing residential-only areas, the following areas will be newly designated as restricted zones.
Details of business restrictions: Most of the months from April to July, August to December, and January to March will be "restricted periods (no business allowed)," meaning that short-term rentals will only be possible for approximately 63 days a year, excluding these periods.
2. [Important] Dramatic changes to the requirements for exceptions to the restrictions (allowing 180 days of operation).
The requirements for the "exception" that allows businesses to operate for 180 days even within restricted areas have been made stricter, as follows:
Item
Before revision
After revision
Conditions for residence/base
Within a 100m radius, either "your own home" or "Management company's officeThere is
My own homeor "within the same building", "on the same premises",adjacent"
Limitation on the number of rooms
None
5 rooms or lessTo be
Target attributes
This also includes models where management is outsourced to a management company.
Individuals such as landlord-occupied propertiesThis applies
With this revision,The requirement of "a management company office within a 100m radius" has been removed.This is extremely important. This completely blocked the investment-type model of outsourcing operations to external companies to conduct full-time operations in restricted areas.
3. Expediting the process: Providing advance notice 60 days before filing.
The procedures for providing prior notification will also be brought forward significantly.
Start of advance notification : The process must be completed at least 60 days before the scheduled filing date (currently it's 7 days).
Report on the information disseminated : After the notification is given, it will be mandatory to promptly submit the "Record of Prior Notification Content" and the distributed documents to the ward office.
Submission of contract : With waste disposal companiesCopy of contract etc.Submission of this document will become mandatory, and the contractor's license number will also be added to the information provided.
4. Schedule and transitional measures
Full enforcement date : December 8, 7.
Transitional measures : For facilities that completed their notification process before June 30, 2026, the restrictions prior to the amendment will continue to apply even after the amendment comes into effect.
Final registration under current rules : In order to complete the notification by June 30th, it is necessary to notify residents by June 23rd, 2026.
Expert advice
This amendment by Shibuya Ward is an extremely strong regulation that effectively eliminates "absentee (investment-type) short-term rentals" in residential areas and unifies them into "owner-occupied" rentals where the owner lives nearby.
For those considering properties in residential areas, the only deciding factor for a 180-day business cycle is whether you can live in that building or next door. Furthermore, the extension of the notification period to 60 days prior to the start of operations requires a more sophisticated approach to schedule management leading up to the project's launch.
Support Administrative Scrivener Corporation provides support for suitability assessments and schedule management based on the latest comparison tables of old and new regulations. If you have concerns about continuing your business in Shibuya Ward, please contact us as soon as possible.
