Osaka City's Interim Report on Special-Zone Minpaku Inspections: 46% of Inspected Facilities in Breach, 27% Not Operating. What It Means If You Plan to Buy and Host in Osaka

The short version: nearly half of the inspected special-zone minpaku were in breach, new certifications have ended, and the route to buying and hosting in Osaka has changed

On 29 October 2026 Osaka City published an interim report, as of the end of September 2026, on inspections carried out under its FY2026 monitoring plan for special-zone minpaku. Of the 4,887 facilities covered by the plan, 3,157 have been inspected, or 65%. Among them, 1,441 facilities were found to have breached the law or failed to follow the city guidelines and were given corrective guidance, which is 46% of those inspected, and 865 facilities, or 27%, were not operating at all and were told to file a notice of closure^[1]. Together that is 2,306 facilities, roughly 73% of those inspected^[1]. Add the fact that Osaka City stopped accepting new applications for special-zone minpaku certification on 29 May 2026^[4], and the regulatory environment for buying a property in Osaka City to run as a holiday rental is now entirely different from what it was one or two years ago.

What special-zone minpaku is, and why Osaka tightened the rules

The formal name of special-zone minpaku is the "foreign visitor accommodation business in a National Strategic Special Zone". It is run under the National Strategic Special Zones Act with certification from the Mayor of Osaka. The other two ways to offer paid lodging in Osaka City are a licence under the Hotel Business Act and a notification under the Private Lodging Business Act^[6]. Under the city ordinance, a special-zone minpaku must let guests use the facility for at least 3 days, meaning 2 nights and 3 days, so a single-night stay is not allowed^[5].

As the number of facilities grew, so did complaints from neighbours about noise and rubbish. Osaka City set up a "nuisance minpaku eradication team" in November 2025 and adopted this year's monitoring plan on 25 March 2026^[1]. On the same day it revised its guidelines for special-zone minpaku. Operators must explain the noise and rubbish rules to guests in person or by phone at check-in and post notices at the building entrance. When a complaint comes in, they must go to the site or phone the guests to warn them directly, ask them to leave if there is no improvement, report the outcome to the complainant, and keep complaint records for 3 years^[3].

On new certifications, the city decided to end applications at its lodging policy project team meeting on 30 September 2025, proposed an amendment to the zone plan at the National Strategic Special Zone Council on 17 November 2025, and received the Prime Minister's approval of the amendment on 28 November 2025. From 29 May 2026 it stopped accepting new applications as well as applications by certified facilities to add rooms or increase floor area. Facilities certified before that date can continue to operate as before^[4].

How the inspection targets were chosen and what was checked

This year's priority facilities number 2,817. The first group is the 1,488 facilities that had not answered the city's operating survey by the end of January 2026. The second group consists of 124 facilities found to be improperly run, including suspected cases, 256 facilities that had received multiple complaints about the living environment, and 357 facilities whose complaint records did not match their survey answers. The third group is 692 detached or terraced-house facilities in category 1 or category 2 residential zones with at least one weak point, such as warning guests only by email or social media, taking more than about 10 minutes to reach the property, or having no 24-hour telephone contact. Some facilities fall into more than one group, so the subtotals do not add up to 2,817. In addition, 2,070 operating facilities in Chuo, Naniwa and Nishinari wards that are not priority targets are also covered^[2].

Inspections are carried out through on-site visits, checks of the required signage and telephone calls to operators, and the period runs from 1 April 2026 to 31 March 2027^[1]. The items checked fall into two groups. The legal requirements cover the sign at the entrance, the usage guidance inside the unit, the display of a 24-hour complaint contact and the structure and equipment of the rooms. The guideline requirements cover noise and rubbish notices, verbal warnings at check-in and when complaints arise, complaint records and reporting, and a system for reaching the property within about 10 minutes^[2]. Breaches are first met with verbal or written guidance followed by a check that the problem has been fixed. If an operator continues to breach the law without correcting it, the city can issue a business improvement order or a suspension order, or revoke the certification under the National Strategic Special Zones Act^[3].

How to read the interim figures

As of the end of September, 65% of the inspections had been completed, 46% of the inspected facilities had breaches or failed to follow the guidelines, and 27% were not operating^[1]. Three points deserve attention. First, the facilities inspected were selected for risk, such as complaints or failure to respond to the survey, together with the facilities in the 3 wards where minpaku are concentrated, so the 46% figure cannot simply be applied to every special-zone minpaku in the city. Second, the 865 facilities with no operations were told to file notices of closure, so the number of special-zone minpaku on the city's books will fall. Some of these units will return to the long-term rental or sales market^[1]. Third, this is an interim report. The final results will be compiled as of the end of March 2027^[2].

What this means for buyers

1. Buying a property to start a special-zone minpaku is no longer possible in Osaka City. New certifications closed on 29 May 2026, and certified facilities cannot add rooms either^[4]. Certification is granted to the operator, so whether you could continue operating in the same way after buying a unit that carries a special-zone minpaku certification is something to confirm with the Osaka City Public Health Center in advance, rather than relying on a verbal assurance from the seller or an agent.

2. The remaining routes are the Private Lodging Business Act and the Hotel Business Act, each with its own hurdles. The private lodging business, often called the new minpaku law, works by notification, but lodging can be offered for no more than 180 days a year, and if the host is not resident the hygiene and related measures must be entrusted to a registered private lodging management company^[8]. The Hotel Business Act requires a licence. Osaka City expects operators to move to this route and, to prevent disputes with neighbours before they arise, invited public comments on a draft amendment to its Hotel Business Act enforcement ordinance from 19 May to 18 June 2026^[7]. In other words, the bar is being raised, not lowered.

3. Owner-occupier buyers should check whether the building has minpaku and what the management rules say. The interim report shows that nearly half of the inspected facilities fell short on points such as signage and complaint handling^[1]. When viewing, ask whether the building contains special-zone or new-law minpaku, check whether the management rules prohibit lodging use, and look at the entrance for a minpaku sign and a complaint contact.

4. Keep an eye on changes in supply. The 865 facilities told to close, plus any more added before the inspections end in March 2027, will partly return to the rental and sales market as vacant units^[1]. That means more choice for buyers, but also a need to establish how such units were used before and how well they were maintained.

Summary

Osaka City's interim report of 29 October shows that 65% of the priority inspections of special-zone minpaku have been completed, and that of the 3,157 facilities inspected, 1,441 (46%) were in breach of the law or the guidelines and 865 (27%) were not operating^[1]. New certifications closed on 29 May 2026^[4], and the city ordinance under the Hotel Business Act is being amended^[7]. If you are considering buying a property in Osaka City to let or to run as lodging, please contact us. We can go through the zoning, the management rules and the business formats that are currently feasible for a specific property, and help you set out the conditions and the risks clearly.