Serviced apartments in Tokyo:
travel agency or brokerage?

TokyoExpat arranges serviced apartments for overseas clients. The inventory looks like one category on a brochure. In Japanese law it is not.

If the stay is a fixed-term residential lease — typically one month or longer, used as a place to live, with day-to-day upkeep on the occupant — introducing the unit and taking a fee is real-estate brokerage under the Building Lots and Buildings Transaction Business Act (Takken-gyōhō).

If the stay is lodging under hotel terms — linen, turnover cleaning and room control remain with the operator, and the guest is not establishing a home — arranging it is travel business under the Travel Agency Act (Ryokō-gyōhō).

A hotel stay that happens to last thirty or ninety nights does not become a lease by the calendar alone. Japan’s Ryokan Business Act already contemplates long lodging. Duration is a clue. Contract form and who runs the room are the test.

There is no single statutory definition. Operators split into two types that photograph the same way: kitchen, washer, front desk, monthly rate.

Hotel-type. The building holds a ryokan or hotel licence and sells under accommodation terms. A kitchen does not change that. Booking the room is arranging lodging.

Residential-type. The unit is leased under a fixed-term building lease (teiki tatemono chintaishaku), usually from one month. Housekeeping and concierge can still exist as add-on services. The legal core is a lease of a dwelling. Introducing that lease, for a fee, is brokerage.

The Japan Tourism Agency’s reading of “accommodation services” under the Travel Agency Act tracks services that ought to be provided as ryokan business or as registered residential lodging (minpaku) under the Residential Accommodation Business Act. A genuine residential lease sits outside that box.

Stays under one month are rarely treated as a home. That is why weekly mansions and short hotel inventory stay on the lodging side. Older public-health notices used one month as a practical line when separating lodging from room rental.

One month is not a rule that turns every hotel into an apartment. The Ryokan Business Act includes geshuku (boarding-house) business: lodging charged in units of one month or more. Long stays can remain lodging.

If the operator keeps accommodation terms, changes the sheets, cleans on turnover, and does not hand over exclusive possession the way a landlord does, the stay remains lodging — including at thirty, sixty or ninety nights.

The file moves to real estate only when the paperwork becomes a fixed-term lease and the substance follows: life base, occupant-side hygiene, exclusive use of the room.

A 2007 Ministry of Health notice is blunt on form versus substance: signing a fixed-term lease does not, by itself, take a lodging operation outside the Ryokan Business Act if the stay is still “putting people up for a fee.”

The same tower can sell both. Mori-type residences, apartment-hotels and branded serviced stock in Minato and Chiyoda do this routinely. Mixing both on one invoice is how teams get surprised.

1. Is the minimum term one month or more?
2. Is the contract a fixed-term building lease or hotel / accommodation terms?
3. Is the occupant using the unit as a home, or as a pass-through stay?
4. Who is responsible for linen and changeover cleaning?

A mere introduction — no negotiation, no fee tied to closing — may fall short of “brokerage.” Once terms are negotiated, the contract is midwifed, and compensation is taken, the work is in licensed territory.

Grey files get checked case by case: operator licence, contract template, and the health-office reading if the stay is short and service-heavy.

Corporate housing that is meant to be a first home in Tokyo — one to twelve months, kitchen, laundry, school-run logistics — is usually a residential product. That is the work we do as a licensed broker.

A hotel used as a two-week bridge, or an apartment-hotel sold on a nightly rate with operator-side housekeeping as the core product, is lodging. That booking belongs with a registered travel agent.

Write the product type into the housing policy before the offer letter. “Serviced apartment, 90 days” is not a specification. “Fixed-term lease from 1 October, occupant-side utilities, optional twice-weekly clean” is.

See also our short-term corporate housing page for how we source 1–3 month residential inventory.