Japan's Guest Registry (Shukuhakusha Meibo): What Hotels and Minpaku Must Record [2026 Guide]

Japan's Guest Registry (Shukuhakusha Meibo): What Hotels and Minpaku Must Record

Last updated: October 28, 2026

What you must record in Japan's guest registry depends on which law your property operates under. Under the Hotel Business Act, "occupation" was removed and "contact details" became mandatory as of December 13, 2023. Under the Minpaku Act (Housing Accommodation Business Act), "occupation" and "date of stay" are still required.

"We collect guest details at check-in — but are we actually collecting the right fields?"

"I heard the occupation field was scrapped. Does that apply to my minpaku too?"

"Wait — do I really have to copy every foreign guest's passport?"

Hi there! This is the AirHost Digital Marketing Team. The guest registry isn't exactly exciting, but it's one of the most commonly overlooked legal obligations in Japan's accommodation business. And because the required fields differ depending on the law you operate under, simply copying another property's form can land you in trouble.

Below, we break down the differences across the three regimes, what to do with foreign guests' passports, the three-year retention rule, the penalties, and how online check-in takes most of this work off your plate. All current as of October 2026.

⚡️ Key Takeaways — 3-Minute Summary

• Required fields differ by law: the Hotel Business Act requires "contact details", while the Minpaku Act requires "occupation" and "date of stay"

• The Hotel Business Act dropped "occupation" on December 13, 2023

• For foreign guests without an address in Japan, you must record nationality and passport number and keep a copy of the passport

• Registries must be kept for three years from the date created — and electronic records are permitted

• Penalties apply: up to ¥500,000 under the Hotel Business Act, up to ¥300,000 under the Minpaku Act

What is the guest registry (shukuhakusha meibo)?
A legally mandated register in which an accommodation operator records each guest's name, address, and other prescribed details, and keeps it on the premises. It is required under all three of Japan's accommodation regimes — the Hotel Business Act, the National Strategic Special Zone system (tokku minpaku), and the Housing Accommodation Business Act (minpaku) — and must be produced when a prefectural governor or other authority requests it. The system exists for public health and public safety purposes, such as containing infectious disease outbreaks and preventing terrorism.

▶ "Is our registry actually OK as it is?" Take our free 4-minute check to see how much of the registry work you could automate, or talk to AirHost about your property.

1. Every guest counts — not just the lead booker

Let's start with the most common mistake.

The guest registry is not satisfied by recording only the person who made the booking. Osaka Prefecture states that accommodation facilities must keep and properly manage a guest registry covering all guests staying at the property. Ibaraki Prefecture goes further, specifying that all guests must be recorded — not just the representative — and that entries should be separated by booking group.

Think of a class register. If only the class leader signs in and writes "plus four friends," nobody knows who was actually there. A guest registry works the same way: everyone who stays needs their own entry.

A group of four means four entries. A family means the accompanying family members too. If your check-in form has a single name field for the "representative," that form likely does not meet the requirement — and it's worth redesigning before an inspection asks for it.

2. The critical part: required fields differ across three regimes

This is the heart of the article. What you must record depends on the law your property is licensed or registered under.

Sources: Osaka Prefecture guidance on guest registry records; Japan Tourism Agency minpaku portal (both in Japanese)

The shorthand is simple: hotels and ryokan need contact details; minpaku needs occupation and date of stay. Get that straight and you'll never misconfigure a check-in form again.

One honest caveat on the minpaku column, though. Whether "contact details" is required under the Minpaku Act is presented differently by different municipalities. The enforcement regulations and the Japan Tourism Agency portal list name, address, occupation, and date of stay (plus nationality and passport number for foreign guests without a Japanese address) — but some prefectures, such as Ibaraki, also list contact details among the required items. Collecting contact details anyway is the safer choice, and you will want them in practice the first time you need to reach a guest. Confirm your final form with the municipality that regulates your property.

"Contact details" means information that lets you reach the guest in an emergency — a phone number or email address. If most of your bookings arrive online, you are almost certainly capturing this already; the task is making sure it lands in the registry.

Why did only the Hotel Business Act change?
The revised Hotel Business Act, effective December 13, 2023, reviewed the registry fields: "occupation," which had little practical use, was removed, and "contact details" — useful for reaching guests during an infectious disease event — was added. The Minpaku Act was not amended at the same time, which is why a gap now exists between the regimes.

3. Foreign guests: request the passport, keep the copy

If inbound guests are a meaningful share of your business, this section is your daily reality.

When a guest is a foreign national who does not have an address in Japan, you must additionally record their nationality and passport number — and simply taking the guest's word for it isn't enough. Osaka Prefecture sets out the following practice:

• Ask the guest to present their passport

• Keep a copy of the passport together with the guest registry

• Where a copy is kept, it may substitute for the name, nationality, and passport number entries in the registry

• If a guest refuses, explain that this is required under national guidance and ask again

• If they still refuse, respond appropriately — for example, by contacting the nearest police station

One nuance matters a great deal for guest experience: this applies to foreign nationals who do not have an address in Japan. Foreign residents of Japan — someone holding a residence card, for instance — are not subject to this passport check. Demanding a passport from every non-Japanese guest is both unnecessary and a poor welcome.

Airbnb's new rules (from November 20, 2026) still allow the registry

For reservations booked on or after November 20, 2026, Airbnb generally restricts hosts from asking guests for ID copies and other personal data, but makes an exception where the law requires it. In that case, hosts must state what is required and why in the listing's "Requests" section before booking, and collect no more than the law requires (Airbnb Help, "Limiting host-imposed contracts and other requirements").

Japan's guest registry and passport copies are exactly that kind of legally required data. If you list on Airbnb, state the registry items and the law behind them in your listing.

4. Keep it for three years — electronic records are fine

The registry must be retained for three years from the date it was created. It should be kept at the facility or the operator's office (Hotel Business Act), or at the notified dwelling or the operator's office (Minpaku Act).

Here's the part operators tend to miss: it does not have to be paper.

The enforcement regulations under the Housing Accommodation Business Act provide that where the required details are recorded in a computer file or electromagnetic medium, and can be clearly displayed on paper when needed, that record may take the place of writing in the registry (MHLW, Enforcement Regulations, in Japanese). For registries under the Hotel Business Act, electronic creation and storage is likewise treated as acceptable provided the record is accurate and can be printed or produced promptly on request.

In other words, you don't need guests filling in paper cards that you then file in a binder for three years. That's exactly where automation comes in.

▶ Still collecting paper registry cards? Our free 4-minute check shows how much you could move online — or ask us how it would work for your property.

5. Identity verification: how far do you have to go?

To ensure the registry is accurate, you must verify each guest's identity before the stay begins.

Under the Minpaku Act, this can be done in person, or by an ICT-based method treated as equivalent to in-person. The Japan Tourism Agency's minpaku portal requires both of the following:

1. The guest's face and passport must be clearly identifiable in the image

2. That image must be verifiably transmitted from inside or in the immediate vicinity of the notified dwelling

Cited examples include a video-call device or tablet installed at the property.

So "unmanned" does not mean "no identity check." If anything, the more remote your operation, the more deliberately you need to design the verification step. If you run a Hotel Business Act property and want to move to contactless check-in, it's worth confirming your intended method with your local public health center in advance.

Some municipalities require in-person checks

National rules allow ICT-based identity verification, but municipal ordinances can add stricter requirements. Toshima City, for example, lists "in-person guest registry entry and key handover" among its current minpaku rules (Toshima City summary, in Japanese), and Shinjuku City has published a draft ordinance that would require in-person identity checks of guests (public comment underway as of October 2026; Shinjuku City).

Whether you can verify identity fully online depends on the municipality where the property is located. Check before rolling out online check-in.

6. Penalties, and the gaps that cause them

The penalties differ by regime.

In practice, non-compliance almost always traces back to one of four gaps:

• Only the lead booker is recorded

• A Hotel Business Act property is still using an old form with an "occupation" field and no "contact details" field

• Foreign guests' passport copies are never taken, or taken but not retained

• Guest data sits scattered across OTA booking records and cannot be produced as a registry on request

That last one hits multi-channel operators hardest. When some bookings live in Airbnb, others in Booking.com, and others in your direct channel, "please produce three years of records" becomes a very long afternoon.

7. For operators: automate the registry with online check-in

If your reaction so far has been "collecting the right fields, capturing passports, and retaining everything for three years sounds like a lot of manual work" — you're right. It is, if you do it by hand. But here's the good news.

Most of it can be systemized through the online check-in features of a property management system (PMS).

Here's what AirHost provides (AirHost ONE guest experience):

• Automated pre-check-in links: an email containing a pre-check-in URL is sent automatically after booking, letting guests complete the guest registry online — cutting both on-site paperwork and front desk workload

• AI-based identity verification: facial recognition technology automatically matches the photo in the passport against the guest's face (an option on the Check-in Premium plan; AirHost Help, "How to set up AI face recognition")

• Video-call verification: real-time verification by video is also supported (an option on the Check-in Premium plan; AirHost Help, "Setting up video chat for identity verification")

• Self check-in: guests can check in and out via web, tablet, or smartphone

• Smart lock integration: no key handover, so the stay can run fully contactless

• Guest form (guest register) set per property: separate forms for local and foreign guests (AirHost Help, "Guest form")

• Guest data export: guest information collected at pre-check-in or check-in can be downloaded as CSV and image files, including for maintaining guest registers for legal compliance (AirHost Help, "Export guest data")

Collect it before arrival, verify it digitally, and leave nothing for the front desk. The obligation itself can't be reduced — but how you collect it is entirely up to you. Guests benefit too: nobody enjoys filling in a paper form after a long flight.

Which fields you make mandatory depends on whether you operate under the Hotel Business Act or the Minpaku Act. If you'd like help configuring this for your property, we're glad to talk it through — including pricing and how quickly you can go live.

Not just the registry: the small daily tasks, all in AirHost

Think about your living room. A TV remote, an air-conditioner remote, a light remote… with that many, you keep grabbing the wrong one. One remote that runs everything would make life a lot easier.

AirHost is that "one remote" for running your property. On top of the registry and identity checks, the everyday tasks sit on the same screen:

• Bookings: bookings from Airbnb, Booking.com and other OTAs in one place (Channel Manager) — and guest details stay attached to each reservation, so no one has to hunt for "the registry entry for that booking"

• Guest messages: guidance sent automatically after booking or before check-in (PMS)

• Cleaning: cleaning schedules on a calendar, with cleaners notified automatically (PMS)

• Room assignment: rooms assigned and optimized automatically (PMS)

• Payments: authorizations, payments and cancellation fees charged automatically according to each booking's cancellation policy (Auto Payment Collection)

• Revenue: revenue, occupancy, ADR and RevPAR in reports (PMS)

In short: let AirHost collect, verify and keep it — and spend your own time on hospitality. "Registry for the system, welcome for people."

For pricing, see the pricing page or ask us for a quote for your property.

▶ Talk to AirHost about your property

▶ Not ready to talk yet? Start with the free 4-minute check.

FAQ

Q. Can we just record the lead booker?

No. Every guest must be recorded. Prefectural authorities including Osaka Prefecture require operators to keep and properly manage a guest registry covering all guests (Osaka Prefecture, Ibaraki Prefecture, in Japanese). If your form has only one name field for a representative, it should be redesigned.

Q. Is the occupation field really no longer needed?

It depends on your regime. Hotel Business Act properties no longer record occupation — it was removed on December 13, 2023 and replaced by contact details (Osaka Prefecture, in Japanese). Minpaku Act properties still record occupation and date of stay (Japan Tourism Agency, in Japanese).

Q. Do we have to ask every foreign guest for a passport?

Only those without an address in Japan. For them, record nationality and passport number, ask to see the passport, and retain a copy with the registry (Osaka Prefecture, in Japanese). Foreign nationals who reside in Japan are not subject to this passport check.

Q. Can the registry be kept electronically?

Yes. Under the enforcement regulations of the Housing Accommodation Business Act, records held electronically that can be clearly displayed on paper when needed may substitute for written entries (MHLW, Enforcement Regulations, in Japanese). Registries under the Hotel Business Act may likewise be created and stored electronically, provided they are accurate and can be printed or produced promptly.

Q. How long must we keep it, and from when?

Three years from the date the registry was created. Keep it at the facility or operator's office (Hotel Business Act), or at the notified dwelling or operator's office (Minpaku Act) (Japan Tourism Agency, in Japanese).

Q. Can we still ask Airbnb guests for a passport copy?

Yes. For reservations booked on or after November 20, 2026, Airbnb generally restricts hosts from collecting ID copies, but allows it where the law requires (Airbnb Help, article 4169). State the items and the legal basis (Japan's guest registry under the Housing Accommodation Business Act or Hotel Business Act) in your listing's "Requests" section before booking, and collect only what the law requires.

Q. What happens if we don't keep a registry?

Fines. Up to ¥500,000 under the Hotel Business Act for breaching Article 6(1) (per Article 11(i)), and up to ¥300,000 under the Minpaku Act where the registry is not kept or retained (per Article 76). See the Japanese Law Translation Database, Hotel Business Act.

Q. Does AirHost support multiple languages for guest check-in?

Yes — guests complete pre-check-in online, and AirHost's guest-facing communication supports multilingual automated messaging, which is where most inbound-heavy properties lose the most time (AirHost ONE guest experience).

Summary

A guest registry is mandatory under all three of Japan's accommodation regimes — but the fields you must collect are not the same. Hotel Business Act properties record contact details; Minpaku Act properties record occupation and date of stay. A surprising number of properties are still running on the wrong form.

Add to that the passport requirements for foreign guests without a Japanese address, and three years of retention, and the administrative weight grows in step with your inbound share.

The good news: electronic records are explicitly permitted. You can't reduce the obligation — but you can absolutely reduce the effort. Collect the details before arrival, verify identity digitally, and both your front desk and your filing cabinet get lighter.

Start with 4 minutes: see which tasks at your property could be automated. It's free, 13 questions, and entering an email address is optional.

▶ Want to review how your property collects registry data? Talk to AirHost.

Related Articles

References

• Osaka Prefecture, "Guest registry record-keeping" (in Japanese)

• Osaka City, "Items to be recorded in the guest registry" (in Japanese)

• Ibaraki Prefecture, "Guest registry for housing accommodation business" (in Japanese)

• Japan Tourism Agency minpaku portal, "Duties of housing accommodation business operators" (in Japanese)

• Ministry of Health, Labour and Welfare, Enforcement Regulations of the Housing Accommodation Business Act (in Japanese)

• Japanese Law Translation Database, Hotel Business Act

• Airbnb Help, "Limiting host-imposed contracts and other requirements"

• Toshima City, summary of the minpaku ordinance revision (in Japanese)

• Shinjuku City, public comment on the draft ordinance revisions (in Japanese)

This article reflects information available as of October 28, 2026. Operational details vary by municipality. Always confirm current forms and procedures with your local public health center or municipal authority.