Most short-term rental operators in Japan know vaguely that they’re supposed to check guest IDs. Fewer know exactly what they’re required to collect, where to keep it, or what to do when a guest pushes back. This is one of those operational details that seems minor until an inspector shows up — so let’s go through it properly.

\

TL;DR

  • Both the Ryokan Business Act (旅館業法) and Minpaku Act (住宅宿泊事業法) require operators to maintain a guest register (宿泊者名簿).
  • For foreign guests, you must record their nationality and passport number in addition to name and address.
  • Self-check-in is fine — a passport photo uploaded via messaging or a check-in app satisfies the requirement.
  • Records must be kept for 3 years under the Minpaku Act.
  • Refusing to complete ID verification is valid grounds to decline accommodation.

What Does the Law Actually Require?

Both legal frameworks that govern short-term rentals in Japan impose ID verification obligations — but in slightly different ways.

Under the Ryokan Business Act (旅館業法), licensed hotel and ryokan operators must maintain a guest register containing the guest’s name, address, occupation, and — for foreign nationals — their nationality and passport number. The 2023 revision of the Act tightened enforcement around this requirement, so it’s not something you can treat as a formality.

Under the Minpaku Act (住宅宿泊事業法), which covers operators registered as minpaku (民泊) hosts rather than licensed under the Ryokan Business Act, Article 8 sets equivalent obligations. Minpaku operators must record guest information, with nationality and passport number mandatory for overseas visitors.

In both cases: if you’re hosting foreign guests — and in Tokyo’s current inbound environment, most operators are — you need their passport details, not just their name from the OTA booking.

What Exactly Do You Need to Collect?

Here’s what the guest register (宿泊者名簿) must include, broken down by guest type:

For Japanese nationals:

  • Full name
  • Address
  • Occupation (required under the Ryokan Business Act; minpaku operators often collect this too for consistency)

For foreign nationals (in addition to the above):

  • Nationality
  • Passport number

The address for a foreign guest is typically their home-country address. In practice, most operators also note check-in and check-out dates and the number of guests — not always legally mandated, but it makes any audit situation much easier.

Does Self-Check-In Satisfy the Requirement?

Yes — the law doesn’t require face-to-face verification. What it requires is that you have the information on record. How you collect it is up to you.

Here are the approaches that work:

Passport photo upload. Ask guests to photograph their passport data page and send it via your messaging channel — Airbnb messages, LINE, or a dedicated check-in tool. We do this in our pre-arrival sequence at BenStay, sent automatically 48 hours before check-in with instructions in English, Japanese, Chinese, and Korean.

Dedicated check-in form. Some operators use a web form or their PMS’s built-in verification flow. Guests fill in their details and upload their document before arrival. This keeps everything in one place and creates a clean audit trail.

On-site tablet or kiosk. For properties where someone is sometimes physically present, a tablet with a camera for document scanning works well and gives guests a familiar hotel-style experience.

What doesn’t work: relying on the OTA booking profile alone. Airbnb and Booking.com do not share passport details with hosts. A “verified” profile on those platforms does not satisfy your legal obligation under Japanese law.

What If a Guest Refuses?

You are legally entitled to decline accommodation if a guest refuses to provide the required information. The Ryokan Business Act (Article 5) lists permissible grounds for refusal, and non-compliance with the ID register requirement is one of them.

In practice, I’ve had this come up a handful of times — almost always a misunderstanding about why we’re asking. A short explanation (“This is required under Japanese law for all accommodation providers”) resolves it nearly every time. Occasionally someone genuinely won’t comply; in that case, offer a refund and decline. The compliance risk isn’t worth it.

One nuance: if a foreign guest sends a driving licence instead of a passport, follow up. Licences don’t always contain nationality in the required format, and for overseas visitors a passport is the document the law contemplates.

How Long Do You Keep the Records?

Under the Minpaku Act, guest register records must be kept for 3 years. The Ryokan Business Act uses the word “maintained” without specifying a period; prefectural guidance typically interprets this as 3 years as well.

Store records somewhere you can actually find them if asked. A dated folder of passport images in cloud storage works. A spreadsheet cross-referenced by booking ID also works. What doesn’t work is relying on Airbnb’s message history — it’s hard to search retrospectively, and platform interface changes can make older threads difficult to access.

What We Do at BenStay

Our pre-arrival automation sends check-in instructions that include a passport upload request. We log the details in a per-property guest register. The AI chatbot we run for guest communication also prompts guests at the start of the conversation if we haven’t received their document yet.

Once it’s embedded in your pre-arrival flow, it runs without any manual effort. Guests who visit Japan have done this at every hotel — so pushback is genuinely rare.

FAQ

Q: Does Airbnb’s guest identity verification satisfy Japan’s ID check requirement?

No. Airbnb’s verification checks that a guest’s government ID matches their profile name, but Airbnb does not share the underlying passport details with hosts. You need to collect the nationality and passport number yourself and retain them in your own records.

Q: Can I collect ID via Airbnb messages, or does it need to be a dedicated system?

Any channel works, including Airbnb messages or LINE. The requirement is that you have the information and can retrieve it. A dedicated check-in form creates a cleaner audit trail, but messaging is legally sufficient.

Q: What are the consequences of non-compliance with guest register requirements?

Penalties under the Ryokan Business Act can include a business suspension order. Under the Minpaku Act, violations can result in administrative guidance, suspension, or — in serious cases — revocation of your registration. The ID check requirement, particularly for foreign guests, is treated as a core compliance obligation, not a technicality.

This post is for informational purposes only and does not constitute legal or tax advice. Regulations and their interpretation can vary by prefecture and change over time. Please consult a qualified professional for your specific situation.