I remember last year when my wife and I were booking one of our annual trips back to Japan, and we received an interesting email from AirBnB. We had booked a two-week stay in a unit in Ebisu. We were looking forward to being in a full apartment, and staying in a neighborhood we'd never explored.

Unfortunately, the message from AirBnB wasn't good news. We were informed that the owner of the residence had failed to notify AirBnB that they'd complied with a new law. We were given a choice: Cancel, or hang on and hope the owner complied in time.

That email was a harbinger for a large spate of AirBnB listings going offline. Within a wink, the majority of Japan's AirBnB listings disappeared.

What happened? Quite simply, AirBnB hit Japan too hard, too fast - and Japan wasn't ready for it.

An Outcry Brings a New Law

In one sense, AirBnB was a blessing for Japan. Between 2012 and 2017, tourism in Japan ballooned to 20 million visitors - an historically unprecedented growth spurt. AirBnB swooped in and supplemented Japan's overtaxed hotels with a different experience for visitors: a chance to stay in a real neighborhood, sometimes with Japanese hosts who were more than happy to help first time tourists get around the unfamiliar and sometimes hard-to-navigate surroundings.

But the introduction of - let's be blunt, foreigners - into Japan's tight-knit and culturally homogenous neighborhoods also brought with it a wave of consternation from residents. Some expressed feeling a lack of safety on seeing strangers (again, let's be blunt - foreigners) coming and going from neighborhoods. Complaints arose around noise, and around these mysterious "residents" who couldn't figure out Japan's unique system of garbage disposal.

More sensationalist headlines about the "dangers" of minpaku (民泊みんぱく; "private lodging", home-sharing) also began to spread. In 2015, a 4-year-old Chinese girl died after falling from a balcony; her mom had left her alone to walk to the nearest convenience store to buy Tokyo Disneyland tickets. And in 2018, an American national rented a room for the purpose of killing and dismembering a 27-year-old woman in the city of Sanda in Hogo Prefecture. Naturally, the Japanese press also covered all of the AirBnB horror stories form abroad, including cases of trashed houses and peeping tom cameras.

One can argue that this is purely an example of Japan's racism and bias against foreigners. While I can't discount that, I think that visitors' lack of knowledge of local customs was also a factor that stoked outrage. Japanese society works because everyone generally knows the rules, and follows them to the letter. When those rules are broken, and the natural rhythm of the day disturbed, it breeds discomfort. The source of consternation isn't always Westerners, either: I've seen Japanese people curl their lips up in disgust at Chinese tourists who stroll through Shinto sites like Meiji Jinguumae, talking loudly and throwing their trash on the ground, in violation of clearly posted rules in multiple languages.

Whatever the cause, the outcry from Japanese citizens forced the Abe Administration's hand. Abe's government was reluctant to do anything that would hurt tourism to the country, so it looked for a minimally invasive solution. It also had to respond to the concerns of cities like Kyoto, which wanted to institute rigid local restrictions that the government didn't necessarily want to impose on the entire nation.

The New Lodging Law, which went into effect in June 2018, sought to thread this needle in two ways. First, it required anyone who wanted to run a home-share to register with local authorities, and to display their registration number clearly outside of their residence. Any home-share that lacked this reservation number would be considered illegal, and subject to large fines and even jail time. The law increased the potential fine for violation from a few ten thousand yen up to several million yen (USD $10K and over), so the measure was no paper tiger.

Second, while compliance with the law would be enforced by the Japan Tourism Agency (観光庁かんこうちょう), the law ceded local control in the registration process, allowing local governments to set additional criteria for doling out registrations. For example, Shinjuku Ward in Tokyo forbids renting places in residence-only zoned areas between Monday and Friday. (Owners in mixed use zones face no such restriction, which is why you can still find AirBnB rentals in Shinjuku.)

The law's immediate impact was devastating to AirBnB's bookings. It didn't help that AirBnB dragged its feet on sending out notifications to customers. When many of AirBnB's current listers failed to secure a registration number from Japan's Ministry of Tourism, AirBnB simply deleted the listings from its site, leaving many customers in a lurch.

For its part, AirBnB insists that the JTA did an about-face on June 1st, and reneged on an earlier promise that customers who booked stays before the law took effect would be exempt from enforcement. That doesn't quite accord with my recollection of the notices AirBnB sent out, which came before that date. However it went down, the results were the same: AirBnB listings in Japan went from over 50,000 to under 4,000 overnight.

With such a dramatic drop, it did indeed seem like AirBnB's time in Japan was swiftly coming to an end. Commentators both in-country and abroad were swift to write eulogies - not just for AirBnB as a business, but for the entire concept of home-sharing in Japan.

(JP) Link: Dead Before Dawn: The Last Days of the Private Lodging Industry in Japan

夜明け前に終わった「日本の民泊産業」の末路 | レジャー・観光・ホテル

Recovery? Yes. Legality?

But reports of AirBnB Japan's demise have been greatly exaggerated. The good news for travelers is that, less than a year out, AirBnB is showing strong signs of both recovery and compliance.

According to Min-paku.biz, a site that specializes in the home-share business, the latest figures out from AirBnB show that there are about 41,000 listings per month on the platform in all of Japan. Obviously, that's shy of the former peak of over 50,000 - but it's close to a full recovery.

(JP) Link: Number of AirBnB Listings as of February Hits 6 Million Worldwide, Over 41,000 in Japan

Airbnbリスティング数、2月時点で世界600万件超、日本41,000件超 | 民泊ニュース | 日本最大級の民泊情報サイト MINPAKU.Biz | 民泊・Airbnb運用代行比較

The shortfall is likely due to a couple of factors. Some renters may have decided that the new registration system was too much of a hassle. Others might now find themselves living in areas where using AirBnB is no longer feasible. For example, owners with properties in residential Shinjuku can effectively no longer rent to most foreign tourists, whose stays generally extend beyond the weekend (which sucks for those individuals and companies who explicitly bought apartments or homes in Japan explicitly as AirBnB investment properties).

However, while all of this is good news for overseas travelers, a survey by the JTA back in October carries a word of caution. An investigation of almost 25,000 home-share listings across 37 different companies found that, despite the new law, the legality of some 4,938 listings could not be determined. Most of the properties either used a fictitious registration number, or used a number that didn't match their application with the JTA.

(JP) Link: JTA Announces Results of Investigation of Illegality Regarding New Lodging Law: 20% of Listings on Minpaku Sites Under Suspicion of Illegality

['観光庁、民泊新法施行時の違法性で調査結果を公表、民泊サイト掲載の2割が違法の疑い | トラベルボイス', '観光庁、民泊新法施行時の違法性で調査結果を公表、民泊サイト掲載の2割が違法の疑い']

So what does this mean for travelers - particularly, for users of AirBnb?

It seems AirBnB struggled at first to comply with the new regulation. Immediately after the law was passed, the JTA found numerous listings on AirBnB that were using the same registration number. In other words, the company's initial implementation of the law was perfunctory and insufficient; it hadn't instituted proper methods to verify the authenticity of the information it was supplied.

(JP) Link: Are Fictitious Registration Numbers on AirBnB's Listings a Sign of "Underground Private Lodging"?

エアビーサイトで架空の届け出番号掲載 「ヤミ民泊」か:朝日新聞デジタル

Curious as to whether anything's changed, I reached out to AirBnB Support and asked them what they were doing to ensure that the JTA registration numbers supplied by guests were valid, and matched the AirBnB listing. An AirBnB Community Representative, Kiran, sent me the following response:

Due to the Japan Short Term Rental regulatory requirements, hosts in Japan will need to add a JTA (Japan Tourism Agency) registration number when creating a new listing.

Once the listing has been created, the listing details will be reviewed by our internal teams before the host can start receiving reservations.

During the review, the host's listing does not appear on search and the host will see a pending message that the listing is under review and it may take a few days.

Unfortunately, we are unable to share internal process with you however, I can inform you that the verifications are performed on every listing and if the registration details are not valid then the listing is suspended until further updates from the host.

AirBnB is being somewhat cagey here, to be sure. But having a tech background myself, and having dealt with fraud prevention issues before, I suspect this is because they don't want to give scammers any clues that might help them circumvent the process. So, despite a shaky start, it appears the company is taking the law seriously, and doing its best to comply.

As a traveler, if you want to use a home-share service, consider the following tips to further ensure your safety - and the comfort of surrounding residents:

  • Stick with companies with solid reputations and a published procedure for complying with the Private Lodging Law. There are still scammers out there, as the JTA's report clearly shows.
  • Confirm online that a given home share has posted a JTA registration number with their listing.
  • Search the home-share site you're using to see if other residences are using the same number - a clear sign that someone is attempting to skirt the law.
  • Confirm upon arrival that the residence has a sign with the same registration number clearly posted. If it does not, contact the renter and insist on seeing the official registration certificate.

Alternatively, you can just stay at a hotel, hostel, or traditional Japanese ryokan. You may pay a little more for a hotel or a ryokan, but you'll buy yourself peace of mind.