LPA Administrative Scrivener Office
Travel Agency Registration
Japan’s Act on Travel Agency Business establishes a comprehensive regulatory framework governing travel-related activities conducted for remuneration. Depending on the nature and scope of the services provided, businesses may be required to register as a Travel Operator, Travel Agent, or Travel Service Provision Business, and must comply with specific licensing, financial, and personnel requirements. The following overview summarizes the regulated activities, licensing categories, and key compliance obligations relevant to operating a travel business in Japan.
1.Travel Activities Regulated under Japanese Law
1.1. Travel Operator Business（旅行業）
Under the Act on Travel Agency Business (Article 2), any business that conducts the following travel-related activities for remuneration is subject to regulation. Such businesses are required to register as a Travel Operator with the Commissioner of the Japan Tourism Agency Local or the governor of the prefecture where the principal office is located (Article 3).
A business will be deemed to engage in regulated travel operator activities if it performs any of the following:
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Planning and Arranging Travel Packages
Creating travel plans, either at the request of travelers or on the business’s own initiative, for the purpose of soliciting travelers. This includes specifying destinations, travel dates, transportation and accommodation services (collectively, “Transportation and Other Services”), and fees, and concluding contracts in the business’s own name with service providers for the benefit of travelers. -
Arranging Ancillary Travel-Related Services
In connection with the above, concluding contracts in the business’s own name for travel-related services other than transportation and accommodation. -
Acting on Behalf of Travelers
Concluding contracts as an agent or broker for travelers in relation to the provision of Transportation and Other Services. -
Acting on Behalf of Service Providers
Concluding contracts as an agent or intermediary for providers of Transportation and Other Services in connection with their provision to travelers. -
Providing Travel Services Using Third-Party Facilities
Providing Transportation and Other Services to travelers by using transportation or accommodation facilities operated by third parties. -
Intermediation for Related Services
Acting as an agent, intermediary, or broker for travelers in relation to services associated with Transportation and Other Services, in conjunction with the activities described in items 3 through 5 above. -
Intermediation on Behalf of Service Providers
Acting as an agent or intermediary for providers of services related to Transportation and Other Services, in conjunction with the activities described in items 3 through 5 above. -
Incidental Travel Services
Providing services incidental to travel arrangements, such as accompanying or guiding travelers, acting as an agent for administrative procedures (including passport-related applications), and other convenience services for travelers, in connection with the activities described in items 1 and 3 through 5 above. -
Travel-Related Consulting
Providing consultation services related to travel.
💡Activities Generally Not Considered “Travel Operator Business”
The following activities are commonly regarded as outside the scope of regulated travel operator business:
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Ticketing services performed on behalf of transportation operators.
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Securing only services unrelated to transportation or accommodation (e.g., stand-alone tour guide services).
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Direct provision of transportation, accommodation, or related services by transportation or accommodation operators themselves.
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Activities that do not involve a direct contractual relationship with the traveler, such as merely accompanying a visitor during transportation.
1.2. Travel Agent Business (旅行業者代理業)
A travel agent is in charge of concluding agreements with travelers on behalf of Travel Operators in exchange for remuneration. Travel agents are therefore in charge of finding travelers for travel plans established by Travel Operators.
1.3. Travel Service Provision Business (旅行サービス手配業)
The travel service provision business consists of concluding contract as an agent, intermediary or broker of a Travel Operator with transportation or accommodation operators for the provision of transport or other services to traveler in exchange for remuneration.
2. Scope of Services under each Type of Travel Operator License
Under the Act, travel operators are classified into four categories and are subject to different requirements for registration:
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Type 1 Travel Operator,
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Type 2 Travel Operator,
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Type 3 Travel Operator, and
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Regional Travel Operator.
Depending on their categories, travel operators are allowed to handle different tourism products including:
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Organized planned tours (募集型企画旅行), where Travel Operators make travel plans (specifying the destination, the dates, the details of the transportation or accommodation services and the fees) first and then recruit travelers. Example: package tours.
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Order-made planned tours (受注型企画旅行), where Travel Operators make travel plans as ordered by travelers. Example: school excursions, group travels.
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Arranged tours (手配旅行), where Travel Operators arrange hotels and transportations for the travelers based on the request of the travelers.
Specifically, Type 1 Travel Operators can handle all domestic and international tours, as well as sales of tourism products by other Travel Operators.
Type 2 and 3 Travel Operators cannot conduct overseas organized planned tours on their own, and Type 3 Travel Operator can conduct domestic organized planned tours on their own only within or adjacent to the area of the municipality of its office. Regional Travel Operators, as the name implies, can conduct all tours only within or adjacent to the area of the municipality of its office.
The scope of services and registration requirement among these categories are summarized in the following table.
3. Surety Bond Obligation
In order to register, Travel Operators need to deposit a surety bond with the Legal Affairs Bureau (Article 7) and to maintain a sufficient financial basis as measured by the so-called Reference Assets (Article 6, Paragraph 1, Item 10).
These requirements are intended for the protection of travelers due to the consideration that tourism products are intangible yet relatively expensive, and troubles may occur if fees are paid but the travel service is not delivered (as desired). The amount of the surety bond to be deposited depends on transaction volumes.
Instead of depositing the Surety Bond, a Travel Operator may deposit a Contribution of Payment Guarantee (弁済業務保証金分担金) to a travel agency association (旅行業協会) where it is an insured member (Article 53),in an amount equivalent to 20% of the required Surety Bond.
Please check below the amount you will need to deposit as Surety Bond or Contribution of Payment Guarantee.
Currently, there are two travel agency associations existent in Japan: JATA (Japan Association of Travel Agents, 日本旅行業協会) and ANTA (All Nippon Travel-Agents Association, 全国旅行業協会). Joining either association entails a similar process of application and reviewing, except that JATA reviews applications on a timely basis and ANTA reviews applications once every two months. The fee for JATA membership is JPY 800,000 for admission and JPY 350,000 annually, while the fee for ANTA membership depends on the location of principal office and the type of the travel agency (for Type 3 Travel Operator in Tokyo, the amount is JPY 800,000 for admission and 61,000 JPY annually).
4. Certified Travel Supervisor (旅行業務取扱管理者)
Both the Travel Operator and Travel Agent need to appoint at least one Certified Travel Supervisor (旅行業務取扱管理者) for each of its office, in order to manage and supervise affairs to ensure fairness in transactions, safety of travel and convenience of travelers (Article 11-2). There are three types of Certified Travel Supervisor qualifications:
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Comprehensive Certified Travel Supervisor (総合旅行業務取扱管理者) can be appointed at any office;
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Domestic Certified Travel Supervisor (国内旅行業務取扱管理者) can only be appointed at offices dealing exclusively with domestic travels;
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Regionally-limited Certified Travel Supervisor (地域限定旅行業務取扱管理者) can only be appointed at offices dealing exclusively with travels within or adjacent to the area of the municipality where the office is located.
Qualifications of Certified Travel Supervisor are obtained by passing the corresponding exams. Currently, the exam for Comprehensive Certified Travel Supervisor is administered by JATA and the exam for domestic ones is administered by ANTA respectively, as delegated by the Commissioner of Japan Tourism Agency (Article 69). As regionally-limited Certified Travel Supervisor is a newly-established category, its exam is administered by Japan Tourism Agency.
In addition, Certified Travel Supervisors also need to receive periodic training every five years organized by travel agency associations (Article 11-2, Paragraph 7).
In case the number of employees hired at a specific office reaches the number of 10 employees, 2 Certified Travel Supervisors will be required for such office.
5. Application Process for Type 1 Travel Operator Registration
A Type 1 Travel Operator registration typically follows a structured process involving both the Japan Tourism Agency and the competent Regional Transport Bureau. In practice, the workflow is as follows:
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Eligibility and requirements check (registration requirements review and gap analysis)
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Compliance consulting to meet registration conditions (as needed)
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Preparation and collection of required documents
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Membership procedures with JATA (Japan Association of Travel Agents)
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Receipt of JATA “membership confirmation” (入会確認書)
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Hearing by the Japan Tourism Agency
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Submission of the registration application to the competent Regional Transport Bureau
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Substantive review by the Japan Tourism Agency
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Issuance of registration notice by the Regional Transport Bureau
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Payment of the Contribution of Payment Guarantee (弁済業務保証金分担金)
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Submission of proof of payment to the authority
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Commencement of operations
Timeline: approximately 4 months in total. The Japan Tourism Agency’s review period alone generally requires around 2 months, and this portion is typically difficult to accelerate as an administrative matter.
6. Our Support
We assist clients with registration as Travel Operators, Travel Agent Businesses, and Travel Service Provision Businesses.
For an efficient initial consultation, please prepare the following documentation (if available):
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Company registry certificate (登記簿／履歴事項全部証明書)
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Articles of incorporation (定款)
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Most recent balance sheet and profit & loss statement
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Copy of the Certified Travel Supervisor qualification certificate (旅行業務取扱管理者の合格証)
