Permits, building rules and landlord approvals: what you need before starting a fit-out in Tokyo

Tokyo fit-outs are governed by overlapping layers of public regulation and private building rules. Understanding them before design is finalised can prevent delays, redesign and unexpected costs.

A company leasing an office in Tokyo can sign the contract, appoint a designer and agree a construction budget—and still not be ready to build.

The reason is that “permission” for a fit-out is not a single approval. Depending on the project, the tenant may need to satisfy the landlord, building management, the Building Standards Act, Tokyo Fire Department requirements and other regulations before construction or occupation can begin.

Some interior projects need no formal building-confirmation application at all. That does not mean they are unregulated. In practice, fire-safety submissions and landlord design reviews can have a greater influence on an ordinary office fit-out than a conventional planning permit.

The important question is therefore not simply “Do we need a permit?”

It is: which approvals apply to this particular building, use and scope of work—and when do they need to be resolved?

Not every Tokyo fit-out needs a building permit

For international companies, one source of confusion is the assumption that every interior renovation needs the equivalent of a European or North American building permit.

That is not how most straightforward Tokyo office fit-outs work.

An office-to-office refurbishment that changes partitions, finishes, furniture, lighting and services without materially changing the building structure or legal use may not require a new building-confirmation application. However, the project must still comply with the Building Standards Act and related regulations.

A change of use can alter the situation. Tokyo Metropolitan Government notes that, following amendments effective in 2019, a building-confirmation application is no longer required when the portion being converted to certain special uses is 200 m² or less. Importantly, Tokyo also stresses that exemption from the application does not exempt the project from complying with the law.

For larger changes of use—to uses such as hotels, restaurants or other categories treated as special buildings under the Building Standards Act—a confirmation procedure may be required. Major alterations or structural work can create additional requirements.

This distinction is important commercially.

A company moving from one conventional office into another is in a very different regulatory position from a tenant converting an office floor into a restaurant, clinic, showroom or other public-facing use.

The regulatory review should therefore begin before the layout is fixed, not after construction drawings have been completed.

The three approval layers: authority, fire department and landlord

The easiest way to understand a Tokyo fit-out is to separate three different systems.

These systems overlap but they are not interchangeable.

Receiving landlord approval does not mean that a project complies with public law. Conversely, a technically legal design can still be rejected by the landlord if it conflicts with the building’s own standards.

This private approval layer is particularly important in larger Tokyo office buildings.

Commercial buildings commonly divide construction responsibilities into A, B and C works. MLIT itself uses the familiar A/B/C terminology when describing the relationship between base-building and tenant works. In common industry practice, A works are owner-controlled and owner-funded; B works are generally requested and paid for by the tenant but carried out through the owner’s designated contractor; and C works are tenant-controlled interior works. The exact boundary varies by property and must be checked against the individual building’s construction classification schedule.

This can have a significant impact on budget.

Moving an air-conditioning outlet or modifying a fire-safety system may appear to be a small design change, but if it falls under B work the tenant may have to use the landlord’s nominated contractor rather than competitively tendering the work.

The A/B/C schedule should therefore be reviewed before the lease economics and fit-out budget are considered final.

Fire-safety approval is often the critical fit-out process

For many ordinary office projects in Tokyo, the most immediate statutory process is not building confirmation but fire-safety review.

Tokyo Fire Department guidance is explicit: when a tenant such as an office or shop carries out internal partition work, a Fire Prevention Object Construction Plan Notification (bōka taishōbutsu kōji-tō keikaku todokedesho) must generally be submitted at least seven days before work starts. A separate Use Commencement Notification must generally be submitted at least seven days before occupation begins.

The Fire Department identifies refurbishment involving changes to room layout or ceiling height as examples requiring notification. Its current guidance notes that low partitions that do not reach the ceiling are treated differently, illustrating how apparently minor design decisions can change the compliance process.

Partitions matter because they can affect much more than room arrangement.

A new meeting room may alter:

• escape routes;
• smoke movement;
• sprinkler coverage;
• fire-alarm detector positions;
• emergency lighting;
• exit signage;
• occupant capacity.

If automatic fire alarms, emergency guidance lights or other fire-safety equipment need to be moved or added, further notifications may be required. Tokyo Fire Department guidance indicates that certain fire-equipment works require notification 10 days before work begins, while installation-completion notifications can be due within four days after completion.

The Fire Department can also inspect the premises before use. Its official guidance states that an inspection may be required after submission of the Use Commencement Notification, depending on the case.

For project scheduling, this means that the opening date should not be set solely by the contractor’s construction programme.

Regulatory submissions and inspections need to be built into it.

Landlord rules can be stricter than the law

The most underestimated document in a Tokyo office project is often not a regulation but the building manual.

Before design begins, the project team should obtain the lease, construction regulations, fit-out manual, A/B/C work classification, base-building drawings and restoration requirements.

Building management may control issues including:

• allowable contractors;
• working hours and noisy-work periods;
• freight-elevator reservations;
• loading access;
• protection of common areas;
• temporary power and water;
• ceiling and flooring systems;
• approved materials;
• drilling into slabs or walls;
• signage;
• security systems;
• waste removal.

These restrictions are building-specific.

A design that works perfectly in one Grade-A office tower may require substantial adjustment in another.

Restoration obligations also deserve attention at the beginning rather than at the end of the lease. In many commercial offices, alterations made for the tenant have to be removed when the premises are returned. Items classified as tenant-funded B or C work can therefore create two costs: installation now and restoration later.

From a business perspective, this changes how design should be evaluated.

Moving a major mechanical service to achieve a slightly cleaner ceiling may be technically possible, but if the intervention requires expensive B work and full reinstatement five years later, the lifecycle value may be poor.

Good fit-out design therefore considers CAPEX, lease duration and restoration cost together.

The hidden approval: asbestos surveys before renovation

Another requirement can surprise international clients because it is unrelated to the visible design.

Japan requires an asbestos pre-construction survey for building demolition and renovation work. The Ministry of Health, Labour and Welfare states that the presence or absence of asbestos-containing material must be investigated before relevant renovation or demolition work is carried out.

The survey obligation is broader than the reporting threshold.

For building renovation work with a total contract value of ¥1 million or more including tax, the result must also be reported electronically to the relevant authorities, irrespective of whether asbestos is ultimately found. Smaller works may avoid the reporting requirement, but the underlying pre-survey requirement still applies.

In an older Tokyo office, this can affect demolition strategy, programme and cost.

The correct moment to investigate is therefore during due diligence or early design—before demolition is priced and certainly before work begins.

It is a good example of why fit-out compliance cannot be reduced to a simple permit checklist.

The age of the building, the existing materials, the proposed work and the tenant’s use all matter.

Approvals should shape the fit-out before design freeze

The safest sequence is to treat regulatory and landlord reviews as part of design development.

Before signing off the final layout, the project team should establish:

1. the legally registered existing use and proposed use;
2. whether building confirmation or a change-of-use procedure is potentially required;
3. the landlord’s construction regulations and A/B/C work boundaries;
4. Tokyo Fire Department filing requirements;
5. the effect of partitions on egress and fire-protection systems;
6. whether accessibility or other use-specific regulations apply;
7. asbestos-survey requirements;
8. approval, construction and inspection lead times;
9. restoration obligations at lease end.

This early work is inexpensive compared with redesigning a completed tender package.

At MB-AA, this coordination forms part of the practical side of workplace design in Tokyo. Our completed headquarters projects for companies including Intesa Sanpaolo, Pirelli, Piaggio Group and other international clients demonstrate the need to coordinate design ambitions with local contractors, building systems and implementation requirements. MB-AA’s own project portfolio describes the studio’s role across architecture, interior design and turnkey delivery in Japan.

The strategic lesson is straightforward.

Permits are only one part of fit-out approval in Tokyo. A project may require little formal building permitting and still face important fire-department, landlord and technical constraints.

The most efficient approach is to identify those constraints before they become design changes.

For companies entering Japan, this protects not only compliance but also programme and budget. The earlier the building rules become design inputs, the less likely they are to appear later as unexpected costs.

MB-AA supports international companies through the design and delivery of workplace projects in Tokyo, including coordination with building management, local consultants and contractors from initial due diligence through construction.

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Further reading

Tokyo Fire Department — Guidance for new commercial tenants
Requirements for construction-plan and use-commencement notifications. Tokyo Fire Department tenant guidance

Tokyo Fire Department — Fire Prevention Object Construction Plan Notification
Guidance on renovation, partition and layout changes before construction. Construction notification guidance

Tokyo Metropolitan Government — Building Standards Act guidance
Official information on building-confirmation procedures and competent authorities in Tokyo. Tokyo building regulations

Ministry of Health, Labour and Welfare — Asbestos Information Portal
Requirements for pre-construction asbestos surveys and reporting. Asbestos survey guidance

MLIT — Tenant and base-building design and construction process
Overview of the division between base-building and tenant fit-out works. MLIT tenant fit-out process