Travel Agency Registration and Unlicensed Taxis: Things to Watch Out for When Working as a Part-Time Interpretive Guide | Distinguishing Between Guiding, Arrangements, and Transportation Services

Key Points of This Article

The laws governing side jobs as an interpreter-guide are primarily the Interpreter-Guide Act, the Travel Agency Act, and the Road Transport Act.
If you create and sell travel itineraries, or arrange transportation and accommodations in exchange for compensation, you are required to register as a travel agency. Even if you only receive a guide fee, planning an itinerary is considered a travel business activity.
If you accept payment and transport customers in your private vehicle without registration, you are operating an “unlicensed taxi” and are in violation of the Road Transport Act.
It is easier to comply with the regulations if you let clients decide on their destination, transportation, and lodging, while the guide focuses solely on providing guidance and interpretation.

Three Laws Related to Interpretive Guides

Interpreter-Guide Act: Only certified individuals may use the title “Certified Interpreter-Guide.” However, providing guidance itself does not require certification (“Is Certification Required for Interpreter-Guides?”).
Travel Agency Act: There are regulations governing the creation and sale of travel itineraries, as well as the arrangement of transportation and lodging.
Road Transport Act: There are regulations governing the transportation of clients by car in exchange for a fee.

Activities Requiring Travel Agency Registration

Under the Travel Agency Act, a business that performs the following activities for compensation is defined as a “travel agency” (Travel Agency Act, Article 2, Paragraph 1; e-Gov Law Search: Travel Agency Act).

Creating a travel plan that specifies the destination, itinerary, transportation, lodging, and fees, and entering into contracts with transportation providers and lodging facilities on one’s own behalf
Making reservations for transportation or lodging on behalf of travelers, acting as an intermediary, or facilitating such arrangements
Providing consultation regarding travel

Registration is required to operate a travel business (Article 3 of the Act), and operating a travel business without registration is punishable by imprisonment for up to one year or a fine of up to 1 million yen (or both) (Article 74 of the Act). Information on the types of registration and where to apply is summarized in the Japan Tourism Agency’s “Overview of the Travel Agency Act.”

Even if you only charge a guide fee, planning an itinerary constitutes a travel business

According to Kagoshima Prefecture’s guidelines, the act of creating and selling an itinerary—including arrangements for destinations and transportation—at the request of a traveler is cited as an example of a travel business. The guidelines state that even if only “guide fees” are received, the activity constitutes a travel business if the itinerary or other travel arrangements are planned or organized (Kagoshima Prefecture: Activities Requiring Travel Business Registration).

Guidelines for Determining the Threshold

Whether registration is actually required is determined on a case-by-case basis. If you are unsure, please consult the travel agency registration office in the prefecture where you reside. As a general guideline, the following considerations can help clarify the distinction:

Likely to comply with regulations: Accompanying a customer on the day of travel and providing guidance or interpretation in a foreign language, based on the destination, itinerary, transportation, and lodging that the customer has chosen themselves.
May constitute a travel business: Creating and selling itineraries that include transportation and lodging; making reservations for transportation or lodging on behalf of customers and receiving a commission; charging fees for itinerary planning or travel consultation.

Be Aware of “Unlicensed Taxis” When Providing Transportation in a Private Vehicle

Transporting passengers for a fee using a private vehicle without a permit from the Minister of Land, Infrastructure, Transport and Tourism (unlicensed taxi service) constitutes a violation of the Road Transport Act (Chubu Regional Transport Bureau: About Unlicensed Taxi Services).The Road Transport Act stipulates that private vehicles may not be used for paid transportation, except in certain cases such as during disasters (Article 78; e-Gov Law Search: Road Transport Act).

Cases Where a Transport Permit or Registration Is Not Required

A document compiled by the Hokkaido Regional Transport Bureau summarizing the Ministry of Land, Infrastructure, Transport and Tourism’s guidelines sets forth the following principles (Hokkaido Regional Transport Bureau: Guidelines on Transportation Not Requiring a Permit or Registration).

When transporting passengers free of charge, it is permissible to receive reimbursement for actual expenses such as gasoline, tolls, and parking fees.
When a tourist guide holding a qualification recognized by the national government or a local government transports a customer for the purpose of providing a tour, and does not receive a fee specifically designated for transportation, no permit or registration is required.
However, even if the person identifies as a guide, a permit or registration is required if the activity consists solely of transporting customers to their destination.

Unlicensed guides do not fall under the second example mentioned above. Whether a permit or registration is required is ultimately determined on a case-by-case basis. If in doubt, it is safest to use trains, buses, or taxis for transportation and avoid transporting customers in your own vehicle.

Things to Decide in Advance to Avoid Problems

Let the client decide on the destination, itinerary, transportation, and lodging (it’s fine to make recommendations, but ask the client to handle the reservations).
In your estimate, clearly separate the fees for guiding and interpretation from the expenses the client will pay themselves (such as transportation, admission fees, and meals)
Confirm the mode of transportation and who will pay for it before the day of the tour

Post your tour and interpretation plans on jpwork hub

jpwork hub is a service that connects international visitors to Japan with people living in Japan who want to put their English or other foreign language skills to use. By registering as a partner, you can list plans—such as interpretation, on-site accompaniment, sightseeing tours, and dining recommendations—at rates you set yourself.You can decide for yourself whether to accept incoming requests based on your schedule and the details of each one, so you can use this as a side job just on weekends.

Registration is free, and fees are charged only when a request is confirmed and payment is processed. Since we’ve just launched the service, we can’t guarantee a specific number of requests, but we welcome those who would like to join us as our first partners to help grow the service together.

When creating a plan on jpwork hub, it’s easiest to follow the guidelines explained in this article by specifying the details of your tour or interpretation services and the fee, while leaving transportation and accommodation reservations to the client.

View details on partner recruitment

Frequently Asked Questions

Does simply recommending tourist itineraries qualify as a travel business?

The Travel Agency Act defines “providing travel-related consultation” in exchange for compensation as part of the travel business. Please distinguish between making recommendations during a guided tour and charging a fee for itinerary planning or consultation itself. If you’re unsure, please consult the travel agency division at your prefectural government office.

Is it okay to purchase Shinkansen tickets on behalf of a customer?

If you receive a commission for arranging transportation on behalf of a customer, this may constitute a travel business. To be on the safe side, have customers purchase tickets themselves or use a travel agency.

Is it okay to drive my own car to tour sightseeing spots and receive only a guide fee?nd accept only a guide fee?

If you are an unlicensed guide, this does not fall under the “examples where a license or registration is not required” as outlined in government documents. Depending on the circumstances, this could be deemed an unlicensed taxi service, so we recommend using trains, buses, or taxis.

Photo credit: The approach to the Senbon Torii (Thousand Torii Gates) at Fushimi Inari Taisha in Kyoto: Luka Peternel / CC BY-SA 4.0 (cropped and resized) Wikimedia Commons.