Japan's Ministry of Land, Infrastructure, Transport and Tourism (MLIT) has opened a public comment period, running from August 21 to September 19, 2026, on new administrative penalties for hire-car operators that fail to document their pickups. The trigger is a paperwork gap that has let illegal airport touting slide.
Under existing rules, operators running general passenger vehicle transport services may only accept hire-car bookings at their registered offices, not through curbside solicitation. MLIT says that alongside rising inbound tourist numbers, illegal off-site touting has occurred at airports, and its inspectors have struggled to prove violations because there is currently no reliable record of what was actually agreed between operator and passenger.
The fix is procedural rather than punitive on its face: MLIT plans to require operators to create and keep records of the transport contract itself, plus written operation instructions, whenever they run "hire transport" using vehicles not restricted to a specific passenger group under Article 86(1) of the Road Transport Act. The point of the paperwork mandate is investigative, making it easier for auditors to catch and prove violations after the fact, not merely to add red tape.
What gives the plan teeth is a new schedule of vehicle-suspension penalties attached to the recordkeeping duties themselves. Fail to issue a transport acceptance note and a first offense costs 60 vehicle-days off the road, doubling to 120 for a repeat. The same 60-to-120-day scale applies to failing to retain a copy of that note. Sloppier paperwork, meaning an acceptance note with missing required fields, draws a warning on first offense and 10 vehicle-days on repeat. Failing to prepare, issue, or carry a written operation instruction costs 30 vehicle-days initially and 60 on repeat, with the same warning-then-10-day track for incomplete entries.
| Violation | First Violation | Repeat Violation |
|---|---|---|
| Failure to issue transport acceptance note | 60 vehicle-days | 120 vehicle-days |
| Incomplete entries on acceptance note | Warning | 10 vehicle-days |
| Failure to retain copy of acceptance note | 60 vehicle-days | 120 vehicle-days |
| Failure to prepare, issue, or carry operation instruction | 30 vehicle-days | 60 vehicle-days |
| Incomplete entries on operation instruction | Warning | 10 vehicle-days |
| Failure to retain operation instruction | 30 vehicle-days | 60 vehicle-days |
MLIT's draft schedule targets a notice and enforcement date of October 1, 2026, though that remains a proposal pending the comment period's outcome. Submissions must reach the ministry in Japanese, via the e-Gov online form, email to the Passenger Transport Division, or post to its Kasumigaseki office, and MLIT may publish commenters' names alongside their submissions unless anonymity is requested. The case is filed under Road Transport Act Article 40 as case number 155260928.
For hire-car and limousine operators serving Japan's airports, the practical shift is that a missing or incomplete pickup record becomes a punishable violation in its own right, giving inspectors a paper trail to check even when the underlying touting is hard to pin down. The comment window closes September 19, 2026.