1. Overview
I will now explain the necessary procedures for starting a matching business or dating club.
Please note that you must notify the Tokyo Metropolitan Public Safety Commission (or the police chief with jurisdiction over the area) at least 10 days before the day you intend to start operations, for each location where you will establish your business or office.
This ordinance aims to protect children and includes provisions such as "not accepting customers under the age of 18," "regulations on advertising and promotions," and "regulations on the areas where businesses can be established."
Please note that operating a business without following the proper procedures and filing the necessary notifications may result in administrative penalties.
Furthermore, after filing the notification, you will need to post a sign that says "No Entry for Minors."
As of January 2023, this ordinance only applies to Tokyo. Therefore, corporations or sole proprietors who do not have an office or business location in Tokyo and do not conduct matching businesses are not required to file a notification.
However, since there may be changes in the future, the scope may expand, and it cannot be said with certainty that it will not be necessary nationwide, we recommend that those operating in other prefectures also review the content and understand it before conducting their business activities.
2. Required documents and information
The following information is based on examples of notifications filed in Tokyo.
The Tokyo Metropolitan Police Department's website states that the following documents and supporting materials are required.
【Required documents】
Notification of Commencement of Business for a Dating Club
[Attached documents (for sole proprietors)]
[Attached documents (for corporate sales)]
3. Notification
Once you have prepared the application form and supporting documents, submit them to the police station that has jurisdiction over the area where your business is located.
If you have any questions about the procedures, you can also consult with the police station.
According to the Tokyo Metropolitan Police Department's website, you can also consult the following contact points for other general matters.
Tokyo Metropolitan Police Department, Public Security Division, Adult Entertainment Business Section
Phone: 03-3581-4321 (Tokyo Metropolitan Police Department main number)
4. About the business model of dating clubs
To operate a dating club (escort service), all that is required is the submission of a "Dating Club Business Commencement Notification Form."
When you break down the concept of a dating club, it essentially means a business that matches male and female clients (mediates dating).
While dating clubs do have some connection to the internet, such as setting up websites and creating sites for members, they are a different type of business from "internet-based dating services" like dating sites.
Furthermore, businesses where encounters occur within the premises, often referred to as "meeting cafes," fall under the category of "store-based sexual entertainment businesses," which are required to register under the Entertainment Business Act, but they are a different type of business from dating clubs.
A dating club (or escort service) is a legal membership-based service where men and women can meet freely through introductions.
We would appreciate it if you would abide by the rules and strive for sound business practices.
5. About offices and branch offices
The "Dating Club Business Commencement Notification Form" includes an option to select whether you are registering as an office or a business establishment. We will explain the difference between an office and a business establishment.
The office is a place where customers (members) do not come and go.
A sales office is a place where customers (members) come and go.
For example, if a place of business only performs administrative tasks, has no visitors, and conducts interviews and consultations at an external hotel lounge each time, it would be considered an office. However, if interviews, consultations, and profile photo shoots are conducted at the place of business, and there are visitors, it would be considered a sales office.
It is important to note that if you plan to operate as a business office, you need to confirm before signing the lease agreement whether you can obtain permission from the owner and whether the area where the office is located is not a prohibited area.
6. Points to note regarding regulations
There are several requirements that must be met by those operating a dating club.
In addition to submitting the "Notification of Commencement of Dating Club Business," the "Establishment of an Employee List" is also required.
There are restrictions such as "not allowing minors as customers and posting signs near the entrance prohibiting minors from entering" and "advertising regulations."
Regarding advertising regulations, advertisements cannot be displayed in places where minors can see them.
Flyers and leaflets are generally not usable in public places; advertising and promotion are only possible in places where minors don't typically frequent, such as hostess clubs, bars, and mahjong parlors.
Therefore, basic sales activities will likely involve using the internet and social media.
Furthermore, please note that if you outsource advertising, the business operator has an obligation to instruct the outsourced company to ensure that they do not violate any regulations.
7. How to request assistance from an administrative scrivener or similar professional
While the PATOLO division does not handle the filing of "Dating Club Business Commencement Notification Forms," you can request the procedure from an administrative scrivener who is knowledgeable about adult entertainment business licenses and the establishment of dating sites.
While there are fees involved, having someone handle the procedures for you might be better for busy owners who don't want to spend time and effort on the paperwork themselves.
Furthermore, if you are planning to establish a company or register as a sole proprietor, you may be able to get advice on all of these matters at once, so why not consult with your nearest administrative scrivener's office?
Many law firms offer free consultations, so it might be a good idea to consult with several firms and then choose the one you feel is best.
The cost for registering as a business establishment through the "Dating Club Business Commencement Notification Form" procedure seems to be around 10 to 20 yen.
For more details, please consult with the administrative scrivener you are seeking advice from.