"Management Company as Manager" Method Added to Important Matters Explanations Under the Real Estate Transactions Act (From April 1, 2026)A new item is added to the important explanation before you buy a condominium
In its December 2025 amendment to the Enforcement Regulations of the Building Lots and Buildings Transaction Business Act, MLIT added matters that real estate agents must explain in transactions of condominiums that have adopted the management-company-as-manager method. It takes effect on April 1, 2026. The interpretation guidelines and the sample form for the explanation of important matters (Attachment 3) were also amended.
- November 6, 2025Cabinet order accompanying amendments to the Forest Management Act and the Forest Act (changes the important matters; effective April 1, 2026)
- December 1, 2025MLIT Order No. 117 (adds matters on the manager method and revises the signboard size)
- December 15, 2025Amending order to the Enforcement Regulations and partial amendment of the interpretation guidelines (Notice No. 452)
- April 1, 2026The new sample form for explaining important matters and other changes apply
Key points
- An amending order dated December 15, 2025 (Cabinet Office and MLIT Order No. 2) adds the important matters to be explained when the management-company-as-manager method is adopted (Article 16-2 of the Regulations). It takes effect on April 1, 2026
- In this method, the management company also serves as the association's manager (representative) and receives or places orders for work. Because of conflict-of-interest concerns, the amended Condominium Ownership Act and related laws require prior explanation to owners
- MLIT Order No. 117 of December 1, 2025 covers adding important matters on the manager method and revising the size of the signboard (effective April 1, 2026, with some parts effective December 1, 2025)
- The "Interpretation and Application of the Building Lots and Buildings Transaction Business Act" was partially amended on December 15, 2025 (Notice No. 452). The text and Attachment 3 (sample form for explaining important matters) are covered; the new version applies from April 1, 2026
- A cabinet order accompanying amendments to the Forest Management Act and the Forest Act (November 6, 2025) also takes effect on April 1, 2026 and changes the content of the important matters to be explained
What to do in practice
- Check that your explanation form for important matters has been switched to the new sample form (Attachment 3) from April 1, 2026
- Set a procedure to confirm with the association or management company whether a condominium uses the management-company-as-manager method
When real estate companies sell or rent a house or condominium, they must explain important things before the contract. From April 1, 2026, a new explanation is added for cases where the company managing the condominium also serves as its representative.
- 1. Hand over managementThe condominium hands its management to a management company
- 2. Also the representativeThat company may also serve as the association's representative (manager)
- 3. The worryThe side ordering work and the side receiving it become the same, creating a conflict-of-interest worry
- 4. More to explainReal estate companies must explain more important items about condominiums using this way
Points
- There is a way where a condominium hands its management to a company, and that company also serves as the representative
- A company that is also the representative can be the side that orders work, so how money is used needs care
- So real estate companies must explain more items about condominiums that use this way
What the words mean
- Explanation of important matters
- When a real estate company explains important conditions to buyers or renters before a contract
- Management-company-as-manager method
- A way where the condominium's management company also serves as the representative (manager) of the management association
- Ministry of Land, Infrastructure, Transport and Tourism (MLIT): MLIT: Amendments and interpretation of the Building Lots and Buildings Transaction Business Act
- Ministry of Land, Infrastructure, Transport and Tourism (MLIT): MLIT: Amended laws to facilitate condominium management and regeneration (October 2025)
This article summarizes and explains materials published by government agencies and is not advice on any individual case. Rules can change, so for actual procedures and decisions always check the latest original materials and consult professionals such as tax accountants or labor and social security attorneys. English, Simplified Chinese and Traditional Chinese versions are translations prepared from the Japanese articles for convenience. If anything differs, the Japanese text and the original source take precedence.