Park-PFI and Park Management Policy 2026 — 165 Parks Reached, TSUNAG and Guideline Updates, and the Coming 20-Year Maturity Problem
Park-PFI, created by the 2017 Urban Park Act revision, has spread to more than 165 parks as of March 2026. Meanwhile, the 2024 Urban Greenery Act revision introduced TSUNAG (effective Nov 2024), and the Park-PFI Activation Guidelines were revised in May 2025. The Regulatory Reform Council proposed extending the contract validity period in February 2025, anticipating the 2037 'first-generation 20-year maturity problem.' This guide maps the policy state, comparison with the Designated Manager System, international models, and expert critiques.
TL;DR
- Park-PFI was created in 2017 and has reached 165+ parks as of March 2026, anchored by three special exemptions (20-year permit, 12% building coverage, ancillary facilities)
- No direct revision bill of the Urban Park Act for the 2026 Diet session is currently confirmed; the confirmed updates are the November 2024 Urban Greenery Act revision (TSUNAG) and the May 2025 Park-PFI Guideline revision
- The Regulatory Reform Council proposed extending the contract validity beyond 20 years in February 2025, anticipating the 'first-generation 20-year maturity problem' arriving from 2037 onward
Executive Summary
Park-PFI (Public Solicitation Management System), created by the 2017 Urban Park Act revision, has spread to 165+ parks as of March 2026. Anchored by three exemptions (20-year permit, 12% building coverage, ancillary facilities), the system has taken hold as a mechanism to "earn within the park to fund public improvements."
The November 2024 Urban Greenery Act revision created TSUNAG (Authorized Premium Green Space Conservation Plan), and the May 2025 Park-PFI Activation Guideline revision followed. No direct revision bill of the Urban Park Act itself for the 2026 Diet session is currently confirmed (as of 2026-05-29).
The next major issue is the "20-year maturity problem." First-generation Park-PFI cases (2018–2019 authorizations) reach their 20-year maturity between 2037 and 2039. Re-solicitation rules, asset succession, and revenue-facility ownership require institutional preparation. The Regulatory Reform Council proposed extending the validity period in February 2025.
165
Park-PFI activations (as of March 2026)
20
Authorized validity period (extended from 10)
12
Special-exemption building-coverage ratio (normal 2%)
2037
First-generation Park-PFI 20-year maturity arrives
Park-PFI Achievements (2017 Revision)
Background, three exemptions, financial support, relationship to existing facility-permit system
Background
In June 2017, the Urban Park Act was revised as part of the "Act on Partial Revision of the Urban Greenery Act and Others." The background was threefold:
- Aging park facilities and lack of renewal funding (local fiscal constraint)
- Stagnant park visitor numbers and declining appeal
- The need to bring in private creativity and capital for park improvements
Three Exemptions
Park-PFI is a system in which "a private operator who jointly delivers (a) revenue facilities (solicitation-target park facilities such as restaurants/shops) and (b) public-portion improvements (designated park facilities like paths, plazas, lighting) funded by those revenues is selected through public solicitation."
| Exemption | Normal | Park-PFI |
|---|---|---|
| 1. Facility-permit period | up to 10 years | ★up to 20 years |
| 2. Building coverage | 2% overall (up to 12% with small-scale exemption) | up to +10% for solicitation-target facilities (max 12%) |
| 3. Ancillary facilities | not allowed | bicycle parking, billboards, signage, etc. allowed |
Financial support: Half of the municipal portion of designated park facility (public) improvement costs is supported by national subsidies through the "Public-Private Bustling Hub Creation Project" via the Social Capital Integration Grant.
165 Parks and the "Hibiya Problem"
Progress
| Time point | Active parks | In service |
|---|---|---|
| End of FY2021 | 102 | 39 |
| End of FY2023 | ~136 (incl. under consideration) | — |
| End of FY2024 | 165 (in service) | 105 |
| March 31, 2026 (latest) | 165+ | — |
Major cases include MIYASHITA PARK (Shibuya Ward), Nagoya Tsurumai Park, Osaka Tennoji Park (Tenshiba), and Fukuoka Tenjin Central Park.
The "Hibiya Problem": Zero Bidders
In 2023, the Hibiya Park Park-PFI solicitation (for the Hibiya Open-Air Concert Hall reconstruction) received zero bids. That a Park-PFI flagship venue saw no bidders surfaced the system's structural challenges.
Cited reasons:
- The scale of the public-improvement burden (theater reconstruction civil cost) was too large
- The revenue facilities alone could not recoup the investment within a viable horizon
- Difficulty reconciling existing-user continuity (the historic concert hall's traditional programming) with the institutional structure
The episode left the lessons that "Park-PFI is not universal" and that "depending on scale and location, conventional procurement or a standalone PFI may be more appropriate."
2024-2025 Policy Expansion (Confirmed)
TSUNAG Creation (Urban Greenery Act Revision, in force November 8, 2024)
The November 2024 Urban Greenery Act revision (Reiwa 6 Law No. 40) institutionalized:
- National "Green Basic Policy" (issued as MLIT Notice No. 1367 of Reiwa 6)
- Prefectural "Wide-Area Greenery Plan" system
- TSUNAG (Authorized Premium Green Space Conservation Plan): private operators draft greenery-conservation plans for national authorization
- Greenery purchase system by the Organization for Promoting Urban Development
- Statutory foundation for greenery-function enhancement projects (climate adaptation, biodiversity, well-being)
Impact on Park-PFI: TSUNAG promotes private investment for new greenery creation and existing greenery quality improvement, and is complementary to Park-PFI. However, the targets and procedures are distinct frameworks — do not conflate them.
Park-PFI Guideline Revision (May 30, 2025)
Revision history: August 10, 2018 → March 31, 2023 → May 30, 2025 (latest)
The May 2025 revised Guidelines PDF should be referenced.
Urban Park Act Operational Guidelines, 7th Edition (December 2024)
The 7th Edition Operational Guidelines is the latest version.
2026 Revision Outlook: Confirmed vs Unconfirmed
Unconfirmed: Direct Urban Park Act Revision Bill
No bill directly revising the Urban Park Act itself for the 2026 (Reiwa 8) Diet session has been confirmed as of 2026-05-29. A check of MLIT's "Diet-Submitted Bills" page and the Social Capital Improvement Council's Urban Planning Subcommittee on Park and Green Spaces minutes did not surface a Park-PFI direct-revision bill.
The accurate statement at time of writing: "Policy-reform discussions are progressing, but no direct revision of the Urban Park Act itself in 2026 has been confirmed at this time."
Regulatory Reform Council Proposal (February 2025)
Issues:
- Current: maximum Park-PFI authorization period is 20 years
- Challenge: 20 years is insufficient for some initial investments to be recouped, presenting outsized risk for small and mid-sized operators
- Proposal A: extend the authorization period itself beyond 20 years
- Proposal B: explicitly state in the solicitation guidelines that, after 20 years, continuation under standard Article 5(1) permits (up to 10 years) is possible
Currently, "20-year authorization + 10-year renewal" allows over 30 years of continuation in principle, but institutional clarification is lacking.
Differentiation from the Designated Manager System
Designated Manager System Challenges
The Designated Manager System (Local Autonomy Act Article 244-2, introduced 2003) is widely applied in park management but has surfaced the following challenges:
Structural challenges:
- Rising prices and wages outstrip designated-manager fees, pushing operators to deficit → withdrawal and zero-bidder issues
- Renewal cycle (5–10 years) instability discourages long-term operator investment
- Lack of facility-improvement function (designated managers can only operate existing facilities, not build new ones)
- Tension between diverse park uses and revenue management (community group free use vs revenue management)
Comparison
| Axis | Designated Manager | Park-PFI |
|---|---|---|
| Primary function | Delegated operation/management of existing facilities | New revenue-facility construction integrated with public improvements |
| Facility improvement | Generally not allowed | Constructs revenue + designated park facilities |
| Funding source | Designated-manager fee (public) | Private revenue + grant support |
| Period | 3–5 years (renewable) | up to 20 years (authorization) |
| Public burden | Relatively high | Reduced (leverages private investment) |
| Local participation | Local NPOs and groups can participate | Large companies advantaged (initial investment barrier) |
Combined Use and the FY2022 Review Committee Proposal
In a single park, combining "designated manager (whole park) + Park-PFI operator (revenue zone)" is institutionally possible.
The FY2022 Review Committee (7 meetings) proposed 'quality management and operation that more flexibly uses urban parks through public-private cooperation' and recommends combining multiple instruments. This is the current backbone document of park policy.
International Models
U.S. Conservancy/BID, U.K. National Trust/CIC, Singapore NParks
U.S.: Conservancy / BID
Central Park Conservancy: an NPO delegated management by the NYC Parks Department. Funded by donations (individual/corporate), management fees, and facility-use revenue. The "private-led" model in which a large share of public-management costs is covered by private donations.
Bryant Park (BID): a Business Improvement District funded by mandatory contributions from surrounding property owners. The "beneficiary-pays" model in which park value increases → surrounding property value increases → contributions flow back.
Differences from Japan: U.S. Conservancy is nonprofit and donation-dependent, while Japan Park-PFI assumes for-profit operators and revenue facilities. The U.S. BID is a statutory contribution system; Japan has no direct BID equivalent (Urban Renewal Special Districts provide a similar function).
U.K.: National Trust / CIC
National Trust: founded 1895, legally established under the 1907 National Trust Act. A private nonprofit that acquires and preserves nature and historic sites through purchases and donations. Member base of 6+ million (among the world's largest private conservation organizations). Not park-specific but a heritage-preservation organization.
National Lottery Heritage Fund (formerly Heritage Lottery Fund): a public fund distributing lottery proceeds to parks, nature, and cultural heritage restoration (1994–).
CIC (Community Interest Company): recently rising in U.K. local park management as a response to public park-budget cuts (austerity).
Differences from Japan: U.K. models center on nonprofit "social enterprises" as management entities, while Japan Park-PFI centers on for-profit private companies. The U.K. has a public greenery fund (lottery); Japan has the Social Capital Integration Grant.
Singapore: NParks
National Parks Board (NParks): a statutory government body (under the Ministry of National Development). Manages 9,000+ ha of parks, greenery, street trees, and nature reserves nationwide. The "City in Nature" strategy (through 2030) targets 200 ha of park expansion, 300 ha of naturalization, and 200 ha of high-rise greening.
Differences from Japan: NParks centrally manages all parks (centralized) vs Japan's municipality-by-municipality decentralization. Funded primarily by government budget, with low reliance on private revenue.
Expert Critiques
Pro and con arguments, including the 20-year maturity problem
Pro Side
- MLIT and proponents: indispensable for park maintenance/renewal under fiscal constraint. Private creativity improves appeal and convenience. A structural answer to social challenges (declining birthrate, aging, depopulation, infrastructure aging).
- Researcher (Yukio Uzui, Organization for Promoting Urban Development): emphasizes transparency in operator selection and alignment with park characteristics. Public-ness assured by zoning revenue facilities separately from public areas.
Con / Concerns
Ryotaro Iwami (Professor Emeritus, Saitama University), key arguments:
- "Park management by corporations is only executed insofar as corporations can profit"
- Revenue facilities have driven mass tree-cutting for profitability
- Resident movements have risen at over 100 implementations nationwide
- The public-ness of "free public access and diverse activity" is being eroded
- "Corporations are extracting deregulation (floor-area-ratio relaxation, etc.) in exchange for token greenery offerings"
Detailed in Iwami's article on Institute of Local Government Issues and the book Why the Trees in Parks Are Being Cut Down (Jichitai Kenkyusha).
Academic Research (Journal of the City Planning Institute, 2024) findings: an analysis of 45 nationwide Park-PFI cases identifies two issues:
- Insufficient consideration of community-group park use
- Risk of public-ness loss from installing revenue facilities on designated park (public-portion) areas
Small/local operator entry barriers: Park-PFI's initial investment burden (operator's self-financed portion of designated park facility improvements) is large, favoring large companies. Local SMEs and NPOs cannot enter, risking homogenization as national chain restaurants and convenience stores fill parks.
The 20-Year Maturity Problem (Next Major Issue)
First-generation Park-PFI cases authorized in 2017–2019 reach 20-year maturity between 2037 and 2039.
Structure of the challenge:
- Lack of institutional rules on "re-solicit or continue" at renewal
- How to treat ownership and residual value of existing (revenue) facilities upon re-solicitation
- Designated park facilities (public-improvement portions) transfer to park-manager ownership (relieving improvement-cost burden), while revenue facilities remain operator assets
- Facility succession issues if a different operator is selected through re-solicitation
Regulatory Reform Council proposal (Feb 2025): explicitly state in the solicitation guidelines that "post-20-year continuation methods (use of Article 5(1) permit) may be described" → giving operators long-term visibility to promote investment.
Outlook
Institutional adjustments expected by ~2030, and decision axes for municipalities and operators
Confirmed Directions
- Continued guideline revisions (May 2025 revised, periodic reviews expected from Reiwa 8 onward)
- Mutual use with TSUNAG (Park-PFI + TSUNAG together expanding private participation)
- Validity-period extension discussions at the Regulatory Reform Council (institutional adjustments anticipated following the February 2025 proposal)
In Discussion / Anticipated
- Response to the 20-year maturity problem: addressable at the ordinance/guideline level; legal revision may not be necessary, but concrete adjustments expected around 2030
- Promoting small / local operator entry: also identified by the FY2022 Review Committee. Flexible solicitation conditions and split solicitation are being tried in various municipalities
- Integration with carbon neutrality and biodiversity: alignment with TSUNAG and the Green Basic Policy requires adding environmental standards to Park-PFI projects
- Diffusion of park management plans: some municipalities (Takarazuka, etc.) have drafted plans; national guidance/mandating is unconfirmed at present
Municipal Decision Axes
- Three Park-PFI adoption preconditions: ① demand for revenue facilities (location, population) ② execution of market sounding ③ alignment with the Designated Manager System
- MLIT provides templates for solicitation guidelines (use is recommended)
- The latest 2026 Guideline (May 2025 version) must always be referenced
Private Operator Decision Axes
- 20-year-out risk: decide whether to factor "re-solicitation risk" into business plans, or wait until guidelines are made explicit
- Combination with TSUNAG: gain national authorization through a new greenery-conservation plan + secure funding through Park-PFI revenue facilities
- A movement toward "split solicitation" and "local-participation promotion" to break the large-company-advantaged structure
Conclusion
Park-PFI has spread to 165+ parks since its 2017 creation — a "success in numbers." At the same time, the Hibiya Park "zero bidder" case, small-operator entry barriers, revenue-bias critiques, and insufficient community-group consideration have surfaced "quality challenges."
The 2024–2025 policy expansion (TSUNAG, Guideline revisions) is moving forward not as Park-PFI alone but within the broader park-greenery management context. While no direct Urban Park Act revision in the 2026 Diet session is currently confirmed, guideline-level revisions following the Regulatory Reform Council proposal will likely materialize within the next few years.
The next major issue is the "20-year maturity problem," and re-solicitation rules, facility succession, and revenue-facility treatment need to be organized now in preparation for the first-generation maturity arriving around 2037. From Park-PFI adoption forward, contract and solicitation design that anticipates the "20-year exit strategy" will be required of both municipalities and operators.
For basics, see Park-PFI Implementation Guide. For failure-pattern lessons, Park-PFI Failure Patterns. For the Designated Manager comparison, Park-PFI vs Designated Manager System.
References
- MLIT "Park-PFI Utilization" (latest implementation page): https://www.mlit.go.jp/toshi/park/toshi_parkgreen_fr_000059.html
- MLIT "Park-PFI Activation Guidelines for Improving Urban Park Quality" (May 30, 2025 revision): https://www.mlit.go.jp/toshi/park/content/001891734.pdf
- MLIT "Review Committee on Flexible Urban Park Management and Operation": https://www.mlit.go.jp/toshi/park/toshi_parkgreen_tk_000064.html
- MLIT "Act on Partial Revision of the Urban Greenery Act and Others Came into Effect" (November 8, 2024): https://www.mlit.go.jp/toshi/park/toshi_parkgreen_tk_000073.html
- MLIT "Urban Development GX (Greenery Conservation and Promotion of Greening)" TSUNAG detail: https://www.mlit.go.jp/toshi/kankyo/toshi_daisei_tk_000089.html
- Cabinet Office Local Decentralization Reform Office "Extension of Validity Period in Park-PFI Public Solicitation Guidelines" (February 12, 2025): https://www.chisou.go.jp/tiiki/kokusentoc_wg/r6/pdf/20250212_shiryou_1_2.pdf
- Urban Park Act (e-Gov): https://laws.e-gov.go.jp/law/331AC0000000079
- Journal of the City Planning Institute "Application Trends and Issues of Park-PFI in 45 Nationwide Parks" (2024): https://www.jstage.jst.go.jp/article/journalcpij/59/3/59_4037/_article/-char/ja/
- Organization for Promoting Urban Development "Research on How to Advance Park-PFI and Other Public-Private Cooperation Projects in Urban Parks" (Yukio Uzui): https://www.minto.or.jp/assets/pdf/urban/u70_06.pdf
- Institute of Local Government Issues "Parks Are in Danger Now — Examining Corporate Park-Making" (Ryotaro Iwami): https://www.jichiken.jp/article/0377/
- Nihon Mecs "Survey Report on Issues with the Designated Manager System" (July 2024): https://www.meccs.co.jp/news/news2024/240711/240711_01.html