What Is a Change of Use
The categories of specified buildings in Appended Table 1 of the Building Standards Act, and where a school-to-welfare conversion sits
Floor area that triggers confirmation for a change of use: when the part put to the new use totals more than this
200 m²
100 m² before the 2018 amendment
Period within which the building official reviews an accepted application (Building Standards Act, Article 6(4))
35 days
Notify the building official when the work is finished
Occupants at which category (6)(b) facilities such as homes for the elderly must appoint a fire safety manager (Fire Service Act Enforcement Order, Article 1-2(3))
10 or more
30 or more for category (6)(c)
Under the Building Standards Act, a "change of use" refers to altering the intended purpose of a building. Converting an abandoned school into a welfare facility constitutes a change of use under the Act.
Categories of Specified Buildings
Appended Table 1 of the Building Standards Act divides the uses of specified buildings into items (1) to (6). Item (2) covers hospitals, clinics with inpatient facilities, hotels, inns, boarding houses, apartment buildings, dormitories and similar uses set by Cabinet Order; item (3) covers schools, gymnasiums and similar uses set by Cabinet Order; and item (5) covers warehouses and similar uses set by Cabinet Order. The uses similar to item (2) are child welfare facilities and similar, a term that covers child welfare facilities, welfare facilities for the elderly, fee-charging nursing homes, support facilities for persons with disabilities, community activity support centers, welfare homes, and facilities for disability welfare services limited to daily life support, training for independent living, transition support for employment and continuous employment support, among others.Converting a school (item (3)) into a welfare facility (item (2)) is therefore a change to a different item of Appended Table 1.
Common Use Change Patterns for Abandoned School Conversions
| Before (School) | After | Appended Table 1 Category |
|---|---|---|
| Elementary / junior high school | Elderly welfare facility (day service, nursing home, etc.) | Item (3) to item (2) (child welfare facilities and similar) |
| Elementary / junior high school | Disability support facility / supported employment facility | Item (3) to item (2) (child welfare facilities and similar) |
| Elementary / junior high school | Childcare center / certified children's center | Item (3) to item (2) (child welfare facilities and similar) |
| Elementary / junior high school | Warehouse | Item (3) to item (5) |
| Elementary / junior high school | Office | To a use that is not a specified building |
Building Permit Requirement (200 m² Threshold)
The 200 m² counted on the part put to the new use, similar uses, the 2018 amendment, the review period and the completion notice
The Floor Area That Triggers Confirmation, and Similar Uses
When a building's use is changed so that it becomes a specified building used for a purpose in column (i) of Appended Table 1 and the floor area used for that purpose totals more than 200 m², the confirmation procedure applies. Changes between similar uses designated by Cabinet Order are excluded.Whether the 200 m² is exceeded is judged on the total floor area put to the new use, not on the whole school building. When only part of a school building becomes a welfare facility, count the area of that part.
The similar uses exempt from confirmation come in groups such as theaters, cinemas and entertainment halls; public halls and assembly halls; clinics with inpatient facilities and child welfare facilities and similar; hotels and inns; boarding houses and dormitories; museums, art galleries and libraries; and gymnasiums, bowling alleys, skating rinks, swimming pools, ski grounds, golf practice ranges and batting cages. Schools do not appear in any group. Converting a school into a child welfare facility or similar therefore requires confirmation if the part put to that use exceeds 200 m².
The 2018 Building Standards Act Amendment
To make use of the existing building stock, the 2018 amendment to the Building Standards Act revised the scale at which a change of use requires building confirmation, raising the upper limit for no confirmation from 100 m² to 200 m². The overview says it streamlines procedures and removes the need for large-scale renovation when converting vacant houses and similar into welfare or commercial facilities, promoting use of the existing building stock.Procedure Depending on Whether Floor Area Exceeds 200 m²
Where the part put to the new use exceeds 200 m² (confirmation required)
- Before starting work, submit an application for confirmation and obtain the certificate of confirmation (Article 6(1) and (8), applied through Article 87(1))
- The building official reviews whether the plan complies with the building standards-related provisions within 35 days of accepting the application.
- For a change of use, the words in Article 7(1) requiring the owner to "apply for inspection by the building official" on completion are read as "notify the building official". Completion is a notice, not an application for inspection
Where the part put to the new use is 200 m² or less (no confirmation required)
- No confirmation is required, but the converted building must meet the Building Standards Act provisions for its new use
- Notification and inspection of fire safety equipment depend on the Fire Service Act categories, separately from this floor area (see the welfare facility section)
- The Barrier-Free Act's duty to meet the standards applies when the floor area being converted totals 2,000 m² or more (same section)
Pre-Existing Non-Conforming Buildings
For a building that met the standards when it was built but no longer complies with current provisions after later amendments (a pre-existing non-conforming building), the question on a change of use is which provisions must be brought into line with the new use (see Relaxation Provisions). Whether or not confirmation is required, consult an architect and the inspection body before design.
Main Renovation Obligations
The statutory conditions for fire compartments, smoke exhaust, corridor width, direct stairs and interior finishes
When converting an abandoned school to a welfare facility, check the provisions in the following areas.
1. Fire Compartmentation
Fire compartmentation divides the inside of a building with quasi-fire-resistant floors and walls and fire protection equipment to stop fire from spreading.
Area Compartmentation
Quasi-fire-resistant buildings, buildings whose specified main structural parts are fire-resistant, and similar buildings with a total floor area of more than 1,500 m² must be compartmented every 1,500 m² of floor area with floors or walls of quasi-fire-resistant construction meeting the one-hour standard, or with specified fire protection equipment. Half the floor area of parts fitted with automatic sprinklers or similar fire extinguishing equipment is excluded from the count.Vertical Shaft Compartmentation
In buildings whose main structural parts are quasi-fire-resistant and similar buildings that have habitable rooms in a basement or on the 3rd floor or above, shaft parts such as atriums, stairs, elevator shafts and duct spaces must be separated from other parts by quasi-fire-resistant floors or walls or fire protection equipment.Use Compartmentation (for Specified Buildings)
Where part of a building falls under any item of Article 27, Paragraph 1 of the Act, that part must be separated from the rest by floors or walls of quasi-fire-resistant construction meeting the one-hour standard, or by specified fire protection equipment. Item (2) uses fall under Article 27(1) when the 3rd floor or above is used for them, or when the part used for them on the 2nd floor totals 300 m² or more. Check the area even when placing a welfare facility for the elderly or a support facility for persons with disabilities on the 2nd floor.
2. Smoke Exhaust Equipment
Specified buildings used for the purposes in items 1 to 4 of column (i) of Annex 1 of the Act, with a total floor area exceeding 500 square metres, must be fitted with smoke exhaust equipment.
A building that stays a school is exempt. The exemptions in that article include schools (other than integrated centers for early childhood education and care), gymnasiums, bowling alleys, ski grounds, skating rinks, swimming pools and sports practice facilities. Convert a closed school to another use and the exemption no longer applies. Whether smoke exhaust equipment is needed depends on the use after conversion.
In item (2) specified buildings, parts compartmented by quasi-fire-resistant floors or walls or fire protection equipment with a floor area of 100 m² or less are excluded from the smoke exhaust rules. Parts that the Minister of Land, Infrastructure, Transport and Tourism designates, taking into account ceiling height and the finish materials of walls and ceilings, as places where smoke and gas do not descend to a height that hinders evacuation in a fire, are also excluded. Check with an architect, using the floor plans, which exclusions apply.
3. Egress Facilities (Corridor Width and Direct Stairs)
The corridor width and related provisions apply to specified buildings in items (1) to (4) of column (i) of Appended Table 1, buildings of three or more storeys, and buildings with more than 1,000 m² of total floor area, among others. On floors where habitable rooms total more than 200 m² (100 m² in a basement), corridors must be at least 1.6 m wide with rooms on both sides and 1.2 m otherwise. Corridors for pupils in elementary and junior high schools must be at least 2.3 m with rooms on both sides and 1.8 m otherwise. On floors other than the evacuation floor where rooms used for the main purpose of child welfare facilities and similar total more than 50 m², two or more direct stairs leading to the evacuation floor or the ground are required. In buildings whose main structural parts are quasi-fire-resistant or made of non-combustible materials, the 50 m² becomes 100 m².The facility standards for each type of welfare service (the standards for designating operators) may also set corridor widths and similar requirements. Check them with the municipal department that designates operators, together with the Building Standards Act.
4. Interior Finishes
Item (2) uses are subject to interior finish restrictions when the part on the 3rd floor or above totals 300 m² or more in fire-resistant or quasi-fire-resistant buildings meeting the one-hour standard, when the part on the 2nd floor totals 300 m² or more in quasi-fire-resistant buildings not meeting it, and when the part used for that purpose totals 200 m² or more in other buildings. Walls (excluding the part up to 1.2 m above the floor) and ceilings of habitable rooms must be finished in fire-retardant materials (quasi-non-combustible materials for the ceilings of habitable rooms in buildings with habitable rooms on the 3rd floor or above), and the walls and ceilings of the main corridors and stairs leading from those rooms to the ground in quasi-non-combustible materials.Relaxation Provisions
How rules apply when changing the use of a pre-existing non-conforming building, certification of an overall plan for phased work, and floor evacuation safety verification
Changing the Use of a Pre-Existing Non-Conforming Building
When the use of a pre-existing non-conforming building is changed, Article 27, Article 28, Article 35 and other provisions apply. Changes between similar uses with no repairs or remodelling, or only minor ones, are among the exceptions. Article 86-7(2) and (3) also apply to a change of use: Article 27 and related provisions do not apply outside the independent part whose use changes, in buildings with two or more parts that can be treated as separate buildings, and Article 28 (natural lighting and similar) and the corridor standards of Article 35, among others, do not apply outside the part whose use changes.Phased Work (Certification of an Overall Plan)
Where the work accompanying a change of use of a single pre-existing non-conforming building is split into two or more jobs and the designated administrative agency certifies the overall plan, Article 27 and related provisions do not apply until the last job begins. The plan must meet three criteria: splitting the work is unavoidable given how the building is used or other circumstances; the building and site will comply with the law once all the work is complete; and no stage of the work increases hazards to safety, fire protection, evacuation and the like.Verifying Evacuation Safety by Calculation
Floors of buildings whose main structural parts are quasi-fire-resistant or made of non-combustible materials that are shown to have floor evacuation safety performance by the floor evacuation safety verification method (or that receive ministerial certification) are exempt from provisions including corridor width (Article 119), smoke exhaust (Article 126-2) and interior finishes (part of Article 128-5). Where renovating to the prescriptive specifications would be costly, check with an architect whether this method can be used.
Welfare Facility–Specific Considerations
Sprinklers, the Barrier-Free Act, notification and inspection of fire safety equipment, and fire safety managers
Sprinkler Installation Requirements
The Fire Service Act Enforcement Order sets whether sprinklers are required by the use categories in Appended Table 1, together with floor area and storey (Article 12).
| Example Facilities | Appended Table 1 Category | Main Cases Requiring Sprinklers (Article 12) |
|---|---|---|
| Homes for the elderly, special nursing homes for the elderly, fee-charging nursing homes and small-scale multifunctional home care facilities where older people who would have difficulty evacuating mainly live or stay overnight, and dementia group homes | (6)(b)(1) | Regardless of floor area (except structures that limit fire spread as set by MIC ordinance) |
| Support facilities for persons with disabilities, and short-term stay or group home facilities that mainly house persons with disabilities who would have difficulty evacuating | (6)(b)(5) | 275 m² or more of total floor area; regardless of area where the facility mainly houses people who cannot evacuate without assistance (except structures that limit fire spread) |
| Day services, and small-scale multifunctional home care facilities not in the row above | (6)(c)(1) | Buildings other than single-storey with 6,000 m² or more in total, or floors of 1,000 m² or more in a basement or windowless storey, or of 1,500 m² or more on the 4th to 10th floors, among others |
| Nurseries, integrated centers for early childhood education and care | (6)(c)(3) | Same as above |
| Child development support, after-school day services | (6)(c)(4) | Same as above |
| Daily life support, transition support for employment, continuous employment support | (6)(c)(5) | Same as above |
For category (6)(c) facilities, the floor used and whether that floor counts as a windowless storey matter as well as area. Check the floors and floor areas you will use on the school's drawings.
Barrier-Free Access Compliance
When building a specified building of the scale set by Cabinet Order or larger (including changing a building's use into a specified building), the owner must make it meet the building accessibility standards. Local governments can add buildings by ordinance or set a smaller scale than the Cabinet Order. Where the duty does not apply, there is an obligation to make efforts to meet the standards. The scale specified by Cabinet Order under Article 14, Paragraph 1 of the Act is a total floor area of 2,000 square metres, or 50 square metres for public toilets. Where the use of a building is changed, the area counted is that of the part subject to the change. The buildings covered include nursing homes and welfare homes and similar facilities used mainly by elderly people and people with disabilities, welfare centers for the elderly, children's welfare facilities, welfare centers for people with physical disabilities, and gymnasiums open to the general public. Where only part of a closed school is converted, the 2,000 square metres is counted on that part.
Under the toilet provisions of the building accessibility standards, on each floor with toilets used by many unspecified people or mainly by older people or persons with disabilities, at least one of those toilets must have at least one wheelchair-accessible stall (with exceptions such as a ground-level floor with a nearby facility that has one). The standards also cover entrance steps, corridors and ramps, lifts and more, so check them together with local ordinances before design.
Fire Service Act Procedures
In addition to building confirmation under the Building Standards Act, the Fire Service Act has its own procedures.
When fire safety equipment is installed, the owner must notify the fire chief or fire station chief and have it inspected. This applies regardless of floor area to category (6)(b) and to category (6)(c) facilities where users live in or stay overnight, and at 300 m² or more of total floor area to other category (6)(c) facilities, among others. Simple extinguishing tools and emergency alarm devices are excluded. A fire safety manager must be appointed at 10 or more occupants for category (6)(b), 30 or more for categories (6)(a), (c) and (d) and similar, and 50 or more for schools and similar in category (7).Consult the local fire station before design to confirm which fire safety equipment is required.
Procedures When the Work Is Finished
When work under a confirmed change of use is finished, notify the building official (Article 7(1), applied with a substitution through Article 87(1)). For fire safety equipment, give notice of installation and have it inspected. Check with the municipal department that designates welfare service operators which documents the designation application requires, and plan backward from the opening date.
Renovation Cost Estimates
The amounts in this table are assumptions this article makes, not published statistics. They move a great deal with the building, the area and the line of business, so replace them with your own quotes and comparable local results.
The following table summarizes the main renovation items and estimated costs when converting an abandoned school to a welfare facility:
| Renovation Item | Estimated Cost | Notes |
|---|---|---|
| Sprinkler installation | ¥1.5–3.0 million (200 m² building) | ¥8,000–15,000 per m² |
| Fire compartmentation (fire doors, fire walls) | ¥0.5–2.0 million | Varies by scope |
| Barrier-free access (ramps, accessible restrooms) | ¥1.0–3.0 million | Varies by spec and number of floors |
| Smoke exhaust equipment | ¥0.5–2.0 million | Mechanical exhaust |
| Interior renovation (quasi-non-combustible finishes) | ¥1.0–5.0 million | Varies by area |
| Total estimate | ¥5–15 million | Varies by facility size and condition |
Renovation costs in MEXT's case collection range from about ¥4 million to about ¥1 billion in total, even among welfare, childcare and medical uses. The facility size and renovation cost for each case are tabulated in "Closed School Renovation Costs: Breakdown by Cost Item and Case Examples."
Practical Takeaways
Pre-Application Consultation
Before submitting an application for confirmation, consult the building official or designated inspection body. For plans such as abandoned school conversions, where the rules on pre-existing non-conformance and use compartmentation come into play, prior consultation brings problems to the surface early.
Early Engagement of an Architect
The rules on buildings that only an architect may design or supervise cover new construction, and extensions, rebuilding, and major repairs or remodelling. Work that is only a change of use is not listed, but deciding which provisions to meet and how far takes building expertise. Bring in an architect early in design.
Coordination Among Responsible Departments
A change of use for an abandoned school involves the building standards department (confirmation), the fire station (fire safety equipment), the welfare department (operator designation), and the board of education and MEXT (property disposal). The procedures run in parallel, so tell each department about the plan early.
Further Reading
Property Disposal of Closed Schools: When No Procedure Is Needed, Disposals Settled by Report, Treasury Payments and Funds, and Documents and Filing Times
When no procedure is needed, disposals settled by report and those needing approval, how the treasury payment is calculated and when a fund replaces it, and the documents and filing times
Abandoned School Welfare Conversion and Community Meetings
How to address NIMBY issues and build community consensus
For guidance on property disposal procedures for abandoned schools, see "Property Disposal of Closed Schools." For advice on managing NIMBY issues in welfare facility conversions, see "Abandoned School Welfare Facility Conversion and Community Meetings."
What to do next
In the order you can act on them, within the week you read this.
| # | What to do | Where | Rough effort |
|---|---|---|---|
| 1 | Find at least one occupant first. Decide who takes the space, then decide the use | Market sounding, local operators | 1–3 months |
| 2 | Produce the seismic assessment and asbestos survey. Commission them if they do not exist | Your facilities team | 2–3 months |
| 3 | Get a renovation cost estimate based on step 2, and price demolition alongside it | A design office | One month |
| 4 | Check the property disposal procedure. Using a subsidized school building for a non-school purpose within the restricted period needs MEXT approval (a report is enough where the requirements are met) | Board of education, MEXT | 1–2 months |
| 5 | Hold a briefing with alumni and community groups before announcing the use | Alumni association, neighbourhood association | One month |
Skip step 1 and you end up with a decided use and no one to take it.
References
Building Standards Act (Act No. 201 of 1950) — e-Gov Legal Database (e-Gov)
Building Standards Act Enforcement Order (Cabinet Order No. 338 of 1950) — e-Gov Legal Database (e-Gov)
Order for Enforcement of the Fire Service Act (Cabinet Order No. 37 of 1961) — e-Gov Legal Database (e-Gov)
Act on Promotion of Smooth Transportation, etc. of Elderly Persons and Persons with Disabilities (Act No. 91 of 2006) — e-Gov Legal Database (e-Gov)
Architects Act (Act No. 202 of 1950) — e-Gov Legal Database (e-Gov)
Bill for Partial Amendment of the Building Standards Act (overview) — Ministry of Land, Infrastructure, Transport and Tourism (2018)
Survey on the Utilization Status of Closed School Facilities (FY2024) — Ministry of Education, Culture, Sports, Science and Technology (MEXT) (March 2025)
