The Rent Keeps Running While the Permit Waits

Letter from the table — RC/RT/2026/T.23

To the Red Tape Council,

I support measuring how long permits take. I support publishing service times. I support making people submit the same basic information once instead of carrying it from counter to counter. But I oppose “silence is consent” as part of the proposed Small Business Impact Standard. A permit that has not been decided is not always safe to treat as granted. My experience in Osaka shows why the delay needs fixing, but not by pretending that an unanswered application is an approval.

In February, I was preparing to open a small business in Osaka City. I had signed a lease for a premises and planned a sign outside it. The landlord’s agreement allowed the sign, but that did not replace the permission required under Osaka City’s outdoor-advertising rules for the sign I intended to install. I understood that I had to wait for the city’s decision before putting it up.

I submitted my application on 6 February 2026. I included the drawings and the information I understood to be required. On 2 March, the city asked for an additional detail about the proposed installation. I supplied it that day. The application was still pending in April; permission arrived on 7 April. I am not claiming that the city broke a legal deadline. The problem was that I could not find a published service time that let me plan around the wait, and the acknowledgement I received did not give me a decision date.

While I waited, the lease did not wait with me. Rent was ¥120,000 a month, due from 1 March. I had also paid ¥200,000 as a lease deposit and ¥60,000 to the sign fabricator, which could not be returned. I did not install the sign before permission came through. I could not sensibly tell a supplier, a

landlord, or myself that the application was “probably approved.” So I kept the cash aside, paid the rent, and delayed the opening work that depended on the sign.

This is where red tape becomes a cashflow problem. A permit delay is not only time spent checking an inbox. It can mean paying rent before a site is ready, holding money that could have paid a worker or supplier, and postponing income without knowing whether the delay will be days or weeks. Those are the same pressures the Cashflow Council is examining from another direction: when money is tied up or arrives later than expected, a small business has less room to absorb ordinary costs.

I want the Days to Open survey to record more than the number of days between an application and a decision. Please ask when the premises began costing money, whether the applicant could operate while waiting, whether an authority requested further information, and whether the applicant could see the next step and an expected date. A count without those details can make a long wait look harmless when it is not.

A one-stop digital process would help if it meant one place to track an application, see what is missing, and understand which office has the next action. It should not imply that every legally separate review can be collapsed into one approval. Published service times should also say what starts the clock, when it pauses, and how an applicant can ask for a stalled file to be reviewed. That would let an owner plan and would give the public a fair way to see whether the process is improving.

But silence cannot safely mean consent in every case. Outdoor-advertising rules can protect public space and safety as well as regulate a business’s plans. If a deadline passes without a decision, automatic approval could leave an applicant exposed to later enforcement, or leave neighbours and the city dealing with a sign that should have been changed. A small operator should not have to choose between waiting indefinitely and relying on a legal fiction.

My proposed alternative is a firm, published decision target; a written notice when the target cannot be met; a named route to escalate an overdue application; and a clear interim status that says what the applicant may and may not do. If a permit is refused, the reasons and the route to correct or appeal should be plain. That will not refund rent already paid, but it would reduce uncertainty and make the authority answerable for the time it takes.