What Is Gacha?
Gacha is a mechanic in social games where players spend in-game currency for random item rewards. Japanese law regulates gacha from several angles.
Complete Gacha Ban (Prize Display Act)
2012 Consumer Affairs Agency Position
In May 2012, the Consumer Affairs Agency (CAA) announced that complete gacha violates the picture-matching prohibition under the Prize Display Act (Act Against Unjustifiable Premiums and Misleading Representations).
Complete gacha: A mechanic where collecting a full set of items earns a separate special reward.
Picture-Matching Prohibition
The Prize Display Act prohibits awarding prizes for completing a combination of cards or lottery items. Complete gacha was deemed analogous: collecting multiple gacha items to receive a bonus parallels the banned mechanic.
Current Status
Complete gacha is banned, but single-pull random gacha remains legal. The following rules apply.
Probability Disclosure (JOGA Self-Regulation)
The Japan Online Game Association (JOGA) guidelines require:
| Requirement | Content |
|---|---|
| Disclosure of per-item probability | Publish drop rates by rarity and item |
| Accuracy | Displayed rates must match actual rates |
| Pickup probability | State specific item probabilities clearly |
Prize Display Act Article 5 (misleading superiority): Discrepancies between stated and actual rates constitute a misleading representation, subject to remedial orders and a surcharge of 3% of sales.
Payment Services Act and In-Game Currency
Prepaid Payment Instruments (Article 3)
In-game currencies (gems, coins, stones, etc.) qualify as prepaid payment instruments under the Payment Services Act.
Criteria: Issued in exchange for money; usable as consideration for goods/services.
Operator Obligations
| Obligation | Content |
|---|---|
| Registration/notification | File with the FSA as a prepaid instrument issuer (self-type) |
| Deposit requirement | Deposit at least half of outstanding balance as of March 31 and September 30 with the Legal Affairs Bureau |
| Information provision | Disclose balance, expiry, etc. to users |
Expiry Dates
Setting expiry dates on in-game currency is permitted but requires clear disclosure to users under the Consumer Contract Act and Prize Display Act.
Minor Protection and Charge Limits
Legal Framework
There is no explicit statutory cap on minors' game spending under Japanese law. However, contracts made by minors without parental consent are voidable (Civil Code Article 5).
Industry Self-Regulation
| Platform | Minor Spending Guidelines |
|---|---|
| App Store | Age-based monthly limits/parental approval |
| Google Play | Parental approval settings available |
| JOGA Guidelines | Monthly cap of ¥50,000–65,000 (guideline) |
Parental Cancellation Right
Parents may cancel a minor's contract under Civil Code Article 5(2) if the minor made large gacha purchases without consent. Exceptions: the minor misrepresented their age (Article 21) or the parent subsequently ratified the contract.
Stealth Marketing Regulation (Effective October 2023)
The October 2023 amendment to the Prize Display Act banned stealth marketing (undisclosed advertising).
Game industry implications: - Influencer gacha videos must clearly disclose paid promotion - "Lucky pull" videos that misrepresent actual drop rates may be regulated
Summary
Game gacha regulation rests on three pillars: the Prize Display Act's complete gacha ban and probability disclosure rules; the Payment Services Act's in-game currency deposit obligation; and minor protection measures. Operators must accurately disclose probabilities, manage minor spending appropriately, and comply with the new stealth marketing rules.