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Consumer IssuesLast updated: 2026-03-303 min readLawyer-Reviewed

Legal Regulation of Game Gacha in Japan: Prohibited Mechanics, Prize Display Act, and Payment Services Act

Key Takeaways

  • ✓Complete gacha (bonus for collecting a set of items) was banned in 2012 as a prohibited lottery mechanic under the Prize Display Act
  • ✓In-game currency qualifies as "prepaid payment instruments" under the Payment Services Act, requiring deposits of half the outstanding balance every 6 months
  • ✓The 2022 stealth marketing amendment to the Prize Display Act further tightened rules on misleading gacha probability representations

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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

Important

Complete gacha is banned, but single-pull random gacha remains legal. The following rules apply.

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Probability Disclosure (JOGA Self-Regulation)

The Japan Online Game Association (JOGA) guidelines require:

RequirementContent
Disclosure of per-item probabilityPublish drop rates by rarity and item
AccuracyDisplayed rates must match actual rates
Pickup probabilityState specific item probabilities clearly

Caution

Prize Display Act Article 5 (misleading superiority) also applies. 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

> The Payment Services Act itself was significantly amended effective June 1, 2026 — see our PSA 2026 amendment guide for the stablecoin and crypto-intermediary rules.

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

  1. 1

    Registration/notification

    File with the FSA as a prepaid instrument issuer (self-type).

  2. 2

    Deposit

    Deposit at least half of the outstanding balance as of March 31 and September 30 with the Legal Affairs Bureau.

  3. 3

    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.

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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

PlatformMinor Spending Guidelines
App StoreAge-based monthly limits/parental approval
Google PlayParental approval settings available
JOGA GuidelinesMonthly cap of ¥50,000–65,000 (guideline)

Parental Cancellation Right

Caution

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.

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This article provides general legal information and does not constitute legal advice. For specific legal issues, please consult with a qualified attorney.

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