Game Payments and Gacha: Reviewing Japan's Payment Services Act and Premiums Rules Together
Hello! I am Noriaki Asato, Representative Attorney at Legal Agent.
Game businesses use many monetisation methods, including in-game currency, gacha, item sales, season passes, subscriptions, event rewards, ranking rewards and integrations with non-fungible tokens.
These features can directly affect revenue. They can also raise issues under Japan's Payment Services Act, Act against Unjustifiable Premiums and Misleading Representations, Specified Commercial Transactions Act and Consumer Contract Act, as well as rules concerning minors and platform terms.
A legal review should therefore examine both the flow of money and the design and presentation of rewards, rather than asking only whether a feature is engaging for players.
Check whether in-game currency is a prepaid payment instrument
When users purchase coins or points in advance and later spend them on in-game items or gacha, the currency may qualify as a prepaid payment instrument under Japan's Payment Services Act.
Even if the currency can be used only in the issuer's own game, filing and security-deposit obligations may arise when the unused balance exceeds JPY 10 million on a statutory reference date, which falls on 31 March and 30 September each year.
The legal and operational design should also address expiration, refunds, treatment of balances when a service closes, purchases by minors, chargebacks and the treatment of balances when an account is suspended. The terms of use, statutory commerce disclosures, purchase screens and help pages should tell a consistent story.
Review gacha probabilities and representations
A gacha review should cover drop rates, rarity tiers, disclosed probabilities, pity or ceiling mechanics, featured items, limited availability, re-runs and collection-completion mechanics.
If the displayed probabilities or other claims do not match the actual system, the discrepancy may create risk under the Act against Unjustifiable Premiums and Misleading Representations.
Particular care is also required for mechanics resembling so-called complete gacha, in which collecting a specified combination of different items yields an additional economic benefit. Such designs may fall within Japan's restrictions on card-combination prize schemes.
Before launch, teams should document the gacha rules, probability displays, nature and value of rewards, player-facing explanations and logs needed to verify the implementation.
Event and ranking rewards require a separate analysis
Games often provide rewards to top participants in events or rankings. The legal analysis can change depending on whether a reward is confined to an in-game item or can take the form of cash, e-money, a gift card, an NFT, a crypto-asset or another transferable digital asset.
Relevant factors include any entry fee, the role of chance and skill, the source of the reward and whether it can be converted into money or traded. Cash equivalents and secondary-market digital assets require particular care from the perspectives of gambling regulation, payment regulation, premiums rules and tax.
Build controls for purchases by minors
High-value purchases by minors are a recurring risk in game operations. Companies should consider age checks, purchase limits, parental consent, confirmation screens, refund handling and an accessible support channel.
Platform controls alone may not be enough. A company's own terms, help content and customer-support procedures should align with the product design. Disputes involving minors can create both legal exposure and lasting harm to player trust.
Conclusion
Game payment and gacha features should be reviewed under both the Payment Services Act and the premiums and representations regime. In-game currency, gacha, event and ranking rewards, purchases by minors and the treatment of unused balances at service closure should be considered from the planning stage.
LegalAgent supports game, app and digital-content businesses with payment regulation, premiums and representations issues, terms of use and statutory commerce disclosures. We believe the goal is to preserve an engaging game design while making the monetisation structure legally explainable and operationally consistent.