Korea, Japan, and China Each Want a Different Gacha Disclosure
ComplianceDisclosure

Korea, Japan, and China Each Want a Different Gacha Disclosure

RK
Ramesh Krishnan·May 11, 2026·12 min read
Summary

Korea passed a real law and enforces it hard. Japan has a two-layer system: a statutory law plus a private industry club. China has the oldest rule and the most opaque history. A single English disclosure block, translated three ways, fails in all three jurisdictions because each one requires different mandatory fields, different headings, and different retention. This post is the plain-language map of what each regulator actually wants.

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If you sell loot boxes in Asia, three governments have three different rules about how to show your odds. Korea passed a real law and enforces it hard. Japan does not have one law. It has a private club of game companies that makes its own rules, plus a separate law about lying in ads. China has the oldest rule and the most confusing history.

One translation does not work in all three. A disclosure that passes in Korea will fail in Japan. A disclosure that passes in Japan will fail in China. Foreign studios learn this the hard way, and so do their lawyers.

One translation does not work in all three.

This post explains, in plain language, what each country actually wants, what the penalties look like, and why translation alone is not enough.

What gacha is

Gacha is the slot-machine style of selling in-game items. You pay for a chance. You might get a five-star sword. You might get a duplicate sticker. The mechanic comes from Japanese capsule toy machines, and most top-grossing mobile RPGs in Asia run on some version of it.

The numbers are big. Asia accounts for most of the global loot-box market. Japan alone makes nearly 40 cents of every dollar spent on gacha worldwide. Korea and China are not far behind. Because so much money flows through these draws, regulators have moved in.

Each country wrote its rule in its own legal language, with its own required headings, its own required numbers, and its own punishments. There is no shared template. Here is what each one asks for.

Korea: a real law, enforced hard

Korea passed a real law about gacha odds. If you sell paid loot boxes to Korean players, you have to show the odds. You have to put them in three places: inside the game, on your website, and in your ads. The law took effect on March 22, 2024.

Three agencies watch. The culture ministry (called MCST) writes the rules. The rating committee (called GRAC) monitors games and flags violations. The fair trade commission (called KFTC) catches studios that lie about odds in advertising. They are not gentle.

In January 2024, the fair trade commission fined Nexon Korea about KRW 11.6 billion. That is around USD 8.9 million. Nexon had misrepresented drop rates of Cube items in MapleStory and Golden Number Cards in Bubble Fighter. It was the largest penalty in the history of Korea's e-commerce consumer-protection law.

Two newer pieces matter for any studio operating from outside Korea.

The first is a 2025 amendment that lets a Korean court make you pay up to three times the player's actual damages if you misrepresent odds. It also flips who has to prove what. Normally a player has to prove you were sneaky. Under the amendment, you have to prove you were not. The amendment took effect January 31, 2025. The special punitive-damages provisions for probability-item disputes came into force August 1, 2025.

The second is a foreign-publisher rule that starts October 23, 2025. If you do not have a Korean office, you might need to hire someone in Korea to handle the paperwork for you. The proposed cutoff is roughly KRW 1 trillion in global sales last year, OR an average of 100,000 Korean monthly users in the last three months of last year, OR a company the culture ministry has flagged as risky. This is not all overseas operators. It is only the big ones. A small indie studio launching in Korea does not have to hire a domestic representative.

What you actually show on the disclosure block: every paid random item, broken into four categories the culture ministry defines (capsule, enhancement, synthesis, and others including ceiling type). Probabilities go as percentages. The rules do not specify how many decimal places. Most studios use two to four decimals.

The Korean words you will see on these blocks: 확률형 아이템 (probability-type items, the umbrella term), 확률 정보 공개 (probability information disclosure, the section heading), 천장 (cheonjang, the ceiling that guarantees a pull after enough tries). You will sometimes see 소프트 피티 written informally, but the culture ministry does not use it. Skip it.

Japan: two layers, both matter

Japan does not have one gacha law. It has two layers and you have to respect both.

Layer one: the real law

It is called the Act against Unjustifiable Premiums and Misleading Representations. The consumer affairs agency enforces it. Two parts of this law matter for gacha.

The first part is the kompu gacha ban. Kompu gacha is a mechanic where you have to collect a specific set of items, drawn from gacha, to win a rarer prize. Think of it like baseball cards: you keep buying packs hoping to complete the set, and only after completing it do you get the special card. Japan banned this in May 2012. The story is famous in the industry. The market reacted on May 7, 2012: GREE lost almost a quarter of its share value in a single day. DeNA lost over 20%. Combined social-gaming losses came to about USD 3.8 billion. The agency formally announced the ban on May 18, with companies given until July 1 to comply.

Regular gacha pulls were not banned. Only the "complete the set for a bigger prize" mechanic is illegal. Standard banner gacha with one rarity table is fine.

The second part is a prize-value cap. When a prize is offered alongside a transaction, the prize cannot be worth more than the lower of 20 times the transaction value or JPY 100,000. This rarely bites for gacha itself but matters for tie-in campaigns and physical bonuses.

A third recent piece: from October 1, 2023, the same law also bans stealth marketing. If a creator promotes a game and gets paid for it, that has to be clearly disclosed. "Lucky pull" videos that misrepresent drop rates can be flagged on this basis.

Layer two: self-regulation

Two industry clubs publish rules their members follow: the Japan Online Game Association, called JOGA, and the Computer Entertainment Supplier's Association, called CESA.

JOGA's gacha guideline gives studios three main compliance paths. They can keep the expected spend to get any rare item below a soft ceiling (whichever is lower: 100 times the single-pull price, or JPY 50,000). They can publish the upper and lower bounds of rare-item rates. Or they can publish the rate of every single item. JOGA has clarified publicly that this is not a JPY 50,000 player spending cap. It is one of the disclosure options.

The standard Japanese heading on a compliant disclosure block is ガチャ提供割合 (gacha teikyou wariai, "gacha provision ratio"). The term for the ceiling that guarantees a pull is 天井 (tenjou, ceiling). Some titles also use スパーク (spark) for hard pity. The transliteration ピティ (piti) is not standard. Skip it.

One useful note: JOGA does not currently require you to disclose your ceiling mechanic itself. Disclosing the ceiling is industry practice in titles like Genshin Impact and Honkai: Star Rail, often driven by quiet pressure from the consumer affairs agency, not by a written JOGA rule.

If you misrepresent odds, the consumer agency can issue a corrective order plus a surcharge of 3% of the sales tied to the misrepresentation. A representative who ignores a corrective order can face up to two years in prison or up to JPY 3 million in fines. Reputational risk in Japan is also real. The 2012 kompu gacha announcement wiped almost USD 4 billion from social-gaming market caps in a single trading day. The Japanese press picks up gacha scandals fast.

China: the oldest rule, the most confusing history

This is the section most often gotten wrong. Three things to know up front.

The regulator is the culture ministry, not MIIT. The original disclosure rule was issued by China's culture ministry on December 5, 2016, effective May 1, 2017. The Ministry of Industry and Information Technology had nothing to do with it. Many industry blogs and consulting decks get this wrong.

The rule changed hands. The culture ministry was merged into the Ministry of Culture and Tourism in 2018. Game oversight then moved to the National Press and Publication Administration (NPPA), which sits under the central government's main communications body. The 2016 rule was formally abolished in August 2019, but its main requirements (show the odds, give a free way to get the item, post the results) carried forward into NPPA enforcement and got restated in the NPPA's December 2023 draft regulation.

The rule asks for three specific things.

First, show the odds. Every paid random draw must list every possible outcome, with name, properties, contents, quantity, and probability. The list goes on the official website or on the draw page. Information must be true.

Second, post the results. The studio must publish aggregated draw results in a prominent place on the website or in-game and retain the records for at least 90 days for government inquiry. This is NOT a per-player history of pulls. It is overall draw outcomes from all players, kept available for regulators to check.

Third, offer a free path. If you sell randomized items, you must also offer another way to get items with the same properties, like direct purchase with non-premium in-game currency, or by trading other items. Paid random pulls cannot be the only way to get the item. This is the rule most often missed by foreign studios.

The 30/3/50 myth

A specific set of numbers appears in many industry blogs: no more than 30 single pulls per day, no more than 3 ten-pull bundles per day, no more than 50 pulls total per day. We could not find a primary source for these numbers in any published Chinese rule. The text first shows up in a 2019 marketing post by Henry Fong of Yodo1. Major industry guides like AppInChina repeat it without citation. Leon Y. Xiao's body of academic work on PRC loot box compliance, which is the most thorough in the field, does not mention these caps.

Treat the 30/3/50 number as folklore until you see a primary source.

What is real: in early 2022, several Chinese studios self-imposed 50-per-day pull caps after informal pressure from regulators. The pressure exists. The specific 30/3/50 structure does not.

The December 2023 panic

On December 22, 2023, the NPPA published a draft regulation that proposed strict new limits on daily login rewards, first-purchase bonuses, and probability-based draws for minors. Markets reacted fast. Tencent shares fell 12% in Hong Kong. NetEase fell almost 25%. The Chinese gaming industry lost roughly USD 80 billion in market value in two days. The official who oversaw the draft was reportedly removed from his post. The NPPA pulled the draft from its website and said it would revise based on industry feedback.

As of May 2026, no final version has been adopted in the form first proposed. Some earlier rules from 2019 and 2021 are still in force (real-name authentication, minor spending caps). Track the file. Do not assume the 2023 draft is law.

The Chinese words you will see on compliant disclosure blocks: 抽取概率 (chouqu gailü, draw probability), 合成概率 (hecheng gailü, synthesis probability for crafting outcomes), 保底 (baodi, the floor-guarantee term for pity).

Why translation alone fails

Here is the failure mode that costs studios money.

A team writes one English disclosure block. They send it to a translator. They paste the translated output into three regional builds. They feel done. They are not.

The Korean output, translated literally, will miss the culture ministry's four item categories and the in-game-plus-website-plus-ads triple posting requirement. The rating committee will flag it. By mid-2024, the rating committee had flagged hundreds of titles for disclosure violations, with foreign-developed studios making up a majority of them.

The Japanese output will use English-derived words like ピティ instead of 天井. It will lack the ガチャ提供割合 heading. It will not match any of the three JOGA disclosure paths. A non-member studio still exposes itself to the consumer affairs agency if odds are wrong.

The Chinese output will not use 抽取概率 as a heading. It will not post aggregated draw results in a place retained for 90 days. It may not surface the free-path requirement at all.

You cannot translate your way to compliance. You have to generate per-region documents from the same underlying rate sheet.

Each country's compliant disclosure block has different mandatory fields, different required headings, different placement, and different retention rules.

The Gacha Disclosure Pack

To make this concrete, we built a free tool: tools.qyren.ai/gacha-disclosure-pack.

You upload a single CSV or JSON rate sheet with your items, banner periods, and pity mechanics. The tool generates three region-specific disclosure blocks in HTML, PNG, and JSON form. The headings come out in Korean, Japanese, and Simplified Chinese. The field structure matches what each country's regulator expects.

It runs entirely in your browser. The rate sheet never leaves your machine. We do not store it. We do not log it. If you have a publisher in any of these markets, you can hand them the output and start a real conversation.

Action
Generate three regional blocks from one rate sheet. Bring your CSV or JSON of items, banner periods, and pity. Get Korea, Japan, and China outputs side by side in HTML, PNG, and JSON. Your lawyer reviews the final block. Your localization team tunes tone. The worst failure mode (one English paragraph translated three ways into three non-compliant documents) goes away.

What is next

This post covered Asia. A followup will cover the English-language markets (UK, US state laws, Australia), Turkey's gambling-adjacent treatment of loot boxes, and the Apple App Store and Google Play platform rules that often bind tighter than any single country's law. Watch the blog for that one.

For more on monetization decisions, see our posts on the Revenue Signal, the first 14 days of monetization, and why the same offer kills revenue across regions.

Sources: MCST (Korea) probability-disclosure guidance (Feb-Mar 2024). Kim & Chang, Shin & Kim, and Yoon & Yang regulatory briefings. Bloomberg and Monolith Law Office on the May 2012 kompu gacha ban (USD 3.8B social-gaming losses). JOGA Guidelines for Display and Operation in Random Item Provision Methods (April 1, 2016). DLA Piper, GVA Law on Japan's Premiums and Representations Act and the October 2023 stealth-marketing ban. PRC Ministry of Culture 文市发〔2016〕32号 Notice. Leon Y. Xiao, peer-reviewed work on PRC loot-box compliance (ICTL 2022, BPP 2024). Niko Partners, Fortune, Fox Mandal on the December 2023 NPPA draft and the USD 80B two-day loss.

RK

Ramesh

Founder, Qyren

Data Sources
  • MCST (Korea), 확률형 아이템 확률 정보공개 관련 해설서 (2024)
  • Kim & Chang / Shin & Kim / Yoon & Yang regulatory briefings
  • KFTC, Nexon Korea decision (January 2024)
  • Japan Consumer Affairs Agency, Premiums and Representations Act
  • JOGA, Guidelines for Display and Operation in Random Item Provision Methods
  • PRC Ministry of Culture, 文市发〔2016〕32号 Notice; NPPA December 2023 draft
  • Leon Y. Xiao, peer-reviewed work on PRC loot box compliance
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