Kompu gacha, or “complete gacha” is a monetization mechanic in social games that heavily incentivizes the practice of gacha — paying a small amount of money to get an item at random, similar to purchasing toys from a vending machine. Games that use kompu gacha typically promise rare “grand-prize” items to players who can manage to amass a set of specific items, which encourages players to spend more money on randomized gacha draws in order to complete their collections. Although extremely lucrative for Japan’s social game companies — some developers see half their sales coming from gacha — the kompu gacha system had come under fire recently for encouraging gambling, particularly in children.

1. EXAMPLES OF COMPLETE
GACHA
1. Purpose
These Examples are provided to assist social game platform operators in completely
prohibiting so-called Complete Gacha (“Comp Gacha”) elements in social games and
similar applications (“Social Games”) on their platforms in Japan and, further, to alert
other businesses by showing noteworthy examples to which they should pay attention
(even if they may not strictly speaking be considered Comp Gacha) so that users can
make informed decisions, thereby creating a positive environment in which they can
more safely enjoy playing Social Games.
Please note that the examples described herein do not cover all possible cases that will
be considered as “card matching”, which is banned by the Japanese Act Against
Unjustifiable Premiums and Misleading Representations (the “Act”), nor do they
determine what will or will not be considered as banned “card matching”. Since these
examples do not provide any legal opinions or interpretations, it is recommended that
Social Games should be planned, developed, and provided to users after an
appropriate authority, attorney, or other expert is consulted for advice on a
case-by-case basis.
These Examples may be supplemented or amended as necessary (e.g., amendment of
laws and regulations, change of an appropriate authority’s opinion).
2. Definitions
In these Examples, the following terms shall mean as follows. If not defined herein, the
terms shall have the same meaning as defined in the “Complete Gacha Guidelines”.
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2. (1) “Platform Operators” mean operators of platforms on which any Social Games
(whether such games are developed or operated by the operators themselves
or by Social Game Providers) are provided to users.
(2) “Social Game Providers” mean operators that provide Social Games through
platforms.
(3) “Gacha” means a feature of a game with which a user can obtain virtual
characters and items used in the game (“ Virtual Items”) randomly, and not
through the user’s direct choice.
(4) “Gacha Items” means Virtual Items that can be obtained by users through
Gacha.
(5) “Paid Gacha” means a form of Gacha in which users can obtain Gacha Items in
exchange for real money or virtual currency, or through the purchase of
products or services for real money.
(6) “Paid Gacha Items” mean Gacha Items that can be obtained through Paid
Gacha. Where Gacha Items can be obtained through both Paid Gacha and
any other way, such Gacha Items shall be considered as Paid Gacha Items.
(7) “Random Item Charge” means a type of charge for providing Virtual Items
randomly and not through the user’s direct choice (e.g., providing Virtual Items
randomly after unlocking and opening treasure boxes with keys that users can
purchase for real money or virtual currency).
(8) “Item Rarity” means one or more designated groupings assigned to items used
in Social Games to show how rare the items are.
(9) “Paid Items” mean Virtual Items that are obtained by users through their own
direct choice in exchange for payment (i.e., items that are not obtained
randomly).
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3. 3. What Would be Considered as Comp Gacha?
The following examples would be considered as Comp Gacha.
(1) Example 1: Typical Comp Gacha
A case where users are clearly shown a pre-determined combination of two or more
different Virtual Items that can be obtained through Random Item Charge such as Paid
Gacha as a condition to getting another Virtual Item.
A
B
Paid Gacha
C Z
Another Virtual Item
D
E
Virtual Items
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4. (2) Example 2: Typical Comp Gacha with Bonus Event being Required for Completion
A case where users are clearly shown a pre-determined combination of two or more
different Virtual Items that can be obtained through a Random Item Charge, such as
Paid Gacha, as a condition to participation in a bonus "event” within a game (e.g., fight
with bosses and access to bonus worlds), with the conditions necessary to complete the
event clearly shown.
This example would be considered as Comp Gacha since it is essentially the same as
Example 1 above; in other words, merely adding such an event does not circumvent the
Act, which prohibits “card matching”.
A
B
Paid Gacha
Event
C Z
Another Virtual Item
D
E
Virtual Items
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5. (3) Example 3: Bingo Gacha (Comp Gacha with Pre-Determined Combination Patterns)
A case where users are clearly shown a pre-determined pattern of combinations of two
or more different Virtual Items that can be obtained through a Random Item Charge
such as Paid Gacha (e.g., a Bingo pattern, as shown below, of completing a line with 5
Virtual Items in a vertical, horizontal, or diagonal row on a 5 x 5 grid) as a condition to
getting another Virtual Item.
This example would be considered as Comp Gacha since, although it is not clearly
shown to users, each such combination will be ascertainable from the pattern.
A B C D E
F G H I J
Paid Gacha
K L M N O Z
P Q R S T Another Virtual Item
U V W X Y
Grid of Virtual Items
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6. (4) Example 4: Comp Gacha Providing Rewards, not Premium Virtual Items
A case where users are clearly shown a pre-determined combination of two or more
different Virtual Items that can be obtained through a Random Item Charge such as
Paid Gacha as a condition to getting rewards (e.g., enhancing various parameters of the
Virtual Items).
A
B A
Paid Gacha
B
C C
D
D E
E
Rewards such as
enhancing various
Virtual Items
parameters
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7. (5) Example 5: Comp Gacha with “Fusion”
A case where users are clearly shown a pre-determined combination of two or more
different Virtual Items that can be obtained through a Random Item Charge such as
Paid Gacha as a condition to getting another Virtual Item; however, in contrast to the
typical Comp Gacha described in Example 1, all or some of these collected Virtual
Items will disappear upon successful completion (this feature will be called
“Fusion”).
Note:
If Fusion is built in a game as one of its basic functions and can be used for any
combination of Virtual Items, it will not come under this example since the
combination is not pre-determined. Still, even if the combination is not
pre-determined, it is recommended that Fusion not be used for any combination of
three or more different Virtual Items.
A A
Paid Gacha
B B
C Fusion C Z
D D Another Virtual Item
E E
The original
Virtual Items
Items will
disappear.
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8. 4. Examples to Which Platform Operators should Pay Particular Attention
Platform Operators should review the following examples to consider whether similar
features should be adopted in Social Games on their platforms and if so, how such
features should be adopted, so that users can make informed decisions on whether
they should use such features as part of their play.
(1) Example 6: Collecting a Certain Number of the Same Items to Achieve Completion
A case where users are clearly shown the collection of a certain number (two or more)
of a pre-determined Virtual Item that can be obtained through a Random Item Charge
such as Paid Gacha, as a condition to getting another Virtual Item.
This example includes where users are clearly shown that the collection of a certain
number (two or more) of any one of predetermined Virtual Items or a certain number
(two or more) of any one of Virtual Items within a pre-determined Item Rarity is a
condition to getting another Virtual Item.
Please note, however, that this example does not include situations where users are
clearly shown that the collection of a certain number (two or more) of any Virtual Item is
a condition to getting another Virtual Item.
A
A
Paid Gacha
A Z
Another Virtual Item
A
A
Virtual Items
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9. (2) Example 7: Adding an Event After Completion
A case where users are clearly shown the collection of a certain number (two or more)
of a pre-determined Virtual Item that can be obtained through a Random Item Charge
such as Paid Gacha as a condition to participation in a bonus “event” within a game
(e.g., fight with bosses and access to bonus worlds) with the conditions necessary to
complete the event clearly shown.
A
A
Paid Gacha
A Event
Z
Another Virtual Item
A
A
Virtual Items
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10. (3) Example 8: Fusion
A case where users are clearly shown the collection of a certain number (two or more)
of a pre-determined Virtual Item that can be obtained through a Random Item Charge
such as Paid Gacha as a condition to Fusion; however, in contrast to Example 6, all or
some of these collected Virtual Items will disappear upon successful completion.
This example does not include situations where Fusion is built in a game as one of its
basic functions and can be used for any Virtual Item, since such Virtual Item is not
pre-determined.
A A
Paid Gacha
A A
A Fusion A Z
A A Another Virtual Item
A A
The original Items
Virtual Items
will disappear.
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11. This example will include the following situations, as long as the Virtual Items to be
collected are pre-determined. However, situations where Fusion is built in a
game as one of its basic functions and can be used for any Virtual Item will fall
outside this example.
A
Paid Gacha
Fusion
B
A
Fusion
C
A
Fusion
B
A
A
Paid Gacha
Fusion
B
A Fusion
C
A Fusion
D
A
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12. (4) Example 9: Collecting Points
This example involves situations where a certain number of points is assigned to a
Virtual Item and users reach a certain number of points by collecting Virtual Items with
points assigned, after which the users receive another Virtual Item depending on the
points users collect (this includes where the amount of points assigned will be
determined randomly, e.g., with dice).
A 1 point
B 2 points
Paid Gacha
30
C 3 points
points
Z
Another Virtual Item
D 4 points
E 5 points
Virtual Item Points
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13. (5) Example 10: Rarer Items or Guaranteed Better Odds
If users get a pre-determined Virtual Item or any Virtual Item within a pre-determined
Item Rarity through a Random Item Charge such as Paid Gacha, the users are
guaranteed to get a rarer Virtual Item or to have better odds of getting a rarer Virtual
Item (the time period of such guarantees may be limited).
Paid Gacha
A B C
If Item A Rarer Item or Rarer Item or
appears, odds higher odds higher odds
will change guaranteed guaranteed
thereafter.
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