Regulatory Compliance

Reviewing premiums, prize draws and contests, and promotional campaigns

Whether campaign benefits—such as prizes awarded by a random drawing, benefits offered to all purchasers, or benefits in campaigns requiring social media follows or posts—are subject to premium regulations depends on how the provision of the benefits is connected with a transaction, rather than on what they are called. Under the Act against Unjustifiable Premiums and Misleading Representations (the "Premiums and Representations Act"), premiums are goods, money, or other economic benefits designated by the Prime Minister that a business operator provides to the other party, as a means of inducing customers, in connection with transactions involving goods or services that the business operator supplies.

Where benefits qualify as premiums, the way value limits are set differs depending on whether they are offered through prize draws and contests, such as random drawings, or other than through prize draws and contests (sōzuke premiums). Even where a purchase is not required to enter, the treatment may differ depending on the conditions from the announcement through receipt of the premium, such as whether a store visit is required to receive it.

We assist with classifying campaigns, checking value limits, and reviewing the conditions for providing benefits, based on campaign proposals, entry rules, draft announcements, and materials supporting the calculations. The limits on sōzuke premiums explained here are based on the public notice currently in force.

Reviewed by Keishi Yoshikawa, Attorney at Law and Patent Attorney (Dai-Ichi Tokyo Bar Association)

Last updated: September 27, 2026

What to check first

The following are examples of matters a company may wish to check when planning a campaign.

The parties and the benefits offered — The company checks who provides what goods, money, points, services, or other benefits, and to whom.
The connection with a transaction — The company checks the purpose of providing the benefits and their relationship with transactions involving the relevant goods or services.
Conditions at each stage — The company checks the conditions for entry, membership registration, purchases, posts, store visits, and receipt of premiums.
How recipients and values are determined — The company checks whether recipients or the value of benefits are determined by a random drawing, relative merit, order of arrival, or provision to everyone.
The distinction from discounts and similar benefits — The company checks whether the benefits are excluded from premiums as discounts or similar benefits, or qualify as premiums but are exempt from the value limits.
Calculating values — The company checks the materials and calculation methods used to determine the transaction value and the premium value.
Value limits and the number of winners — The company checks the maximum individual and aggregate premium values, total projected sales from the relevant transactions, and the number of winners.
Industry-specific regulations — The company checks whether industry-specific notices or fair competition codes apply.

Industry-specific notices have been issued for the newspaper, magazine, and real estate industries and for suppliers of pharmaceuticals for medical use, suppliers of medical devices, and clinical testing laboratories.

How we can helpAssessing whether benefits qualify as premiums / Classifying prize draws and contests and sōzuke premiums and checking the limits / Calculating transaction and premium values / Designing social media campaigns / Reviewing entry rules and announcements / Campaign changes and responses to winners

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Contents

1 Assessing whether benefits qualify as premiums
2 Classifying the method of provision and checking the limits under the notices currently in force
3 Clarifying the connection with a transaction and calculating values
4 Aligning announcements with implementation and preparing for regulatory changes
Key legislation and official sources
Frequently asked questions

1 Assessing whether benefits qualify as premiums

Customer inducement, connection with a transaction, and economic benefits

The guidelines for applying the notice designating premiums and representations (the "designation guidelines") state that whether a benefit serves as a means of inducing customers is assessed objectively, regardless of the provider's subjective intent or the campaign's stated purpose. Providing another economic benefit on condition of a transaction, or a retailer or service provider offering benefits to visitors to its own store, is treated as provision in connection with a transaction.

Distinguishing premiums from discounts, after-sales services, and accessories

Economic benefits recognized as discounts in light of normal business practices are not included in premiums, and the designation guidelines give examples of reducing the price payable according to standards considered reasonable in ordinary commercial dealings, and providing additional quantities of the same goods or services for the same price. After-sales services and economic benefits recognized as accessories to goods are also assessed taking into account the characteristics of the goods, the nature and necessity of the services, the contractual terms of the transaction, and other relevant factors. Even where a discount is outside the premium regulations, how the discount is presented remains an issue under the rules on representations. Price and discount representations are explained in "Reviewing claims about prices, discounts, free offers, and limited periods."

Campaigns with no purchase requirement (open prize draws and contests) and social media campaigns

Campaigns announced widely in which entry does not require a purchase or store visit (so-called open prize draws and contests) are outside the premium regulations and have no specified value limits. The CAA Q&A on premiums states that merely requiring free membership registration does not normally constitute the provision of an economic benefit in connection with a transaction (CAA Q&A, Q15). Following a social media account or clicking "like" is also not normally regarded as leading directly to the purchase of goods or services (CAA Q&A, Q18).

However, where a campaign is advertised as offering higher odds of winning for posts that also include a product image or comments on the experience of using the product, entrants are regarded as highly likely to purchase the product when entering (CAA Q&A, Q19). A campaign allowing entry by registering as a friend on social media, but requiring winners to visit a store to receive their premiums, is regarded as subject to the rules on sōzuke premiums (CAA Q&A, Q20). The designation guidelines state that even where a transaction is not a condition, the provision of economic benefits constitutes provision in connection with a transaction if it is directed primarily at parties to transactions. The company checks not only the conditions at entry, but also whether a purchase or store visit becomes necessary at any point from the announcement through receipt of the premium.

Campaigns directed at businesses

Prize draws and contests using methods such as drawing lots are regarded as subject to premium regulations even where the recipients are businesses (CAA Q&A, Q56). Offers made other than through prize draws and contests are regulated as sōzuke premiums when directed at general consumers, while, as a general rule, the regulations do not apply to offers directed at businesses. However, for suppliers of pharmaceuticals for medical use, suppliers of medical devices, and clinical testing laboratories, goods and services offered to all eligible business recipients, such as medical institutions, are also regarded as subject to regulation (CAA Q&A, Q56).

2 Classifying the method of provision and checking the limits under the notices currently in force

Maximum individual and aggregate values for prize draws and contests

Prize draws and contests are arrangements in which the recipient or value of a premium is determined by drawing lots or another method involving chance, or by the relative merit or correctness of a specified act (public notice on prize draws and contests). The maximum individual value of premiums offered through prize draws and contests must not exceed 20 times the value of the relevant transaction (or 100,000 yen if that amount exceeds 100,000 yen), and their aggregate value must not exceed 2% of the total projected value of transactions relating to the prize draws and contests. Determining recipients by the order of store visits or applications is not regarded as a prize draw or contest.

Joint prize draws and contests

Where a substantial majority of retailers or service providers in a particular area participate jointly; where a substantial majority of retailers or similar businesses in a single shopping district participate jointly (at midyear, year-end, or similar times, on no more than 3 occasions per year and for no more than 70 days in total per year); or where a substantial majority of businesses of a particular type in a particular area participate jointly, the maximum individual premium value may be up to 300,000 yen, and the aggregate value up to 3% of the total projected value of transactions relating to the prize draws and contests (public notice on prize draws and contests). However, this does not apply where participation by other businesses is unjustifiably restricted. Having multiple sponsoring companies does not, by itself, mean that a campaign is a joint prize draw or contest.

Sōzuke premiums and exemptions from the restrictions

The value of premiums offered to general consumers other than through prize draws and contests must be within two-tenths of the transaction value (or 200 yen if that amount is less than 200 yen) and must not exceed the limit considered appropriate in light of normal business practices (public notice on sōzuke premiums). This restriction does not apply to goods or services necessary for the sale or use of goods or the provision of services; samples and other promotional goods or services; discount coupons and other certificates promising discounts for use in the provider's own transactions; or goods or services offered for store openings, business anniversaries, and similar events, in each case where considered appropriate in light of normal business practices. These benefits qualify as premiums but are exempt from the restrictions on sōzuke premiums. They are distinct from discounts and similar benefits that do not qualify as premiums in the first place (Section 1).

Prohibition of card matching

Offering premiums through prize draws and contests that require participants to present a specified combination of different types of tokens from a set bearing two or more types of characters, pictures, symbols, or similar markings is prohibited (public notice on prize draws and contests).

Overview of value limits

Category	Transaction value	Maximum individual premium value	Aggregate premium value
General prize draws and contests	Less than 5,000 yen	20 times the transaction value	2% of the total projected value of transactions relating to the prize draws and contests
General prize draws and contests	5,000 yen or more	100,000 yen	As above
Joint prize draws and contests	Regardless of transaction value	300,000 yen	3% of the total projected value of transactions relating to the prize draws and contests
Sōzuke premiums	Less than 1,000 yen	200 yen	No aggregate limit
Sōzuke premiums	1,000 yen or more	Two-tenths of the transaction value	No aggregate limit

Based on the public notices on prize draws and contests and on sōzuke premiums (as of September 2026). Sōzuke premiums are also subject to the limit considered appropriate in light of normal business practices. Industries with industry-specific notices need to be checked separately.

3 Clarifying the connection with a transaction and calculating values

Transaction value

When premiums are offered to purchasers according to the purchase amount, that amount is the transaction value. Where premiums are offered regardless of the purchase amount, or to store visitors without a purchase requirement, the transaction value is 100 yen as a general rule, and the treatment of cases where the lowest value of the store's usual transactions is below or above 100 yen is also specified. The same approach applies, with the necessary adaptations, to the transaction value for prize draws and contests. The CAA Q&A states that the transaction value is normally the lowest amount among the transactions necessary to receive the premium (CAA Q&A, Q59).

Premium value

Where identical items are commercially available, the premium value is the price that the recipient would normally pay to purchase them. Where they are not commercially available, the price that the recipient would normally pay if purchasing the item is calculated, taking into account the acquisition price, market prices of comparable products, and other relevant factors. A low acquisition price therefore does not, by itself, mean that the premium can be assigned a low value. If comparable products are not commercially available either, the price that the recipient would normally pay if purchasing the item is calculated from factors such as the acquisition price, manufacturing cost, and the profit margin anticipated if the premium were sold (CAA Q&A, Q76). The company keeps records of the products used for comparison and the reasons for selecting them, as well as the basis for the costs and assumed profit margin.

Treatment of points and coupons

The CAA Q&A states that where using accumulated points to make the purchase is a condition, the transaction value is the price payable less the value of the points used (CAA Q&A, Q62). The restrictions on sōzuke premiums do not apply to discount coupons and similar certificates used in the provider's own transactions where they are considered appropriate in light of normal business practices (public notice on sōzuke premiums). The designation guidelines state that whether an economic benefit qualifies as a discount is assessed from the perspective of maintaining fair competition, taking into account the nature of the transaction, the nature of the economic benefit, how it is provided, and other relevant factors. The company identifies where points can be used, what they can be exchanged for, and how the choice between points and other benefits operates, and checks these against the published categories.

Total projected sales and combining values across multiple campaigns

The total projected sales on which the aggregate limit for prize draws and contests is based are the total projected sales of the eligible products during the campaign period. Where two or more premiums are offered in connection with the same transaction, premiums equal to their combined value are treated as having been provided, even if the offers are made through separate campaigns. For two or more prize draws or contests in connection with the same transaction, the guidelines for applying the public notice on prize draws and contests state that, where they are conducted jointly with other business operators, each participating business operator is treated as having provided premiums equal to the combined value, even if the campaigns are separate, and that where a business operator, without acting jointly with other business operators, offers additional premiums through further prize draws or contests to the winners of a prize draw or contest, the business operator adding those premiums is treated as having provided premiums equal to the combined value. By contrast, prize draws and contests each requiring the purchase of different products are treated as conditional on separate transactions, with the limits calculated separately (CAA Q&A, Q93). The company identifies the transactions eligible for entry, the business operators conducting the campaigns, the possibility of winning in more than one campaign, and the period of the relevant sales.

4 Aligning announcements with implementation and preparing for regulatory changes

Representations about entry conditions, the number of winners, and the drawing method

The CAA Q&A states that cases such as having fewer actual winners than the number announced may violate the Premiums and Representations Act as misleading representations as to transaction terms (CAA Q&A, Q87). The company compares the announced conditions with the status of entries and the actual conduct of drawings and provision of premiums.

Campaign changes and responses to entrants

If the campaign content is to be changed, the company identifies the previous announcements and the status of implementation, and considers whether changes are permissible, how to announce them again, and how to respond to people who have already entered.

Supporting calculations and records of drawings and premium provision

We propose ways to keep records of the basis for calculating transaction and premium values, the methods and results of drawings, and the provision of premiums. Review arrangements and oversight of external providers are explained in "Advertising review procedures, representation management systems, and oversight of external providers."

Review of the limits on sōzuke premiums

The government's Regulatory Reform Implementation Plan (Cabinet decision of July 21, 2026) provides that the CAA is to investigate matters such as business operators' promotional activities and changes in general consumers' purchasing behavior, and then consider increases to both the 200 yen limit for transactions worth less than 1,000 yen and the limit of two-tenths of the transaction value for transactions worth 1,000 yen or more, reaching a conclusion in 2027. Under the Premiums and Representations Act, restrictions on the provision of premiums are changed by public notice, after holding a public hearing to seek the opinions of relevant businesses and the general public and hearing the opinions of the Consumer Commission.

The value limits shown on this page are based on the notices in force as of September 2026. If an amendment is published, we will check its content, effective date, and transitional provisions and update this page.

Key legislation and official sources

English translations of legislation are provided for reference. The Japanese texts are authoritative.

Article topic	Legislation or official source	Source type and English version reviewed
Definition of premiums; misleading representations as to transaction terms; procedures for changing premium restrictions	Act against Unjustifiable Premiums and Misleading Representations— Japanese text on e-Gov	Legislation. English translation (earlier version). The translation identifies its last version as Act No. 29 of 2023.
Scope of premiums and exclusion of discounts	Designation of premiums and representations	Public notice (Japanese). English title translated by the firm.
Customer inducement, connection with transactions, and discounts	Guidelines for applying the designation of premiums and representations	Official guidance (Japanese). English title translated by the firm.
Prize draws and contests: definition, limits, joint campaigns, and card matching	Restrictions on premiums offered through prize draws and contests	Public notice (Japanese). English title translated by the firm.
First-come offers, transaction values, total projected sales, and combining campaigns	Guidelines for applying the restrictions on prize draws and contests	Official guidance (Japanese). English title translated by the firm.
Sōzuke premiums: limits and exemptions	Restrictions on premiums offered to general consumers	Public notice (Japanese). English title translated by the firm.
Transaction values and combining premium values	Guidelines for applying the restrictions on premiums offered to general consumers	Official guidance (Japanese). English title translated by the firm.
Premium values	Criteria for calculating premium values	Official guidance (Japanese). English title translated by the firm.
Open prize draws and contests	CAA overview of premium regulations	Official information (Japanese). English title translated by the firm.
Membership registration, social media campaigns, and store visits	CAA Q&A on premiums: Q15, Q18–Q20	Official guidance (Japanese). English title translated by the firm.
Offers to businesses, transaction values, points, and premium values	CAA Q&A on premiums: Q56, Q59, Q62, Q76	Official guidance (Japanese). English title translated by the firm.
Numbers of winners and separate transactions	CAA Q&A on premiums: Q87, Q93	Official guidance (Japanese). English title translated by the firm.
Industry-specific notices	Newspapers; magazines; real estate; pharmaceuticals for medical use, medical devices, and clinical testing laboratories	Public notices (Japanese). English titles translated by the firm.
Fair competition codes	CAA information on fair competition codes	Official information (Japanese). English title translated by the firm.
Planned review of sōzuke premium limits	Regulatory Reform Implementation Plan, July 21, 2026	Cabinet decision (Japanese). English title translated by the firm.

Legal information reviewed: September 27, 2026

Frequently asked questions

Is a campaign outside the premium regulations if no purchase is required?

The absence of a purchase requirement for entry does not, by itself, determine the treatment. For example, a campaign requiring winners to visit a store to receive their premiums is regarded as subject to the rules on sōzuke premiums (CAA Q&A, Q20).

Do value limits also need to be considered when distributing coupons or points?

Benefits recognized as discounts in light of normal business practices are not included in premiums, and the restrictions on sōzuke premiums do not apply to discount coupons and similar certificates used in the provider's own transactions where they are considered appropriate. Treatment differs according to the conditions of use and what the benefits can be used for, so each case is checked individually.

If several companies sponsor a campaign, do the higher limits for joint prize draws and contests apply?

The higher limits for joint prize draws and contests apply only in the cases specified by the public notice, such as joint campaigns conducted by a substantial majority of retailers and similar businesses in a particular area.

Can the acquisition price be used to calculate the limit if the premium was purchased cheaply?

Commercially available items are valued at the price that the recipient would normally pay to purchase them (criteria for calculating premium values). For items not commercially available, the price that the recipient would normally pay if purchasing the item is calculated from the acquisition price and market prices of comparable products or, if there are no comparable products, from factors such as manufacturing costs and anticipated profit margins. The acquisition price does not simply become the premium value (criteria for calculating premium values; CAA Q&A, Q76).

Are random drawings open only to corporate customers also regulated?

Prize draws and contests using methods such as drawing lots are regarded as regulated even where the recipients are businesses (CAA Q&A, Q56). As a general rule, the regulations are regarded as not applying to benefits offered to businesses other than through prize draws and contests, with exceptions for certain industries, such as pharmaceuticals for medical use (CAA Q&A, Q56).

Is it permissible to reduce the number of winners after announcing "100 winners"?

Cases such as having fewer actual winners than the number announced may constitute misleading representations as to transaction terms (CAA Q&A, Q87).

Contact

Making an inquiry

Please let us know, as far as you are able, the campaign proposal, draft entry rules and announcements, materials showing the prices of the premiums and eligible products, and the planned schedule.