First, ask whether it is "tied to a transaction"
Japan's Act against Unjustifiable Premiums and Misleading Representations (the Premiums and Representations Act) caps the value of prizes given along with the sale of goods or services. The first question that decides whether a cap applies is whether the prize is given "in connection with a transaction". A campaign open only to people who bought a product, or one where only people who visited a store get something, is tied to a transaction, so caps apply.
On the other hand, a campaign that anyone can enter, with no purchase or visit needed, is treated as a sweepstakes not tied to a transaction (an "open sweepstakes"). According to the Consumer Affairs Agency's overview of premium regulation, open sweepstakes once had a 10 million yen cap, but it was abolished in April 2006, and there is now no specific cap on the value of the prize.
The key question for a "follow and repost to enter" campaign on social media is which of the two it falls into.
Social media examples in the Consumer Affairs Agency's Q&A
In its Q&A on premiums, the Consumer Affairs Agency gives three examples of social media sweepstakes. The basic idea is whether people who want to enter are likely to be led to buy the product.
| Campaign | Key point of the agency's answer | Rule that applies |
|---|---|---|
| Follow the official account and press "like" to enter. Prizes are mailed | Following and liking do not usually lead directly to buying a product. No store visit is needed | Not covered by premium rules unless other circumstances tie it to a transaction |
| Follow and post with a designated hashtag to enter. Posting a product photo or review as well doubles the chance of winning | People are likely to buy the product to raise their chance of winning | Tied to a transaction, so the general sweepstakes rule applies |
| Register as a friend to enter. Winners go to a store to receive the prize | A store visit is required, so it is tied to a transaction. Anyone who visits gets one | The open-to-all gift (sōtsuke) rule applies |
What this table shows is that it is neither "social media means anything goes" nor "every giveaway is off limits." Even for a follow campaign, once you add a condition that gives an advantage for buying a product or a condition that requires a store visit to receive the prize, it becomes a campaign with caps.
Easy-to-miss conditions that count as "tied to a transaction"
The Q&A has other examples to watch for. Even if anyone can enter, if the way to enter is printed on a product's packaging, the campaign is seen as mainly targeting people who buy that product and is considered tied to a transaction. A campaign that sends winners a discount coupon for your own store requires a store visit and so is tied to a transaction, but if it is recognized as a discount within normal business practice, it is said not to count as a premium.
For a campaign where "entry starts on social media but a purchase or visit comes into it somewhere," the safe approach when in doubt is to treat it as tied to a transaction and keep it within the caps.
Quick reference of the caps
Prizes tied to a transaction have three kinds of caps depending on how they are given. Based on the Consumer Affairs Agency's overview and Q&A, here are the caps as of October 2026.
| Type | How it is given | Transaction value | Maximum per person | Total prize value |
|---|---|---|---|---|
| General sweepstakes | Given to some people by lottery or ranking | Under 5,000 yen | 20 times the transaction value | 2% of the expected total sales for the sweepstakes |
| General sweepstakes | Same | 5,000 yen or more | 100,000 yen | 2% of the expected total sales for the sweepstakes |
| Joint sweepstakes | Held jointly by several businesses, such as a shopping street | Any | 300,000 yen | 3% of the expected total sales for the sweepstakes |
| Open-to-all gift (sōtsuke) | Given to everyone who meets the condition | Under 1,000 yen | 200 yen | No limit set |
| Open-to-all gift (sōtsuke) | Same | 1,000 yen or more | 2/10 of the transaction value | No limit set |
"Transaction value" is the amount of the purchase the campaign targets. For a visit-based campaign that does not require a purchase, the Q&A explains that the transaction value is that of the cheapest item the shop normally sells (in principle 100 yen). For example, in a general sweepstakes drawn from buyers of a 1,000 yen product, the prize for one person is capped at 20,000 yen, and the total prize value at 2% of the sales expected during the campaign period.
X's contest rules
In its guidelines for running contests, X lists what organizers must do. All of them exist so that participants do not break X's rules.
| What X requires | What it means for your campaign |
|---|---|
| Do not have people create multiple accounts | State in the rules that anyone entering from multiple accounts loses eligibility |
| Do not have people repeat the same post | Don't set conditions like "the prize goes to whoever reposts the most." It helps to state that entering many times a day is invalid |
| Have people include the organizer's @username | So that you can verify every entry, have people enter by replying or with a post that includes the @ |
| Use only relevant hashtags | Don't make people add hashtags unrelated to the post |
| Follow X's rules and the law | Complying with applicable law is the organizer's responsibility |
X's automation rules also ban automated liking, and allow automated replies only when the other person has asked for them. When you send winner notifications automatically, it is safest to limit them to replies to people who entered or DMs to entrants who have shown they are willing to receive them.
Facebook and Instagram contest rules
Meta's Pages, Groups and Events Policies require that, when you run a promotion (a contest, giveaway or sweepstakes), participants completely release Meta from legal liability and be made aware that the promotion is not sponsored, endorsed or run by Meta. They also say you must not ask or encourage participants to promote the promotion by sharing, reposting, tagging and so on. Meta does not help run promotions, and running one is the organizer's responsibility.
Instagram's promotion guidelines likewise require participants to release Instagram and state that Instagram does not sponsor the promotion, and they ban encouraging inaccurate tagging, such as tagging people who are not in the photo. If you are planning a "tag a friend to enter" campaign, reread these pages before you run it.
Other things to watch besides prizes
Entrants' personal information
You will have to ask winners for their address and name. Ask only winners, ask only for what you need to send the prize, and collect it by DM or an entry form, not in a public reply. State in the rules what you will use it for and when you will delete it, and add a link to your own privacy policy.
When you give something in return for a post
Since October 1, 2023, advertising that is not identifiable as advertising (so-called stealth marketing) has been added to the misleading representations under the Premiums and Representations Act. According to the Consumer Affairs Agency's explanation of stealth marketing, the businesses that sell the product are the ones regulated, and posts that a business asks or instructs a third party to make count as the business's own representations. For a campaign where people post reviews of a product in exchange for a prize, check this point as well when you design it.
What to write in the entry rules
The rules should state the organizer, the period, the conditions to enter, the number of winners and prizes, how winners are chosen, how and by when winners are notified and must reply, how entries from multiple accounts are handled, how personal information is handled, and the social network's release. Decide the period, number of winners and notification method on the assumption that you will not change them later. Changing conditions after entries have begun breaks your promise to the people who entered.
What you can do in SNS TOWN
Campaigns in SNS TOWN are built so that people enter by replying to a post on X. You can require a reply and add a keyword, a follow or a repost (including quotes) as conditions. The form recommended in X's guidelines, "enter by replying to the organizer's post", works as is, and likes are not used as a condition.
There are two methods. A lottery picks winners automatically after the deadline. Each person is treated as having entered once, and everyone has the same chance. Instant win is a method where winners are chosen one after another during the entry period, and winner notifications also go out during the period. In both, the system picks winners at random from entrants who meet the conditions. There is also a setting that excludes very new accounts and accounts with few followers, which can reduce entries from multiple accounts.
You can have between 1 and 100 winners, and notify them by reply or DM. You can announce winners in a post only for campaigns with up to 5 winners. After entries start, settings cannot be changed and you can only stop the campaign, so it never ends up different from your entry rules. How to make one is in Create a campaign and Draw winners. Check pricing for the plans that include it.
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免費開始Frequently asked questions
Is there a prize cap for a campaign where people just follow and repost to enter?
For a campaign where people enter by following and liking and the prize is mailed, the Consumer Affairs Agency's Q&A answers that premium rules do not apply unless other circumstances tie it to a transaction. But if you add conditions such as making winning easier by buying a product, or requiring a store visit to receive the prize, it becomes a campaign with caps.
What if we give a gift to everyone who visits our store?
A visit is a condition, so it is tied to a transaction, and since everyone gets it, it counts as an open-to-all gift (sōtsuke). The cap is 200 yen if the transaction value is under 1,000 yen, and 2/10 of the transaction value if it is 1,000 yen or more.
What is the "expected total sales" used for the total prize value?
It is the total sales you expect during the sweepstakes period from the transactions the sweepstakes covers. In a general sweepstakes, keep the total prize value within 2% of that. A longer period raises expected sales, but the expectation should be one you can back up with grounds.
Can we choose winners from people with many followers?
X's guidelines and the Premiums and Representations Act do not set detailed rules on how winners are chosen, but choosing in a way that differs from the method in your entry rules would deceive the people who entered. If you wrote a lottery, draw by lottery. If you want to reduce fraudulent entries, write that into the entry conditions from the start.
Does the Premiums and Representations Act apply to instant win?
It applies in the same way as a lottery, depending on whether it is tied to a transaction. Even if you learn the result on the spot, it is still a sweepstakes that gives prizes to some people. The term is explained in instant win.
Where should I ask if I am not sure about the legal judgment?
The Consumer Affairs Agency and the prefectural offices in charge of the Premiums and Representations Act take inquiries. If you want the wording of your entry rules checked as well, having a lawyer familiar with the Act review them is the surest way. This article is a guide to judgment and does not guarantee that any particular campaign is acceptable.
