National Police Agency issues circular on pachinko advertising handling

The National Police Agency (NPA) issued Notification No. 157, dated December 23, 2022, to the heads of all prefectural police headquarters, titled "Handling of Advertising and Promotion in Pachinko Businesses"¹. It sets out the operational policy for applying advertising and promotion restrictions to pachinko operators, their appointed managers and industry bodies, and instructs prefectural police to focus guidance and enforcement on areas that particularly require it¹.

The notification states that Article 16 of the Amusement Business Act covers advertising and promotion that suggests acts grossly stimulating gambling spirit or suspected legal violations, and that this applies to audio advertising as well as visual advertising¹. It adds that Article 16 is not limited to advertising and promotion carried out in the vicinity of the business premises¹. Advertising materials at a business premises that suggest grossly stimulating gambling spirit or suspected violations fall under the maintenance obligation for premises structure and equipment under Article 12¹. Because gaming machines installed in pachinko premises are excluded from the structure and equipment provisions of Article 4, Paragraph 2, Item 1, stickers or similar items with such displays attached to machine glass panels should instead be considered under prefectural ordinance rules against operating in a manner that grossly stimulates gambling spirit¹.

The notification lists six categories of display that would be treated as violations of the advertising and promotion restrictions or the premises maintenance obligation¹:

On industry self-regulation, the notification notes that the Pachinko and Pachislot Industry 21st Century Association has drawn up national guidelines including securing warning slogans of a certain size¹:

Police are told to respect cooperative self-regulation rules that do not conflict with the notification, and not to take administrative guidance against an operator merely for breaching those rules¹.

What it means for players

The notification concerns how pachinko premises advertise, not the legality of playing. Displays that promise easier wins, better settings at particular times, higher prize exchange values or large numbers of balls are treated as suspected violations, so players are less likely to see such claims on shop fronts, in flyers or in audio announcements. The notification also confirms that warning slogans about playing in moderation and the 18-and-over age rule form part of the industry's national guidelines¹. It does not change payout rates, machine specifications or the rules on exchanging prizes, and it does not set out any new restrictions on individual players.

What happens next

Where a violation is found, police are to give necessary administrative guidance and share information with the prefectural cooperative¹. If an operator repeats violations, does not comply with guidance, or industry efforts are not expected to work, police are to consider instructions and other measures under Article 25¹. Before any administrative action over a violation of the premises maintenance obligation covered by the notification, police should give the operator an opportunity to explain¹. For the time being, prefectural police must coordinate with the NPA Community Safety Bureau's Security Division in advance before taking administrative action over such violations¹.