Odds near the summon CTA: store rules versus ad creative practice

Apple requires loot-box odds disclosure before purchase; CAA Japan materials address gacha/comp-gacha representation. Ads that promise summons without odds remain a creative-compliance gap.
Some JP/KR-facing UA teams put pity or rate copy near the summon CTA in paid ads. Store rules and advertising law are not the same object. This brief separates what the sources we read require from what ads often omit.
Store rule (Apple)
App Store Review Guidelines 3.1.1 states that apps offering “loot boxes” or other mechanisms that provide randomised virtual items for purchase must disclose the odds of receiving each type of item to customers prior to purchase. That obligation sits on the purchase path inside the app (and related metadata expectations elsewhere in 2.3). It is not, by itself, a Meta or TikTok ad-library mandate to render a rates table inside a 15-second video.
Japan representation context (CAA)
Japan’s Consumer Affairs Agency publishes Q&A on internet transactions and “card matching”, clarifying how premium-representation rules interact with paid gacha mechanics (including historical “comp gacha” / card-matching interpretations). This is a jurisdiction representation source for product design and claims—not a permission slip to invent “guaranteed SSR” lines in UA.
When disclosure in the ad helps — and when it backfires
| Pattern | Observation | Inference |
|---|---|---|
| Rates/pity only in help centre | Common | Ad reviewers and players may treat the ad promise as incomplete relative to in-app rules |
| Numeric odds burned into the endcard | Rare; must match live tables | Mismatch between ad table and live pity is a compliance incident waiting to happen |
| “See rates in game” near CTA | Middle path | May reduce overclaim risk without freezing a numeric table in paid media |
| “Guaranteed SSR” without conditions | High risk | Conflicts with both store odds expectations and representation caution |
Not claimed: that any named live ad was inspected for this brief; Meta Ad Library was not used as a primary read from the source source here. Creative casefiles that need a stable library URL remain separate assignments.
Operator minimum
- Align summon claims with the live rates/pity page before scaling spend in JP/KR.
- Keep a dated screenshot of the in-app odds panel beside the creative brief.
- Treat Apple 3.1.1 as a purchase-path requirement; treat CAA materials as representation context for Japan—not interchangeable checklists.
Download the claim vs rule CSV.


