- The eight patterns Japan's Consumer Affairs Agency treats as unclear, and what they have in common
- Common mistakes and fixes for blogs, X, Instagram and YouTube
- Why platform labels are a supplement, and what FX referrers need to watch beyond disclosure
Quick answers
- Q: Do Japan's stealth marketing rules apply to referrers?
- A: Enforcement is aimed at advertisers, and people who promote at an advertiser's request are generally not covered (Consumer Affairs Agency Q&A). But the agency's guidelines name affiliate content with paid referral links as a typical example of an advertiser's own advertising. How you disclose can put the advertiser at risk, so it is worth getting right on your side too.
- Q: Where should the disclosure go?
- A: Where readers look first, at least as large and as dark as the surrounding text. Under the title on a blog, at the start of the post on X, in the first line of an Instagram caption, and at the start of a YouTube video, again when the referral comes up, and in the description. The guidelines list end-only placement, small or faint text and burying it in hashtags as unclear.
This article is written for people who refer others to Kingfin, and is shared for informational and educational purposes. It is not a recommendation for any reader to deposit funds or open an account. The service being referred is an offshore FX and investment-related platform, and investing carries the risk of loss. This piece reflects a general understanding as of October 2026 and does not guarantee any registration count or income.
Written is not the same as seen
More affiliates now add "PR" to their posts and articles. But having the word somewhere on the page and having readers actually notice it are two different things. Japan's Consumer Affairs Agency, in its operational guidelines, lists eight ways a disclosure can still count as unclear even when the right word is there.
The basics, that the rules took effect on October 1, 2023 and that enforcement is aimed mainly at advertisers, are covered in our guide to Japan's stealth marketing rules for affiliates. This piece picks up where that one stops: where to put the disclosure, and how, so people actually see it, on blogs, X, Instagram and YouTube.
Why referrers should get this right
According to the agency's Q&A, affiliates who promote at an advertiser's request are generally outside the scope of the rules. There are still two good reasons to take disclosure seriously.
The first is the advertiser. The guidelines give, as an example of an advertiser's own advertising, the case where an advertiser uses an affiliate program to have referrers present its products. Content with paid referral links is treated as the advertiser's ad. If your disclosure falls short, it is the advertiser who answers for it, which is exactly why advertisers set disclosure rules for their referrers.
The second is your readers. If they know up front that you earn a commission, they can read with that in mind. That beats them working it out after the fact.
Content you write entirely on your own initiative, without being paid, is generally not covered. But the decision does not rest on whether you were paid or how much; purpose and the business relationship are weighed together. "It's only a small commission" is not a safe reason to skip it.
Words that count as clear
The guidelines give four words as clear examples: the Japanese words for advertisement (kokoku) and promotion (senden), the loanword puromoshon (promotion), and PR. A sentence such as "I received this product from Company A and am posting about it" also works.
There is a caveat attached: even with those words, a disclosure may not count if the overall presentation is unclear. Placement matters more than vocabulary.
Many Japanese blogs carry a stock line to this effect. It is not one of the examples in the guidelines. The agency's Q&A (Q13) takes up this very line and says that even at the top of a page, it has to be clear once text size and color are taken into account. Nor has the agency designated it as official wording. Do not treat it as a sentence you paste once and forget. Look at where it sits and how large it is.
Eight patterns that count as unclear
Section 3-1(2) of the guidelines sorts unclear disclosures into eight types, labeled a to h in English order. In our own words:
- a. Partial: the disclosure covers only part of the content
- b. Contradicted: "Ad" at the top, then "these are my independent thoughts as a third party" in the body (or the other way round)
- c. Hard to catch in video: shown too briefly to register, or in a long video shown only in the middle or at the end rather than at the start
- d. Unrecognizable wording: phrasing that does not read as advertising
- e. End only: placed only at the end, where it is hard to notice
- f. Small type: smaller than the surrounding text
- g. Buried: mixed into a long block of text, or in small or faint type that is hard to spot
- h. Lost in hashtags: hidden among a large number of hashtags
Put side by side, they come down to one test: is it where readers look first, at the same size as everything around it, and not buried in other words? Each platform just has its own ways of breaking that test.
Blogs and affiliate sites
A single line at the very bottom, in small light-gray type: "This article contains PR" (e, f, g). Or "PR" at the top, followed in the body by "these are my honest personal opinions, with no connection to any company" (b).
Put a line under the title, before the article starts, at least as large and dark as the body text, for example: "PR: this article contains links that pay me a referral commission." The agency's Q&A says that for affiliate sites, even a disclosure at the top is judged on its size and color. If only part of a page is advertising, the disclosure should sit near that part. And do not undercut it with "just my personal opinion" in the body.
Comparison sites get a specific note in the guidelines: if it is clear that the whole site is advertising, each product does not need its own label. The condition is that the whole site is clearly an ad. A small line tucked away somewhere on the site is unlikely to meet it.
X
Nothing in the post itself, with "PR" in the second post of the thread. "#PR" mixed into a dozen hashtags at the end (h). Wording like "a service I always rely on" that never actually says it is an ad (d).
Start the post that carries the referral link with "PR" or "Ad". The agency's Q&A says a disclosure in the replies rather than the post itself will often not count as clear. It also says that stating your affiliation alone does not necessarily make a disclosure clear.
X was reported to have added a "Paid partnership" label in March 2026. We have not been able to read the official help page ourselves, so check your own app and X's help center for whether it is available to you and whether it covers affiliate links. Either way, keep "PR" in the post text.
A lone "*PR" dropped into the middle of a long caption (g). "#PR" tacked onto the hashtag pile at the end (h).
Put "PR" in the first line of the caption, and use the official label as well. Instagram's Branded Content Policy requires posts made in exchange for money or goods to be disclosed with the paid partnership label, which works by tagging a business partner on the post.
YouTube
"This video contains PR" shown only at the end of a long video. A tiny caption that flashes for a moment at the start and never comes back (both c).
Say it at the start, out loud and on screen. Say it again when the referral comes up, and put it at the top of the description. The agency's Q&A notes that viewers may join partway through, so a disclosure only at the start may not be enough, and it is preferable to make it clear throughout. YouTube also lets you declare paid promotion in the video's details (advanced settings), even after upload. Viewers then see a disclosure message during the first 10 seconds of the video only, so it does not replace saying it yourself.
We found no official document saying that a platform label on its own satisfies Japanese law. Treat labels as a supplement, and still say it in your own words at the start.
Beyond disclosure: FX referrals
Disclosure deals with stealth marketing. Soliciting and advising on financial products are governed by separate rules, so "I wrote PR" does not settle everything. At a minimum:
- Do not give individual advice, such as which currency to trade and when
- Do not use absolute claims like "guaranteed profit" or "no risk to your principal"
- Make it easy for readers to check for themselves whether a service is registered in Japan
Japan's Financial Services Agency states on its page warning about solicitation by unregistered overseas firms (Japanese) that overseas firms dealing in financial instruments with Japanese residents as a business need to be registered. It also publishes a warning about investment solicitation on social media (Japanese). If readers ask, point them to these pages and answer with the facts. For anything specific to your situation, talk to a professional.
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Frequently asked questions
Disclosure: OlympTrade is an offshore platform that is not registered with Japan's Financial Services Agency (FSA), so Japan's investor protection schemes do not apply. This article is informational and educational content from Kingfin's English editorial team and does not guarantee any specific result or income. It is not a recommendation for any reader to deposit funds or open an account. It reflects a general understanding as of October 2026 and does not guarantee that effects or outcomes will repeat. Results from side-hustle or affiliate activity vary from person to person and take time to materialize. We cannot promise that anyone "will definitely earn" or that success is easy for everyone. Kingfin's affiliate program promotes FX and investment-related services, and trading carries the risk of loss. Results vary from person to person, and no income amount is guaranteed.
