The December 12th issue of Jinja Shinpō had an interesting front-page article about cashless payment systems and the implications for jinja. It turns out that introducing such facilities at jinja is not at all straightforward.
First, there are four different types of cashless payment in Japan, and they are covered by different laws. These are pre-paid systems, funds transfer systems, direct bank payment systems, and credit systems. The law for pre-paid systems does not allow them to be used for charitable donations, as they must be used to pay for goods or services. The others can legally be used for such purposes, but the companies that offer the services may impose further restrictions.
The journalists at Jinja Shinpō sent enquiries to a number of such companies asking what their cashless systems could be used for, and got answers back from seven. No credit card companies replied, so there is no detailed information about that system here. (I know that it is possible to make charitable donations by credit card in Japan, because I do, but I don’t know the details.)
The main body of the enquiry asked whether the company’s cashless system could be used for various things at a jinja: offerings for an annual matsuri, offerings in the offering box, omamori, omikuji, personal request matsuri, off-site matsuri, and entry to a garden or museum. All of the companies said that it would be possible to use their systems to pay for admission to gardens or museums, which is unsurprising — that is straightforward payment for a service, and was almost certainly included as an example that should be fine.
The two companies offering direct bank payments (debit cards, basically, although the form may be a smartphone app) said that all the kinds of payment were possible, although one noted that its contract forbade shops from recruiting for religious groups. This kind of system is covered by the banking law, and it seems that this is basically the same as cash from a legal perspective.
The funds transfer companies did not permit simple donations, but one of them, which claimed to have many religious groups as customers, did allow everything else. The other did not permit payments for off-site matsuri. The pre-paid companies were most restrictive, saying that it would only be allowed for omamori and omikuji — in other words, for the ones that look like purchasing a product.
That raises its own problems, because the tax office’s official legal stance is that the truly ridiculous mark-up on omamori indicates that this is not a purchase, but rather a token of appreciation for a donation, and thus religious corporations do not need to treat that income as commercial income. However, if the jinja is treating them as commercial goods in order to use a cashless payment system, that could cause issues with the tax office. (Or vice versa — in either case, it is likely to cause trouble for the jinja.)
One of the companies actually raised the more fundamental problem in its response. These are supposed to be religious acts, not commercial transactions. If Jinja Honchō issues official guidance that they can be treated as commercial, that would be a problem. Without that, however, it looks as though it may be impossible (illegal) for jinja to use the most popular cashless systems.
I must confess that I had not realised how complex this was, but it is a serious problem for jinja. I have basically stopped offering coins on my normal jinja visits, simply because I have hardly any change these days — almost everything is cashless. It does make me wonder whether it would be more useful for Shinto Seiji Renmei to stop going on about changing the constitution, and instead push for a change in the law covering cashless payments so that jinja can legally use the popular systems.