The AI Framework Act's domestic-agent duty came into force on 22 January 2026, administered by the Ministry of Science and ICT. It is the newest of Korea's local-representative regimes, and for a foreign AI-service provider it is the one most likely to be overlooked — precisely because it is new, and because its central threshold is set low enough to reach companies that do not think of themselves as large.

The KRW 10 billion trigger

Under Article 36, the duty reaches a foreign AI-service provider through any of three tests: a prior-year revenue floor on the order of KRW 1 trillion, an AI-service-revenue floor of KRW 10 billion — roughly USD 7 million — or a domestic-user measure. The AI-service-revenue figure is the one that changes the picture. A company well under the general revenue floor can still be caught if its AI-service revenue crosses the KRW 10 billion line, which pulls a large part of the mid-market AI sector into scope rather than only the largest platforms.

One point is genuinely unsettled: whether "AI-service revenue" is measured on domestic revenue alone or on a worldwide basis. That distinction can decide whether a given provider sits over or under the line, and it is not yet fully resolved. The sensible time to work it out is before a launch or a year of growth that would push revenue across the threshold, not after.

The designation and notification duty

Where the duty is triggered, the regime requires a qualifying foreign provider to designate a domestic agent and to make that designation known to the regulator. A notification wave is under way as providers work through the requirement, and the maximum administrative penalty for non-compliance is set at up to KRW 30 million, above the game-sector ceiling. The scope of the regime is also under active discussion in the National Assembly, which means the set of providers it reaches may widen rather than settle.

What to check first

  • Measure your AI-service revenue against the KRW 10 billion line, and pin down the basis. Establish whether the figure is assessed on domestic or worldwide revenue before treating yourself as under the threshold, because that answer is not yet settled.
  • Test the domestic-user measure separately. The user-based trigger is independent of revenue. A service can sit under both revenue floors and still be reached through domestic usage.
  • Check whether another domestic-agent duty already applies. A provider that also distributes a game, or that meets the personal-data thresholds, may face a separate duty under a different law. Designating an agent for one regime does not discharge the others, and the same provider may need to satisfy more than one.

The AI regime is early enough that its edges are still moving, which is itself an argument for checking position now rather than waiting for the scope to settle. A provider that establishes where it sits against the KRW 10 billion trigger today will know in advance whether a coming feature or a coming year of growth pulls it into the regime — rather than learning it from a notice.

Munteok provides regulatory information, not legal advice.