For most foreign studios, the answer turns on one number. Korea's Game Industry Act has carried a domestic-agent duty for foreign game companies since 23 October 2025, and it attaches through either of two triggers: prior-year revenue on the order of KRW 1 trillion, or a daily average of 1,000 domestic downloads. The revenue test reaches only the largest publishers. The download test is the operative one — a thousand downloads a day is not a big-company number, and it pulls mid-size and independent studios into scope alongside the platforms. The duty is administered by the Ministry of Culture, Sports and Tourism together with the Game Rating and Administration Committee.

The practical test: localized and charting

Few studios track their Korean daily downloads as a compliance metric, so the useful question is what stands in for that number. The clearest practical tell is chart presence in full localization. A title that runs on the Korean app stores fully translated and appears on the country's game charts typically sits above the 1,000-a-day line — that is roughly what chart position means. If your game is localized into Korean and visible on the Korean charts, the working assumption should be that the duty reaches you, and the analysis shifts to confirming the numbers rather than dismissing the question.

The reverse also holds. A game with no Korean localization and no meaningful Korean install base will usually sit under both triggers, and establishing that cleanly is itself worth doing — the point of a threshold test is that it can rule you out as well as in.

"Not on the first list" and "not obligated" are different things

On 10 July 2026, the ministry closed its first sweep to identify foreign publishers that carry the duty: 81 companies were found obligated, and 80 of those have now designated an agent. It is tempting to read that as the end of the exercise — the list built, the market compliant, the matter settled. The first list is settled. The process behind it is not.

The sweep found companies one way, but enforcement runs on its own track. Corrective orders against foreign publishers have continued to issue by public notice through mid-2026, with the companies left unnamed. A publisher that did not surface in the first identification round can still meet the download test today, and a duty that attaches by threshold does not wait for the next list to be drawn. A publisher with no Korean address, meanwhile, may never see its own notice until the matter is already on the record.

What to do with the answer

  • Measure the trigger honestly. If the title is localized and charting, treat the 1,000-a-day line as likely crossed and verify, rather than assuming the question away.
  • Treat designation as administrative. The duty asks for an agent located in Korea, with a Korean address, authorized to receive official notices and to answer the regulator on your behalf — a filing, not a proceeding.
  • Check the other regimes while you are at it. Korea runs several separate domestic-representative duties with different triggers and different regulators, mapped in our note on the five local-representative laws. Satisfying the game-sector duty does not discharge the others, and the mapping is quickest done once, together.

Munteok provides regulatory information, not legal advice.