Korea has spent the last several years adding "domestic agent" and "domestic representative" duties to law after law. There is now no single obligation to point at and no single filing that discharges them. A foreign company can sit comfortably under one regime while being squarely caught by another, and the effective dates, thresholds, regulators, and penalties differ in every case. For a company entering the Korean market, the hardest part is often not meeting any one duty but working out which ones apply at all.

Five regimes, five sets of rules

At least five separate laws now impose a local-representative or local-agent duty, each administered by a different regulator:

  • Personal Information Protection Act. The domestic-representative duty under Article 31-2 was strengthened by an amendment in force on 2 October 2025. It reaches operators over a prior-year revenue level on the order of KRW 1 trillion, or roughly one million daily domestic data subjects over the preceding three months, and it can also attach on demand when the Personal Information Protection Commission issues a data-submission request.
  • Telecommunications Business Act. The Article 22-8 representative duty has been in force since June 2019, but its threshold is set so high that only two global platform operators have ever been designated, and field enforcement has been effectively dormant.
  • Game Industry Act. The domestic-agent duty took effect on 23 October 2025. It is triggered at either KRW 1 trillion in revenue or a daily average of 1,000 domestic downloads, and it is administered by the Ministry of Culture, Sports and Tourism together with the Game Rating and Administration Committee.
  • AI Framework Act. The Article 36 domestic-agent duty came into force on 22 January 2026, administered by the Ministry of Science and ICT. It reaches foreign AI-service providers over a revenue floor, an AI-service-revenue floor of KRW 10 billion, or a domestic-user measure.
  • E-Commerce Act. A domestic-agent duty is drafted and sits at the enforcement-decree stage of the legislative process, not yet in force. The contemplated thresholds are a KRW 1 trillion revenue level or roughly one million monthly domestic consumers, with the Fair Trade Commission as the regulator.

Why the confusion is the real problem

Set these side by side and the pattern is clear. The thresholds are not aligned, the triggering metric shifts from revenue to downloads to data subjects to AI-service revenue, and the penalties range from a modest administrative ceiling to newly created fines. Two of the regimes are calibrated for the very largest operators. One — the game duty — reaches down to mid-size and even independent studios through its 1,000-downloads-a-day test. One — the AI regime — is new enough that its scope is still being settled.

The practical consequence is that a company can believe it is compliant because it satisfied the regime it happened to hear about, while a second duty with a lower trigger has quietly attached. This is not a temporary state that will resolve as the regimes mature. It is a standing feature of a landscape assembled law by law rather than by design, and it puts the burden of interpretation on the company that can least afford to guess.

Mapping which duties reach a specific operating profile — and, just as important, which comfortably do not — is the first and most under-done step of a Korea market entry. Done early, it turns a diffuse anxiety about "Korean regulation" into a short, ordered list of what applies, what is close, and what can be set aside until the numbers move.

Munteok provides regulatory information, not legal advice.