A proposed amendment to the AI Framework Act (안 제31조제2항) moved from committee referral to committee review on 8 September 2025. Under current law, any AI business operator must label generative-AI output as AI-generated, with no distinction between the company that builds the underlying model, API, or generation engine and the company that builds the app, platform, or content service on top of it. The amendment would keep the labeling duty but split how it must be satisfied: AI-development operators would label output using a machine-readable method interoperable with international technical standards, while AI-utilizing operators would label output in a way users can clearly recognize. No effective date or penalty figure is set out in the bill text at this stage — it remains under committee review, not in force.

What this means for you

  • Identify which role you occupy, or whether you occupy both. If you provide a model, API, or generation engine to other businesses, you would fall under the developer standard (machine-readable labeling). If you build the end-user app, platform, or content service on top of a generative-AI model, you would fall under the deployer standard (clearly recognizable labeling to users). Companies that both build and ship their own model may need to satisfy both.
  • No action is required yet. This is a bill under committee review, not a law in force — there is no current effective date, and the labeling *duty itself* is not new (it already exists under current law); what would change is the method of compliance.
  • Watch for the machine-readable standard. If enacted as drafted, developer-side compliance would need to align with an international technical standard for machine-readable labeling (e.g., provenance/watermarking metadata) rather than a simple visible tag — this is worth flagging to engineering now if you supply models or APIs into Korea, so implementation isn't scrambled later.
  • Track committee progress. As with other pending amendments, the bill can stall, advance, or be folded into a broader revision. Confirm current status before treating either the current uniform rule or the proposed split as final.

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