Game Industry Promotion Act

Game Industry Domestic Representative in South Korea

Since 23 October 2025, certain foreign game distributors and game providers without a Korean address or place of business must designate a Korean domestic representative in writing for specified regulatory reporting and game-information display duties.

Requirement in force Effective since 23 October 2025 Ministry of Culture, Sports and Tourism (MCST) and Game Rating and Administration Committee (GRAC)

Who may be affected?

Foreign game distributors and providers meeting a statutory trigger

Applicability depends on three questions: whether the foreign company conducts a game distribution or game-providing business in Korea, whether it lacks an address or place of business in Korea, and whether it meets at least one threshold prescribed by the Enforcement Decree.

Common business profiles

  • Foreign mobile-game publishers and operators serving Korean users
  • PC, online and console game publishers supplying or operating games in Korea
  • Foreign copyright owners, licensors and distributors supplying games for Korean release
  • Game providers offering probability-based items to Korean users

What do “game distribution” and “game-providing” mean?

These are statutory business classifications. They depend on the company’s actual role in supplying or making a game available, not only on whether the company describes itself as a developer, publisher, platform or app business.

  • Game distribution business: Generally, a business that imports a game, including a master copy, or owns or manages the game’s copyright and supplies the game to a game-providing business or another party for distribution or use.
  • Game-providing business: Generally, a business that makes a game available so that members of the public can use or play it. This can include an online or network-based operator directly providing a game to Korean users.

Not every developer, store or platform is covered

A company that only develops a game but does not distribute or provide it may fall outside these classifications. MCST guidance also distinguishes a general open online marketplace that merely enables third-party transactions from a business that directly imports, supplies or provides games. Hybrid business models should be reviewed according to the company’s role for each title and platform.

Preliminary applicability checklist

  • The foreign company conducts a game distribution business or game-providing business directed at the Korean market or Korean users.
  • The company itself has no address or place of business in Korea.
  • Its total revenue for the previous business year was at least KRW 1 trillion.
  • Alternatively, it distributed or provided at least one game that recorded an average of at least 1,000 installations per day during the previous year on mobile telecommunications devices sold in Korea.
  • Alternatively, MCST ordered the company to submit a report under Article 31(2) because an incident significantly harming the orderly distribution of games occurred or was considered likely to occur.
  • Only one of the three threshold triggers is required, but the business-classification and absence-of-Korean-presence conditions must also be satisfied.

Important threshold details

The revenue test refers to worldwide total revenue for the preceding business year, not only Korean revenue or game-business revenue. Foreign-currency revenue is converted into Korean won using the preceding year’s average exchange rate. For the mobile-installation test, only Korean downloads are counted; downloads of the same game across multiple app marketplaces are combined, and the previous year’s total downloads are divided by 365 regardless of the game’s launch or termination date. The presence of probability-based items is not itself a domestic-representative threshold.

Korean presence and representative eligibility

The appointed representative must have an address or place of business in Korea. The current Article 31-2 does not expressly require appointment of an affiliated Korean company merely because one exists. However, the activities of a Korean branch, office, affiliate or other local operation may affect whether the foreign company itself is considered to have a Korean place of business and should be reviewed before appointment.

Administrative fine

A qualifying foreign game business that fails to designate a domestic representative may be subject to an administrative fine of up to KRW 20 million. Separate enforcement consequences may apply to failures involving required reports or game-information displays.

Objective scope matrix

Separate the representative role from the game company’s retained responsibility

Article 31-2 assigns two categories of statutory functions to the domestic representative. The precise service scope, approval route and exclusions are confirmed in the signed engagement.

01 · Statutory functions

Functions assigned by Article 31-2

  • Perform reports required under Article 31(2) of the Game Industry Promotion Act.
  • Perform the game-information display duties under Article 33 that apply to the company and its games.
  • Maintain an effective means of communication with the appointing foreign company.
  • Have the representative’s required identity and contact information stated in the company’s applicable terms and conditions.

02 · Proposed Korea Agent Direct scope

Korean representative coordination

  • Act as the formally designated domestic representative after eligibility and scope confirmation.
  • Maintain approved Korean address, telephone and email contact information.
  • Coordinate Article 31(2) reports using information and evidence supplied and approved by the client.
  • Coordinate applicable Article 33 display information, including client-approved probability-item information where relevant.
  • Receive covered MCST or GRAC communications, track deadlines and maintain an activity record.

03 · Optional support

Separate approved scope

  • Readiness review of Korean terms, game pages and required display locations.
  • Bilingual administrative coordination for probability-item disclosures or a defined authority inquiry.
  • Coordination with independent Korean gaming counsel, rating specialists or technical advisers.

04 · Foreign company

Client-retained responsibilities

  • Develop, classify, rate, distribute and operate the game and its related services.
  • Calculate, validate and technically implement probability rates and item mechanics.
  • Ensure the legal and factual accuracy of game, rating, content and probability-item information.
  • Prepare complete substantive reports and supporting evidence and approve all submissions.
  • Make gameplay, account, refund, remedy, policy and risk-management decisions.

What may fall within Article 33 display duties?

The applicable display requirements depend on the company’s role, the type of game and how the game is distributed or provided in Korea. They may include the business operator’s name, the game rating and game-content information. For games containing probability-based items, separate rules may require the item types and supply probabilities to be displayed in prescribed locations, including within the game and on relevant websites, advertisements or promotional materials. Certain designated game products may also be subject to operational-information display requirements. The foreign company remains responsible for identifying the requirements applicable to each game and for the accuracy and technical implementation of all displayed information.

Appointment and operation

Written designation, terms disclosure and active communication

The appointment must be made in writing. The foreign company’s applicable terms and conditions must state the representative’s required identity and contact details, and the representative must maintain an effective means of communication with the company.

Typical process

  1. Classify the foreign company’s role for each game, platform and Korean distribution channel.
  2. Review Korean presence and test the revenue, mobile-installation and MCST-order triggers.
  3. Map applicable Article 31 reporting and Article 33 display duties for the relevant games.
  4. Complete due diligence, execute the service agreement and written representative designation, and establish the approval matrix.
  5. Update the applicable terms with the representative’s name, address or place of business, telephone number and email address.
  6. Notify GRAC of the appointment and later changes in accordance with MCST’s official operational guidance, and activate communication, deadline and record-management procedures.

GRAC notification

Article 31-2 expressly requires written designation and disclosure of representative details in the applicable terms. MCST’s official guide additionally recommends notifying GRAC without delay when a representative is newly designated or redesignated, or when the representative’s address, telephone number or email changes.

Information normally requested after initial contact

  • Certificate of incorporation, registry extract and authorized-signatory evidence
  • Description of the company’s development, publishing, licensing, distribution and operating roles
  • List of games, Korean platforms, stores, websites and applications
  • Previous-business-year total revenue and supporting calculation information
  • Previous-year Korean mobile-installation data by relevant game
  • Information about Korean branches, offices, affiliates, personnel and operational activities
  • Game ratings, game-content displays, probability-item information and current Korean terms
  • MCST or GRAC correspondence and internal legal, compliance and technical escalation contacts

No document upload at inquiry stage

Do not send corporate records, credentials, identity documents, authority evidence, unpublished game data or personal information through the public form. A separately approved secure exchange method is arranged after initial contact.

Applicable law and official sources

Game Industry Promotion Act

Relevant provisions: Articles 2, 31, 31-2, 33 and 48; Enforcement Decree Articles 18-3 and 23

Authority: Ministry of Culture, Sports and Tourism (MCST); GRAC performs designated administrative and compliance-verification functions

Frequently asked questions

Practical applicability questions

Does every foreign game publisher serving Korea need a domestic representative?

No. The foreign company must conduct a game distribution or game-providing business, lack its own Korean address or place of business, and meet at least one of the three Enforcement Decree triggers.

Is the KRW 1 trillion test based only on Korean game revenue?

No. The decree and MCST guidance refer to worldwide total revenue for the previous business year. The calculation is not limited to revenue earned in Korea or revenue from the game business. Foreign-currency amounts are converted using the preceding year’s average exchange rate.

How is the 1,000 average daily mobile-installation test calculated?

MCST guidance counts Korean downloads of the same game across all app marketplaces during the previous calendar year, combines those downloads, and divides the total by 365. The calculation applies regardless of when during that year the game was launched or discontinued.

Can a PC or console game company be covered?

Yes. The mobile-installation trigger is specific to installations on mobile telecommunications devices sold in Korea, but a PC, online or console game business may still be covered through the total-revenue trigger or an MCST reporting-order trigger.

Do probability-based items automatically trigger the representative requirement?

No. Probability-based items can create important Article 33 display duties, but their presence is not one of the three domestic-representative thresholds.

Is an app store or open marketplace automatically a game distributor?

No. MCST guidance distinguishes a general open marketplace that merely enables third-party transactions from a business that directly imports, owns or manages rights to, supplies or provides games. The platform’s actual contractual and operational role must be reviewed.

Does the appointment make Korea Agent Direct responsible for refunds or gameplay decisions?

No. Article 31-2 assigns reporting and display functions. Ordinary compensation, refund, account, gameplay and customer-service decisions remain with the foreign company unless a separate written service scope expressly provides otherwise.

Will Korea Agent Direct calculate or verify probability rates?

No. The publisher or provider remains responsible for the calculation, accuracy and technical implementation of probability rates. Korea Agent Direct may coordinate the display of client-supplied and client-approved information within the agreed representative scope.

Preliminary review

Discuss Game Industry representative requirements

Share basic company information. Agent Direct will use it for a preliminary non-legal screening and to discuss an appropriate next step.

Do not send sensitive material.

Do not submit credentials, identity documents, breach details, personal-data requests, confidential evidence or files through this form.

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Additional context

Submitting an inquiry does not create an appointment, legal assessment or attorney-client relationship.

Related representative services

One company may face more than one Korean representative regime