The Game Dev's Playbook: Navigating Korea's Mandatory Agent Designation Law

Background of the Designated Domestic Agent System

Foreign game companies have historically been in a regulatory blind spot under South Korea's The Game Industry Promotion Act (GIPA), making it difficult to manage and supervise their compliance with business obligations (such as user protection and disclosure of loot box probability information).

To address this, the GIPA was amended to mandate the designation of a Domestic Agent (DA) for foreign game companies of a certain scale. This agent is tasked with representing the overseas company in fulfilling reporting and game rating display obligations, thereby enhancing user protection and securing regulatory fairness between domestic and foreign operators.

Part 1. Mandatory Domestic Agent Designation: Final Scope and Detailed Analysis

Following the amendment of the GIPA on October 22, 2024, the mandatory designation of a Domestic Agent (GIPA Article 31-2) will be imposed on global game publishers and studios meeting specific criteria, effective October 23, 2025. This regulation is crucial for protecting Korean users and ensuring regulatory equity.

I. Criteria for Mandatory Designation

Global game publishers or studios must satisfy both of the following conditions to be required to designate a Domestic Agent:

1. A game distribution or provision business that does not have an address or place of business in South Korea.

Even if a company's server is abroad and it lacks a registered legal entity in Korea, it may still be subject to the designation obligation if it conducts substantial business activities for Korean users, such as providing services in Korean and accepting domestic payment methods.

2. Satisfies one of the following scale criteria:

**A. Global revenue of KRW 1 Trillion or more in the preceding fiscal year.

The revenue scope is not limited to revenue generated in Korea or game-sector revenue; it is based on the operator's total worldwide revenue.

**B. An entity that distributes or provides a game with an average of 1,000 or more mobile installations per day in the preceding year.

This standard applies exclusively to mobile games and download counts within Korea. It signifies cases where the total number of domestic game downloads in the preceding year, divided by 365 days, is 1,000 or more, irrespective of the game's launch or termination date.

If a single distributor or provider offers multiple games, the numbers are not aggregated across all titles. The 1,000 daily install threshold applies to each individual game title. However, if one game is offered across cross-platforms (PC, mobile, etc.), the user counts from all platforms for that single game are aggregated.

The previously proposed standard of 'MAU of 100,000 or more' is no longer valid. The final enforcement decree defines the target based on the 'daily average new mobile install count of 1,000 or more,' effective October 23, 2025.

**C. Developers directly designated by the regulatory authority (Minister of Culture, Sports and Tourism).

This applies to operators deemed necessary by the Minister of Culture, Sports and Tourism due to an existing or potential incident causing significant harm to game users. This can be preemptively applied in cases of rapidly increasing users where urgent user protection is required.

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II. Roles and Qualifications of the Domestic Agent

The Domestic Agent acts on behalf of the overseas principal to fulfill legal obligations, including reporting to regulatory bodies and disclosing loot box probability information.

Roles and Qualifications of the Domestic Agent

Part 2. Analyzing Business Risks for Non-Designation

Failure to comply with the Domestic Agent designation mandate can result in severe business damage beyond mere fines.

1. Cumulative and Repeated Fines

• Fine: Up to KRW 20 Million imposed under the GIPA for non-compliance.
• Risk: Since the designation obligation is assessed annually based on scale criteria, non-compliance that persists can lead to fines being repeatedly and cumulatively imposed each year.

2. Potential App Market Distribution Suspension

In addition to fines, there is a high probability that major Korean app markets will be directed to suspend distribution (sales stop/deletion) of the non-compliant game following a regulatory corrective order. The Ministry of Culture, Sports and Tourism (MCST) is currently pursuing supplementary legislation to solidify the basis for app market suspension measures.

• Impact: Deletion from app markets means that not only are new installs prevented, but existing users cannot receive updates or monetization becomes impossible. This severely damages the publisher's credibility among Korean users.

Part 3. TheGameAgent's Strengths in Domestic Agent Services

TheGameAgent is more than a legal representative—we are a strategic partner for success in the Korean market, offering unique expertise.

1. Industry Expertise Covering Compliance and Monetization

TheGameAgent's specialization derives from the CEO's decade-long tenure at Google, where they served as the Google Play Policy Lead for Korea, collaborating with domestic regulatory bodies (such as the Game Rating and Administration Committee, GRAC), and subsequently supporting the growth of major domestic and international game developers in the Google Play Partnership team.

TheGameAgent leverages this unique 'Dual Insight' to guarantee your compliance and minimize risk.

2. Proven Track Record: The Choice of Korea's Top Grossing Developers

TheGameAgent currently serves as the Domestic Agent for leading developers ranked highly on the Korean Top Grossing Chart. We provide not only optimized compliance responses but also Local GTM (Go-To-Market) and marketing consulting, actively supporting the business continuity and growth of our clients in the Korean market.

3. Proactive Risk Management

Designation Status Check: We accurately and quickly confirm your company's designation status (typically within 1 business day) and implement optimal response strategies to prevent distribution suspension during the transition period.

Tailored Crisis Management: We proactively establish the best communication and response strategies in anticipation of potential distribution suspension measures, such as MCST data requests or corrective orders, ensuring your business continuity.