Could Korea Expand Domestic Agent Requirements for Overseas Game Publishers?

South Korea's mandatory Domestic Agent system is facing renewed scrutiny after a parliamentary audit revealed significant gaps in its coverage of overseas game publishers.

During the National Assembly's October 12, 2026 audit of the Game Rating and Administration Committee (GRAC), lawmakers questioned whether the current designation criteria adequately cover overseas publishers with repeated regulatory violations.

Although all 81 overseas game publishers subject to the mandatory designation requirement had appointed Domestic Agents, many other publishers receiving corrective requests remained outside the system.

The findings have prompted discussions about whether Korea should expand its Domestic Agent requirements beyond the existing thresholds.

Parliamentary Audit Reveals Gaps in Domestic Agent Coverage

According to data presented during the audit, 277 overseas game publishers received corrective requests from GRAC over the previous three years.

However, only 40 of those publishers, approximately 14.4%, were included in the mandatory Domestic Agent designation list.

This means that approximately 85.6% of overseas publishers that received corrective requests were not subject to the designation requirement.

The findings raised concerns that the current eligibility criteria may exclude publishers with repeated compliance issues, even when their games are actively distributed in Korea.

Lawmakers emphasized that a high designation compliance rate among eligible publishers does not necessarily mean the regulatory framework covers all publishers requiring oversight.

Why Are Some Overseas Publishers Excluded?

Under the current framework, overseas game publishers without a Korean address or business establishment are required to appoint a Domestic Agent when they meet specified statutory and regulatory thresholds.

These include annual revenue and the average daily number of domestic installations for each individual game. 

One concern raised during the audit was that the installation threshold is assessed at the individual game level rather than across a publisher's entire portfolio.

As a result, a publisher operating multiple smaller games may fall outside the designation requirement even if its combined user base is substantial.

The audit also highlighted cases involving publishers that had received repeated corrective requests across multiple games despite not meeting the existing designation thresholds.

These examples suggest that publisher size alone may not fully reflect the level of regulatory attention required.

Could Repeated Violations Become a New Designation Criterion?

During the audit, lawmaker Kim Jae-won proposed considering additional Domestic Agent designation requirements for overseas publishers that repeatedly receive corrective requests, even when they do not meet the existing thresholds.

GRAC Chairman Seo Tae-geon acknowledged the concern and indicated that the committee would discuss possible measures with the Ministry of Culture, Sports and Tourism.

However, no new designation criterion based on repeated violations had been formally adopted as of October 13, 2026.

The discussion represents a potential direction for future regulatory reform, rather than an immediate change to the legal obligations of overseas game publishers.

What Does This Mean for Overseas Game Publishers?

The parliamentary discussion is particularly relevant to overseas publishers operating multiple games in Korea or managing compliance issues across different titles.

Even publishers that currently fall below the mandatory Domestic Agent thresholds may benefit from reviewing their Korean regulatory exposure.

Key considerations include:

• Reviewing designation eligibility: Assess whether current revenue and installation figures meet the applicable Domestic Agent thresholds.
• Monitoring corrective requests: Maintain records of regulatory inquiries, corrective requests, and compliance actions across all games distributed in Korea.
• Strengthening regulatory communication: Establish clear internal procedures for responding to Korean authorities, particularly where multiple titles are involved.
• Tracking potential regulatory changes: Monitor whether discussions about repeated violations lead to proposed amendments or changes to the implementing regulations.

These steps can help publishers prepare for possible changes without assuming that expanded designation requirements are already in force.

A Potential Shift Toward Broader Regulatory Coverage

The October 12 parliamentary audit highlights a distinction between compliance with the existing Domestic Agent designation rules and the overall effectiveness of Korea's regulatory oversight.

While the current system has achieved full designation compliance among the identified obligated publishers, lawmakers are questioning whether its eligibility criteria are sufficiently broad.

For overseas game publishers, the key development to watch is whether repeated compliance issues or broader portfolio-level activity become factors in future Domestic Agent designation requirements.

Any expansion would require further legal or regulatory action. Until then, publishers should continue complying with the existing rules while monitoring developments that could affect their eligibility.

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