Overseas game firms ignoring odds correction orders may face network restrictions

South Korea's National Assembly passed an amendment to the country's Game Industry Promotion Act at its October 1 plenary session, strengthening overseas game companies' obligations to protect users in Korea[1]. Under the amendment, overseas game companies may face orders for the refusal, suspension, or restriction of the use of information and communications networks if they fail to appoint a domestic agent, or violate disclosure requirements for randomized paid items and then fail to comply with a corrective order[1]. The bill is a committee alternative prepared by the National Assembly's Culture, Sports and Tourism Committee, combining amendments separately proposed by Cho Seung-rae of the Democratic Party and Kim Jae-won of the Rebuilding Korea Party. Their original bills were discarded after being folded into the committee alternative on the same day[1][2][3]. The information below is current as of October 5, 2026.

What domestic agents do under the current law

A domestic agent serves as the point of contact with the Korean government and users for an overseas game company that has no address or place of business in Korea. Under the current law, companies in this category that meet certain criteria must appoint a domestic agent in writing. The agent handles government reporting and game labeling obligations on the company's behalf and must have an address or place of business in Korea[4]. The appointed agent's name, address, telephone number and email address must be included in the terms of service[4].

The enforcement decree sets the criteria for companies required to appoint an agent. They include companies with total revenue of KRW 1 trillion or more in the previous year, or companies distributing or providing a game that was installed on mobile devices sold in Korea an average of 1,000 times a day or more in the previous year. Companies asked by the Ministry of Culture, Sports and Tourism to submit a report following an incident that seriously disrupts orderly game distribution are also covered[5]. The domestic agent system took effect in October last year[1].

What the amendment changes

First, game companies' obligations will now include protecting users in Korea from harm and handling their complaints. Domestic agents for overseas game companies will also take on these duties[1][6].

The amendment also specifies whom companies must appoint. According to law firm Yoon & Yang's account of the committee alternative ahead of the plenary vote, the order of priority is as follows. First comes a legal entity established in Korea by the game company. Second comes a Korean legal entity over whose executive composition or business operations the game company exercises dominant influence. Only when neither exists may the company appoint another legal entity capable of diligently performing the agent's duties[6]. This means it will become harder for a company with a Korean subsidiary to appoint a third-party agent merely as a formality. Companies that have already appointed an agent must also select a replacement from these priority entities within six months of the amendment taking effect, if any such entity exists[6].

Game companies will also have greater oversight responsibilities. They must train agents to perform their duties properly, check their work and maintain an agent appointment without interruption while offering games in Korea[6]. The Ministry of Culture, Sports and Tourism and the Game Rating and Administration Committee (GRAC) will be able to require companies to submit materials to check for legal violations[1].

Why the amendment singles out item odds

There is a reason the new sanctions provision specifically mentions randomized paid items. Disclosure of information about these items became mandatory on March 22, 2024[7]. In the third week after the requirement took effect, GRAC requested corrections from nine companies that had not disclosed the information. For overseas game companies without a Korean branch or agent, it had to work with app marketplace operators on follow-up action[8]. The amended law includes restrictions on the use of information and communications networks as a sanction for failing to comply with a corrective order[1]. Yoon & Yang described the provision as a measure that significantly strengthens the ability to regulate overseas operators effectively[6].

Games from overseas companies also appear near the top of Korea's revenue rankings. On October 5, Whiteout Survival ranked 2nd and Kingshot ranked 9th on the Korean App Store's top-grossing games chart. Both are Century Games titles[9]. The company's developer address listed on Google Play is in Singapore[10]. Whether a company like this must appoint a domestic agent depends on whether it has an address or place of business in Korea and whether it meets the enforcement decree's criteria[4][5].

What happens before the law takes effect

The amended law will take effect six months after it goes through a Cabinet meeting and is promulgated[1]. In the meantime, the enforcement decree will establish details such as which legal entities qualify as being under dominant influence and how agents must be trained[6]. If you want to find an overseas game's contact in Korea, you can already look for the domestic agent section in its terms of service. The current law requires the agent's name and contact details to be listed there[4].

Sources

[1] Yonhap News Agency. Stronger user protection duties for overseas game companies approved (in Korean). October 1, 2026.

[2] National Assembly Bill Information System. Bill to partially amend the Game Industry Promotion Act (12 sponsors including Kim Jae-won, Bill No. 2220858) (in Korean). Discarded after being folded into the committee alternative on October 1, 2026. Accessed October 5, 2026.

[3] National Assembly Bill Information System. Bill to partially amend the Game Industry Promotion Act (10 sponsors including Cho Seung-rae, Bill No. 2211759) (in Korean). Discarded after being folded into the committee alternative on October 1, 2026. Accessed October 5, 2026.

[4] Korean Law Information Center. Game Industry Promotion Act, Article 31-2 (Appointment of a domestic agent) (in Korean). Accessed October 5, 2026.

[5] Korean Law Information Center. Enforcement Decree of the Game Industry Promotion Act, Article 18-3 (Scope of companies required to appoint a domestic agent) (in Korean). Accessed October 5, 2026.

[6] Law Times. Game Industry Promotion Act amendment (committee alternative) nears passage in the National Assembly: Will it make the 'domestic agent' system more effective for overseas game companies? (in Korean). Law firm Yoon & Yang, September 28, 2026.

[7] Korea Policy Briefing. Loot-box information disclosure starts on the 22nd... corrective action for violations (in Korean). March 2024.

[8] Electronic Times. 'Loot-box' information disclosure expands to overseas game companies... GRAC requests corrections from 9 noncompliant companies (in Korean). April 9, 2024.

[9] Apple. App Store top-grossing games chart (Korea). Accessed October 5, 2026.

[10] Google. WOS: Whiteout Survival Google Play listing (in Korean). Developer information. Accessed October 5, 2026.