YOON&YANG

The amendment to the Enforcement Decree of the Game Industry Promotion Act, which sets the criteria for companies required to appoint a domestic agent, was finally approved at the Cabinet meeting on October 14, 2025. Based on these criteria, the system mandating overseas game companies to designate a domestic agent will be implemented starting October 23, 2025. Although somewhat delayed, the government’s official guideline was also distributed on the same day. Now, approximately 100 overseas game companies must send a “Certificate of Domestic Agent Designation” to the Game Rating and Administration Committee using the form provided in the guideline.

1. Amendments to the Game Industry Act Enforcement Decree Approved at Cabinet Meeting on October 14

2. Criteria: KRW 1 Trillion Global Revenue or 1,000 Average Daily Downloads; Government Officially Issues Explanatory Guideline

3. Companies that Meet the Criteria Must Designate a Domestic Agent and Notify the Game Rating and Administration Committee from October 23, 2025

4. Implications

1. Amendments to the Game Industry Act Enforcement Decree Approved at Cabinet Meeting on October 14

The Ministry of Culture, Sports and Tourism announced that the amendment to the Enforcement Decree of the Game Industry Promotion Act, which mandates the appointment of a domestic agent by overseas game companies, has been approved at the Cabinet meeting held on October 14, 2025. This amended decree will take effect starting from October 23, just about a week later. The draft of this amended decree was previously announced at the end of July 2025.

2. Criteria: KRW 1 Trillion Global Revenue or 1,000 Average Daily Downloads; Government Officially Issues Explanatory Guideline

Under the new regulation, any overseas game companies whose annual global revenue exceeds KRW 1 trillion (approximately USD 700 million) or whose games have been installed on Korean users' mobile devices an average of more than 1,000 times per day in the previous year is required to designate an individual or corporation with an address or place of business in Korea as their domestic agent. Violation of this requirement may result in an administrative fine of up to KRW 20 million. The Ministry of Culture, Sports and Tourism released a press statement along with the Guideline to Designation of Domestic Agents for Overseas Game Companies (attached to this newsletter, the “Guideline”).

3. Companies that Meet the Criteria Must Designate a Domestic Agent and Notify the Game Rating and Administration Committee from October 23, 2025

The Guideline explains that companies subject to this obligation of designating a domestic agent are required to send a “Certificate of Designation” to the Game Rating and Administration Committee (a sample of the said form is provided on page 14 of the Guideline). As a follow up, the Game Rating and Administration Committee will soon be sending official letters to companies meeting the threshold criteria, to (i) inquire whether they have designated a domestic agent, and (ii) request for the name, address, and contact information of the domestic agent.

4. Implications

As observed in other legislations such as the Personal Information Protection Act and the Telecommunications Business Act which require designation of a local representative, the so-called “domestic agent system” is being utilized as a regulatory mechanism to protect Korean nationals. Therefore, it is advantageous for companies subject to this obligation to designate, as their domestic agent, a large and leading law firm capable of providing competent and comprehensive legal services to ensure compliance and respond effectively to the upcoming changes.

Yoon&Yang Game Center consists of professionals and experts with rich practical experience in relevant bodies, specializing in the game industry. We proactively monitor issues and are ready to respond quickly to all legal matters regarding the game sector. For inquiries, please contact us at any time.