Publishing a game in South Korea as a foreign company

The Korean market and why the rules matter

Korea’s game market was worth KRW 23.85 trillion in 2024 according to the 2025 Korea Game White Paper, up 3.9% on the year, with mobile at 59%, PC at about a quarter and console at 5%. It is the fourth-largest market in the world, with 7.2% of the global total, and Korean players are among the highest spenders per head on mobile and PC titles. Foreign games — Chinese mobile titles above all, but also American, Japanese and European ones — take a large and growing share of the top-grossing charts.

The rules governing them sit mainly in the Game Industry Promotion Act, administered by the Ministry of Culture, Sports and Tourism and the Game Rating and Administration Committee (게임물관리위원회, geimmul gwalli wiwonhoe) (GRAC), with the Korea Fair Trade Commission enforcing consumer law and the communications regulator dealing with app-store payment rules. Korean regulation of games has swung from heavy — the 2011 shutdown law barring young teenagers from online games at night — to targeted: the shutdown law was abolished from 1 January 2022, and the focus since then has been transparency of paid random items and reachability of foreign publishers.

Rating: the only gate before launch

Korea has no approval of the kind China requires for a game to be published; the gate is an age rating (등급분류, deunggeup bullyu). Every game product must be rated before it is distributed or offered to the Korean public, in one of four classes: all ages, 12 and over, 15 and over, and adults only (not for youth (청소년이용불가, cheongsonyeon iyong bulga)). The criteria are sexual content, violence, crime and drugs, language and gambling-like features. Adults-only games must be rated by GRAC itself; for the rest, rating has largely been delegated.

Most games are rated by self-rating operators (자체등급분류사업자, jache deunggeup bullyu saeopja) designated by the Ministry — Google, Apple, Epic, ONEstore, Microsoft, Smilegate and others — through the age-rating questionnaires in their developer consoles; Google Play and ONEstore use the international IARC system, in which GRAC participates. In 2025, of about two million games rated, 99.9% went through eleven self-rating operators and private agencies, with Epic’s user-generated content alone accounting for over half. A second phase of moving mobile and simple-game rating to private bodies is due in November 2026. For a mobile game on Google Play or the App Store, the store questionnaire is therefore the Korean rating; for a PC game sold on a storefront that is not a designated operator, or a console title on a platform without self-rating status, the publisher applies to GRAC.

A GRAC review typically takes ten to fifteen days. Fees depend on the platform and are adjusted by coefficients for network play, genre and Korean localisation; GRAC publishes a fee simulator. Changes to the content of a game GRAC has rated must be reported in advance or within 24 hours, except for minor changes, and a change that would alter the rating requires a new one. Distributing an unrated game, or a game with content different from what was rated, is a criminal offence punishable by up to five years’ imprisonment or a KRW 50 million fine, and GRAC can order removal and block distribution.

Check whether your storefront is a designated self-rating operator before launch; the list changes.

GRAC monitors self-rated games after release: it checked about 120,000 in 2025 and took nearly 7,000 actions, from rating corrections to removal, although its monitoring budget and staff were cut sharply for 2026. Foreign games that switch content after rating — adding gambling-like features in a later update, for instance — are a recurring enforcement target.

The domestic agent rule

Foreign publishers without a Korean office were hard to reach when Korean users complained about vanished items, sudden shutdowns or misleading probabilities. An amendment to the Act passed in September 2024 and in force from 23 October 2025 requires a foreign game company with no address or place of business in Korea to appoint a domestic agent (국내대리인, gungnae daeriin) if it meets any one of three tests: worldwide sales of KRW 1 trillion or more in the previous year; an average of 1,000 or more new mobile installs per day in Korea in the previous year; or a request from the Minister after an incident that seriously harms users. The install test, adopted in the final decree in place of a draft monthly-user test, is the one that catches mid-sized mobile publishers.

The appointment must be in writing, the agent’s name, address, phone number and email must appear in the game’s terms of service, and GRAC must be notified of the appointment and of any change. The agent handles reporting requests from the Ministry and local governments and compliance with the rating and probability disclosure rules, must be able to communicate in Korean, and its violations are attributed to the foreign company. Failure to appoint carries an administrative fine of up to KRW 20 million, which can be imposed again each year the obligation applies. By July 2026, 80 of the 81 companies identified as obliged had appointed agents, and two dozen more had done so voluntarily.

A domestic agent is not a publisher. A foreign studio that wants to market, run events, manage a Korean community, contract with Korean influencers and payment providers, and hold Korean trademarks and a business registration usually sets up a Korean subsidiary or partners with a Korean publisher; either removes the agent obligation because the company then has a Korean place of business. See registering a Korean company and permanent establishment risk for the tax side of running a Korean team.

Paid random items: disclosure

Korea was the first major market to make probability disclosure for probability-based items (확률형 아이템, hwangnyulhyeong aitem) a statutory duty, in force since March 2024 under the Act and its Enforcement Decree, with a Ministry guideline published in February 2024. It covers paid items whose result is random, in three types: capsule items (loot boxes and gacha pulls), enhancement items that raise an item’s level with a chance of failure, and combination items that merge items into a random result. Items obtained only for free are outside the rule, but an item obtained partly with paid currency is inside it.

The disclosure must give the probability of each possible outcome, by type, grade and performance; the total quantity or availability period for limited boxes; any mechanics that vary the probability; the conditions and probabilities of pity systems, both when the pity condition applies and when it does not; and advance notice of probability changes. It must appear on the purchase and use screens in the game, on a website the user can search without logging in, and in advertising — ads must state that the game contains probability-based items, and a notice in a video ad should stay on screen for at least three seconds. Everything must be in Korean.

• Enforcement under the Act: GRAC monitors disclosures and issues corrective orders — 22 in 2025 and 31 by August 2026; failure to comply with an order is punishable by up to two years’ imprisonment or a KRW 20 million fine.
• Consumer law: the KFTC fined Nexon KRW 11.6 billion in January 2024 under the E-Commerce Consumer Protection Act for misleading users about the probabilities of MapleStory’s enhancement cubes and items in Bubble Fighter; Nexon’s appeal is pending.
• Victim relief: GRAC opened a victim relief centre in February 2026 that mediates user claims, including against foreign games.
• Revenue-based surcharges: a bill for surcharges of up to 3% of revenue or KRW 1 billion was under committee review in 2026 and had not passed.

Punitive damages and the burden of proof

An amendment passed on 31 December 2024 and in force since 1 August 2025 added a damages provision to the Act. Where a game company intentionally or negligently fails to disclose probabilities or discloses them falsely, users can recover up to three times the damage they suffered, and the burden of proof is reversed: the company must prove it was neither intentional nor negligent. Class-style claims by groups of users are realistic in Korea, where player communities organise quickly and lawyers advertise for claimants after each disclosure scandal. For a foreign publisher, the practical consequences are that probability tables must be generated from the live server configuration rather than maintained by hand, that every change needs a logged release process, and that Korean users must be told in advance.

Gambling, cash-out and play-to-earn

The Act prohibits games that produce gambling-like results and the business of exchanging game results or items for cash; violations are punishable by up to five years’ imprisonment or a KRW 50 million fine. In practice this means no mechanic that lets players convert in-game winnings into money, and caution with trading systems that facilitate real-money markets. Play-to-earn games that reward players with tradeable crypto tokens are refused a rating by GRAC, and the Seoul Administrative Court upheld that approach in January 2023 in a case involving a Klaytn-based title, so blockchain games are launched in Korea, if at all, with the earning functions switched off. See crypto rules in Korea for the wider regime.

Minors are protected less by curfews than by choice: the shutdown law was replaced by an opt-in game-time selection system under which under-18s or their guardians can limit playing hours, and games for adults require age verification. Korean data protection law requires parental consent for collecting personal data of children under 14.

Payments, VAT and withholding

Most foreign mobile games sell through Google Play and the App Store, which collect payment and — for in-app sales to Korean consumers — account for Korean VAT as the marketplace. The 2021 amendment to the Telecommunications Business Act prohibits app stores from forcing developers to use the store’s own billing, and allows third-party payment within apps; enforcement against Google and Apple was still not final in 2026, with proposed fines of about KRW 63 billion and refund mediation with some 300 game companies under way.

A foreign publisher that sells directly to Korean consumers — web shops for in-game currency, PC launchers, its own payment system — must register for VAT under the simplified regime for foreign suppliers of electronic services and file and pay 10% VAT quarterly; a penalty of 1% has applied since 2024 for failure to register on time. See digital services VAT. Payments by Korean publishers to a foreign developer under a licence are royalties subject to Korean withholding at 22% including local tax, reduced by most treaties to 10% to 15% if the forms are filed before payment; see treaty rates.

Refunds, shutdowns and Korean terms

Korean consumer law gives buyers of digital content a seven-day right of withdrawal under the E-Commerce Consumer Protection Act, limited where use of the content has begun and the seller disclosed that clearly before purchase. Unused paid currency is generally refundable, and the KFTC’s standard terms for online and mobile games — which Korean publishers follow and against which foreign terms are judged — expect advance notice before a service ends, refunds of unused paid items on shutdown, and no unilateral changes to the terms that disadvantage players without notice. Terms written for the United States or Europe and translated into Korean regularly contain clauses the KFTC considers unfair: blanket exclusion of refunds, liability exclusions for the company’s own fault, and a foreign court as the only forum for Korean consumers. See consumer protection law and digital subscriptions.

Korean players also expect things the law does not strictly require: patch notes and probability changes posted in Korean on the day, a Korean community manager on Naver Cafe or Discord, compensation packages after outages, and quick answers to coordinated complaints. Publishers that treat Korea as one more translation often find that a single mishandled update — a nerfed character, a silent rate change — turns into a truck protest outside their partner’s office, a Korean ritual that has followed several disclosure scandals. Localisation budgets should include people, not only text.

Publishing models compared

The choice turns on how much Korean live operation the game needs.

Korean publishers bring marketing, PC café distribution, community management and relationships with Kakao and Naver; they also take a large share of revenue and control of the player relationship. A Korean subsidiary costs more to set up and run but keeps the community and data in the group. A licence agreement should allocate rating, probability disclosure, refund and shutdown obligations explicitly, with an indemnity for regulatory fines and damages claims — after August 2025, those are not theoretical.

A worked example

A Polish studio’s mobile RPG reaches the Korean top 50 in its first year, averaging 2,500 new Korean installs a day, with gacha pulls for characters and an enhancement system for weapons. Its Korean revenue runs through Google Play and the App Store, which collect VAT. On 1 January of the second year it meets the domestic agent install test; it appoints a Seoul law firm as agent, adds the agent’s details to the Korean terms of service and notifies GRAC.

A Korean player community finds that one character’s pity counter resets on a server change, contrary to the published rules. The studio fixes the bug, but GRAC issues a corrective order and players file claims at the victim relief centre. Under the 2025 damages rule the studio must show the error was not negligent; its release logs, automated probability exports and advance notices are the evidence. It settles by refunding affected pulls in premium currency and publishes a Korean-language explanation, and the following year sets up a small Korean subsidiary to run community management and live operations.

Mistakes we see

1. Launching on a storefront that is not a self-rating operator without a GRAC rating.
2. Updating content after rating in ways that change the rating, without reporting it.
3. Probability tables maintained by hand, drifting from the server configuration.
4. Pity mechanics disclosed without both probabilities — with and without the pity condition.
5. Ads without the probability-item notice.
6. Missing the install threshold for the domestic agent at the start of the year.
7. Direct web-shop sales without VAT registration.
8. Licence agreements silent on regulatory fines and damages claims.

Korean terms you will meet

Questions readers ask

About the author

Alexander Baranov

Founder of the BCA Group · cross-border corporate and tax adviser since 2008

Alexander advises foreign founders and groups on company formation, tax structuring and corporate law in more than 40 jurisdictions across Europe, the Gulf, Asia and Latin America. He is the author of nine books on international business and tax and writes regularly for professional finance and tax journals. He works in English, German, Spanish and Russian.

This guide is based on the Korean statutes cited in the text and on our own filings. It is reviewed when the law or official rates change.

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