South Korea’s Ministry of Culture, Sports and Tourism and the Game Rating and Administration Committee (GRAC) have released the country’s first official compliance roster under a landmark foreign-game-publisher mandate — naming 81 international companies required to field a locally based Korean representative. Of those 81, eighty had met the designation deadline as of the roster’s publication. The one holdout is now in a pre-penalty review process that could result in an administrative fine. (Exchange rate as of July 28, 2026; all KRW conversions in this article are approximate.)

The roster itself spans virtually the entire tier-one global games industry, from Nintendo, Roblox, and Epic Games on the Western side, to MiHoYo (Genshin Impact, Honkai: Star Rail) and NetEase among eleven Chinese publishers named. But the more telling number came from the GRAC July 10 briefing held for affected companies: of 103 entities with designated representatives serving 1,205 monitored games, the committee found that 40 percent of games containing randomized items showed partial non-disclosure of the required probability figures and 14 percent showed complete non-disclosure. Getting a representative on paper, it turns out, is easier than getting them to fix the actual compliance problem the mandate was designed to solve.

Designating an agent and enforcing the law the agent was created to follow are not the same thing — and in South Korea’s world-leading loot box regulatory regime, the gap between those two things is now documented and on the record.

Who Made the List

The 81 companies span casual mobile, console, AAA retail, and massively multiplayer categories across five continents. Western publishers include Epic Games, Take-Two Interactive, Electronic Arts (operating through EA Switzerland), 2K Games, Ubisoft Entertainment, Warner Bros. Games, Capcom, Konami Digital Entertainment, Bandai Namco Entertainment, Niantic, Playtika, King.com, Scopely, Zynga, Garena (Sea Group), Sony Interactive Entertainment, Square Enix, Innersloth (Among Us), PONOS (The Battle Cats), and Roblox Corporation.

Eleven of the 81 companies are headquartered in mainland China or Hong Kong: MiHoYo, NetEase, Kuro Games (Wuthering Waves), Bilibili’s Hong Kong subsidiary, ByteDance’s game label Nuverse (朝夕光年), Century Games unit Tap4Fun (point4fun, publisher of White Out Survival and King Shot), IGG, Haoplay, Youzu (affiliated with Pearl Abyss partner), Dewdrop Games (SP Games), and TapTap parent XD Network. Tencent itself was not included because it operates a Korean subsidiary directly; however, Tencent’s Finnish studio Supercell — maker of Clash of Clans and Brawl Stars — appeared on the roster as a standalone publisher.

An additional 24 foreign game companies that did not technically meet the mandatory thresholds have voluntarily registered representatives, according to Newsway, which first reported the full roster.

The Law Behind the List: Game Industry Promotion Act Article 31-2

The designation obligation derives from Article 31-2 of the Game Industry Promotion Act (GIPA), which the South Korean National Assembly amended on September 22, 2024, per Shin & Kim analysis. The provision took effect October 23, 2025, following a 12-month implementation window during which the Ministry of Culture, Sports and Tourism issued enforcement-decree details, accepted public comments, and revised the threshold criteria.

A foreign game company triggers the obligation if it lacks a domestic Korean address or place of business and meets either of two criteria, per enforcement decree details:

An annual global revenue exceeding ₩1 trillion (approximately $683 million USD at the July 28, 2026 mid-market rate of ₩1,465 per dollar) in the prior year. Or an average of 1,000 or more new daily installs in Korea over the prior year. The daily-install threshold replaced an earlier standard — averaging 100,000 monthly Korean users — after domestic game companies argued the original threshold was too narrow to cover meaningful numbers of foreign operators. The revised metric was expected to bring approximately 90 to 96 companies within scope, up from an estimated 60 under the earlier standard, as Korea Herald reported.

Google Play and Apple App Store operators are explicitly exempt.

The designated representative must maintain a physical Korean address (not a P.O. box), be capable of conducting business in Korean, and serve as the actual contact point for GRAC regulatory queries about probability disclosures for randomized item systems, advertising compliance, and reporting obligations. Regulators warned at the July 10 briefing that representatives who respond only via automated email replies or online forms will be considered non-compliant, per the GRAC compliance notice.

What “One Still Non-Compliant” Actually Means

South Korea’s existing penalty structure explains why one holdout company can remain in the system rather than simply stopping operations. Under current GIPA rules, a company that fails to designate a representative faces an administrative fine of up to ₩20 million (approximately $13,652 USD) — a figure widely acknowledged as insufficient deterrence for a major publisher, per Inven Global analysis. The fine can be imposed repeatedly until designation occurs, but the economic calculus is straightforward: a multi-billion-dollar publisher can absorb repeated ₩20 million fines without meaningful incentive to comply.

That calculation is set to change. Lawmaker Kim Seong-hoe of the Democratic Party of Korea introduced a bill in September 2025 that would raise the ceiling for gacha disclosure violations to the lower of 3 percent of annual sales or ₩1 billion (approximately $683,000 USD) — imposed immediately upon detection, with no corrective-request grace period. Separately, lawmaker Jo Seung-rae has proposed granting regulators the power to suspend game distribution for persistently non-compliant publishers, which would convert a fine question into a market-access question.

Both bills remain in the National Assembly’s legislative queue, with no confirmed vote date.

The Disclosure Quality Problem the Roster Doesn’t Solve

Designation compliance at 99 percent looks like regulatory success. The July 10 briefing data tells a different story about what happens downstream of designation.

GRAC reported that a review of 103 entities with representatives — covering 1,205 games — found that games containing randomized items failed full disclosure requirements at troubling rates: 40 percent showed partial non-disclosure of probability figures and 14 percent showed complete non-disclosure, according to GRAC briefing data. In plain terms: roughly half the covered games with loot box-equivalent mechanics are still not properly disclosing the odds players face when they spend real money.

South Korea’s loot box probability disclosure regime, effective March 22, 2024, is independently assessed as the most rigorously enforced in any major gaming market. A 2025 Xiao and Park study published in Acta Psychologica by Leon Xiao and Solip Park found that South Korea’s actively enforced disclosure law produced demonstrably better compliance outcomes than industry self-regulation in other markets. GRAC deployed 27 dedicated monitoring personnel — more than a quarter of its 99-person workforce — to conduct real-time surveillance of loot box mechanics across covered games since August 2025, per Korea Game Desk reporting.

The GRAC head made the enforcement expectation explicit at the July 10 briefing: domestic representatives “must not merely forward official correspondence” to headquarters — they must diagnose the specific violation, explain the required fix, and confirm that the principal company has actually made the change. Representatives who operate as mail forwarding services will face the same scrutiny as the publishers they nominally represent, per the Newsway report.

How the AI Basic Law Adds a Second Layer

Companies on the GRAC’s gaming roster may face an overlapping obligation under South Korea’s AI Basic Law, which took effect January 22, 2026, per Library of Congress analysis. Article 39 of the Framework Act on the Development of Artificial Intelligence and Establishment of Trust creates its own domestic-representative requirement for foreign AI operators, targeting companies with prior-year total revenue exceeding ₩1 trillion (approximately $683 million USD), prior-year AI-service revenue exceeding ₩10 billion (approximately $6.83 million USD), or at least one million average daily Korean users, according to a Trade.gov market brief.

Because many of the 81 game publishers on the GRAC roster use AI systems in their games — for recommendation engines, adaptive difficulty, NPC behavior, or content generation — some may face both a GIPA representative obligation for their gaming-law compliance and an AI Basic Law representative obligation for their AI-law compliance. The GRAC’s July 10 briefing specifically addressed both frameworks, making it the practical implementation touchpoint for companies navigating the combined regime. A one-year grace period on AI Basic Law fines runs through January 22, 2027, except for violations involving loss of life or fundamental human rights.

What This Law Does — and What It Doesn’t

Korean gamers gained something concrete on October 23, 2025, that they did not have before: a legally responsible, physically present, Korean-speaking point of contact at every major foreign publisher operating in the country. For the years preceding the law, documented consumer complaints about foreign publishers — billing disputes, refund requests, false probability disclosures — routinely stalled because there was no Korean address to serve documents on and no local staff authorized to respond, per Korea Herald background. The domestic representative system closes that enforcement gap.

What it does not close is the data relationship between Korean gamers and the publishers who collect their behavioral data. For the eleven Chinese companies on the list, that relationship is governed not just by GIPA and Korean consumer protection law, but by China’s National Intelligence Law (2017), whose Article 7 requires all Chinese organizations and citizens to “support, assist, and cooperate with national intelligence work.” China’s Data Security Law (2021) and Cybersecurity Law (2016) create additional government-access obligations that apply regardless of where a company’s servers are physically located or what its stated privacy policy says. The GIPA domestic representative system creates accountability to Korean regulators; it does not and cannot alter the legal obligations these companies carry under Chinese law.

South Korea as a Regulatory Template

South Korea is the world’s fourth-largest gaming market by revenue, with approximately $14.6 billion in revenue in 2025 and roughly 29.5 million active gamers spending more per capita than any other comparable population, per Seoulz market data. Its loot box regulatory history — the 2023 GIPA amendment mandating probability disclosure, the 2024 KFTC fine of ₩11.6 billion (approximately $7.9 million USD) against a domestic publisher for deceptive gacha practices, the February 2026 GRAC Loot Box Victim Relief Center — amounts to the most systematically developed consumer-protection framework for randomized-item gaming mechanics in any major market, per the Chambers & Partners guide.

No comparable market has implemented a foreign-publisher local-agent system specifically for gaming. Japan, the world’s third-largest gaming market, requires no comparable designation from foreign publishers. The European Union’s Digital Services Act creates accountability mechanisms for very large online platforms but does not extend to gaming-specific probability disclosure or create gaming-specific local agents. North American markets have no equivalent.

The global question the industry is watching: if South Korea’s enforcement architecture — designation plus monitoring plus escalating penalties — demonstrably improves both market access accountability and consumer protection quality, will other major markets develop similar systems? The cost of building a representative network is manageable for major publishers (one representative may serve multiple foreign principals simultaneously), but the operational overhead of maintaining genuine compliance — rather than nominal designation — is exactly the kind of cost that scales with how seriously enforcement agencies pursue disclosure-quality outcomes. South Korea’s July 10 briefing data suggest they intend to pursue it seriously.

Frequently Asked QuestionsWhich foreign game companies are required to appoint a South Korean local representative?

Foreign game companies that do not have a Korean office or place of business and meet either of two thresholds must comply: annual global revenue exceeding ₩1 trillion (approximately $683 million USD at the July 28, 2026 exchange rate of ₩1,465 per dollar) in the prior year, or an average of 1,000 or more new daily installs of any of their games in South Korea over the prior year, per the official MCST press release. Google Play and Apple App Store operators are exempt. The 81 companies on the current roster include publishers ranging from Nintendo and Roblox to MiHoYo and NetEase. Companies not reaching the thresholds may also be designated if regulators determine they pose a significant harm risk.

What happens to a game publisher that refuses to designate a representative in South Korea?

Under current law, non-compliant publishers face administrative fines of up to ₩20 million (approximately $13,652 USD), which can be imposed repeatedly until they comply, per the Shin & Kim newsletter. One company from the 81-company roster is currently in a pre-penalty opinion-submission process, the stage before a fine is formally issued. Pending legislation would escalate penalties to up to 3 percent of annual sales or ₩1 billion (approximately $683,000 USD) for gacha disclosure violations, and separate proposals would allow regulators to suspend game distribution in South Korea for persistently non-compliant publishers, per Inven Global reports.

What is South Korea’s loot box probability disclosure law, and does it now apply to foreign game publishers?

South Korea’s Game Industry Promotion Act requires game publishers to disclose the exact odds for randomized in-game items — loot boxes, gacha pulls, prize crates — in Korean for any game distributed in the country, effective March 22, 2024, per Lexology legal analysis. The domestic representative system makes those disclosure obligations enforceable against foreign publishers for the first time: the Korean representative is legally responsible for ensuring the game’s odds information is correctly displayed, and GRAC can now compel responses from someone physically present in the country. However, GRAC’s July 10, 2026 briefing data show that 40 percent of covered games still partially fail the disclosure standard and 14 percent fail it entirely, even with representatives in place.

Should Korean gamers think differently about playing games from Chinese publishers now that a local representative is required?

The representative system gives Korean gamers a genuine new avenue for complaints, billing disputes, and refund requests from the Chinese publishers on the list — that is a real and meaningful consumer protection improvement, per the Newsway briefing report. What the system does not change is the data-law relationship. Companies like MiHoYo, NetEase, and ByteDance’s Nuverse remain subject to China’s National Intelligence Law (2017), which requires all Chinese organizations to cooperate with national intelligence requests, and to China’s Data Security Law (2021), which governs what data they hold and can be compelled to share. Those obligations run independently of Korean law and are unaffected by the domestic representative designation. Korean gamers who play titles from Chinese publishers should understand that a local Korean contact does not alter the legal obligations those publishers carry under Chinese national law.