You need one if your company offers games in Korea, has no office or place of business there, and meets any one of three tests: KRW 1 trillion in worldwide sales last year; one mobile game averaging 1,000+ daily installs on Korean devices last year; or a report request from the Minister of Culture, Sports and Tourism under Article 31(2) after an incident that seriously harms, or may harm, orderly game distribution.
Step 1: Is your company in scope?
Test each legal entity, not the brand or group. An entity is in scope if it distributes or provides games in Korea ("offers" below) and has no Korean office or place of business.
- Korean affiliates. An affiliate that does no game work does not take you out of scope. A Korean subsidiary that solely handles the game's distribution in Korea does, according to the ministry's FAQ.
- Targeting Korea. The test looks at substance: Korean-language service, Korean payment methods, region settings, Korean ads, local users, and any Korean branch doing game work.
- Marketplaces. Open marketplaces are excluded if they don't distribute games themselves and have no loot-box (probability-item) disclosure duties. If you also publish games, that part is assessed separately.
- Groups. If a parent and a subsidiary both offer games in Korea, each runs the test for itself. They can share one agent.
Step 2: Do you meet any one test?
One test is enough.
| Test | Threshold | Counts | Doesn't count |
|---|---|---|---|
| Worldwide sales | At least KRW 1 trillion in the prior year (prior fiscal year for a corporation) | All revenue, every country and business line. Convert at the prior year's average exchange rate (the ministry's guide points to Seoul Money Brokerage Services). | Korean bookings, app-store proceeds or game-division revenue in place of total sales |
| One mobile game | Installs on Korea-sold devices, 1 Jan to 31 Dec last year, divided by 365, of at least 1,000 (365,000 annual installs) | The same title across all app stores, any player nationality. Divide by 365 even if the game launched in December or shut down mid-year. | Daily or monthly active users, PC or console installs, installs added across different titles |
| Ministry report request | The Minister of Culture, Sports and Tourism required a report under Article 31(2) after an incident that seriously harms, or may harm, orderly game distribution | That request | Routine GRAC emails, or Article 31(2) requests from a local government or for another reason |
Article 31(2) is a paragraph of Article 31. Article 31-2 is the separate article that creates the agent requirement.
Examples
- PC publisher, KRW 1.2 trillion in worldwide sales, no large mobile title: needs an agent.
- Mobile studio, KRW 4 billion in sales, one game with 410,000 Korean installs (1,123 a day): needs an agent.
- Five games with 90,000 Korean installs each: the install test isn't met. Check the other two tests.
- Below every threshold: you can still appoint an agent voluntarily.
If you need an agent
Appoint one in writing. List its name, representative, Korean address, Korean phone number and email in the Korean terms of every game you offer in Korea, not just the one that triggered the test. The ministry's guide also recommends emailing GRAC the designation certificate and a copy of the terms. See how to appoint.
From 21 April 2027 the three tests stay the same, but agent duties and selection rules change. See what changes.
Annual checklist
Eligibility is reviewed every year as of 23 October.
- All year: log installs on Korean devices per title and per app store. Keep the exports and metric definitions.
- After year-end: record each entity's prior-year worldwide sales and the exchange rate used to convert to KRW.
- Before 23 October: for every entity that offers games in Korea, record whether it has a Korean office, what any Korean affiliate does, its sales, each title's installs divided by 365, and any Article 31(2) report request from the ministry. Check your agent's details and every Korean terms URL. Note who reviewed it and where the evidence is kept.
- When anything changes: update your agent's details or re-designate promptly.
Sources
- Game Industry Promotion Act, Article 31-2The agent requirement.
- Enforcement Decree, Article 18-3The three tests.
- Ministry final announcement and English guide, 14 October 2025
- Act No. 22085Effective 21 April 2027.