Look, let's be honest about the domestic representative designation system implemented last October, which forces overseas gaming companies of a certain scale to appoint a local representative to keep them playing by local rules. Now that it has hit its one-year mark, critics are pointing out that the current thresholds leave plenty of loopholes for overseas publishers to slip right through, meaning the net needs to be cast much wider.

During the Culture, Sports and Tourism Committee audit held on October 12, Representative Kim Jae-won of the Rebuilding Korea Party cornered Game Rating and Administration Committee Chairman Seo Tae-gun, highlighting gaping blind spots in the domestic representative designation system. Kim zeroed in on the metric of 'user count'. Under current legislation, overseas game companies are required to appoint a local representative if they pull in an annual revenue of at least 1 trillion won or rack up an average of 1,000 daily installs. Crucially, the installation count is calculated per individual game, rather than being pooled across the entire company.

Touching upon the installation count, Kim pointed out that "publishers running multiple small-scale games slip right through the designation net even if their total pooled user base is massive. Over the past three years, out of the game companies receiving corrective requests from the Game Rating and Administration Committee, 18 failed to meet the designation criteria for revenue and installs yet racked up corrective requests across two or more games, and 8 of them ended up on the mandatory designation list solely due to entirely different titles." Meanwhile, 29 overseas publishers failed to meet the local representative designation requirements for even a single game while repeatedly receiving anywhere from 21 down to 10 corrective requests from the committee.

Kim emphasised that "out of 277 overseas companies receiving corrective requests over the past three years, a paltry 40—just 14 percent—actually sit on the mandatory designation list. It feels like the target scope itself was drawn up far too narrowly. Even if they fail to meet the statutory benchmarks, companies that repeatedly face corrective actions need to be dragged in and designated anyway."

Responding to this critique, Game Rating and Administration Committee Chairman Seo Tae-gun stated, "I completely agree with the points raised by the honourable representative. At present, we lack the legal basis to take special enforcement action against overseas corporations that repeatedly receive corrective requests. We will consult closely with the competent ministry, the Ministry of Culture, Sports and Tourism, to figure out a way forward."

On a related note, a partial amendment to the Game Industry Promotion Act spearheaded by Representative Kim Jae-won to beef up user protection duties for overseas gaming companies sailed through the National Assembly plenary session on October 1st. The amendment introduces new compliance obligations for game providers to safeguard domestic user welfare and handle grievances, while stipulating that when designating a local representative, priority must be given to domestic corporations established or effectively controlled by the business in question. Furthermore, it slaps game operators with duties to manage and supervise their domestic representatives and maintain their designation, empowering authorities to issue corrective orders if the representatives fail to pull their weight.