Proposed Amendments to GIPA Subordinate Regulations – Relaxing the Duty to Report Content Revisions and Revising Self-Rating Business Operator Qualifications

Following the recent amendment to the Game Industry Promotion Act (“GIPA”), the Ministry of Culture, Sports and Tourism announced proposed amendments to the Enforcement Decree and Enforcement Rule of the GIPA, with an effective date scheduled for October 9, 2025.

Overview of the Proposed Amendments

The proposed amendment relaxes the obligation to report content revisions by exempting “minor matters” from the reporting requirement.

It also eases the qualifications for designation as a self-rating business operator; meeting the capital requirement of KRW 100 million or more will now suffice.

However, the definition of “minor matters” remains abstract, which may lead to varying interpretations. We recommend close monitoring of the forthcoming Game Rating and Administration Committee (“GRAC”) regulations, which are expected to clarify these criteria.

In our previous newsletter, we mentioned that the proposed GIPA amendment had passed, relaxing the duty to report content revisions and self-rating business operator designation requirements (Link). In advance of the October 9, 2025 effective date, the draft subordinate regulations have now been publicly released for comments. The Ministry will collect public feedback until September 15, 2025.

Specification of “Minor Matters” Exempted from the Duty to Report Content Revisions

Previously, the Enforcement Rule provided an exception for reporting content revisions only in cases of technical supplements or improvements that did not alter the game content. The proposed amendment lists the following as “minor matters” that are exempted from the reporting duty (Article 9-2(2) of the amended Enforcement Rule):

Corrections of errors or technical improvements that do not substantively change the game content;
Modifications to in-game systems, characters, items, backgrounds, scenarios, videos, etc., provided, these do not impact the existing rating decision or game content information; and
Changes to the appearance of a game device that do not affect how the game is used, applicable to both minors and general on-site arcade game business.

*Note: Any revisions related to speculative content are excluded from this “minor matters” exemption (proviso to Article 9-2(2)).

While more detail is provided, some wording remains open to interpretation. As the Enforcement Rule delegates further clarification to the GRAC’s internal regulations (Article 9-2(3)), which we believe is the GRAC’s Game Rating Rules, continued monitoring of related regulatory updates is recommended.

Additionally, for content revisions reported in advance under the amended GIPA, the revised game content must be submitted to the GRAC as prescribed by the relevant regulations, to confirm consistency with the reported revisions. The amended Enforcement Decree introduces an administrative fine of KRW 1 million for failure to submit revised game content (Annex Table 4, Subparagraph 3-2 of the amended Enforcement Decree).

2.	Relaxation of Requirements for Designation as a Self-Rating Business Operator The proposed amendment to the Enforcement Rule implements the relaxed requirements for designating self-rating business operators under the GIPA:

Previously, designation required average sales of at least KRW 10 million for the past three years.
Under the amendment, a self-rating business operator can be designated based solely on meeting the capital requirement (KRW 100 million or more, per Article 21-2(2)(i)(a) of the GIPA and Article 9-4(1) of the amended Enforcement Rule), regardless of the above sales requirement.

[Korean Version]

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