1.

Periodic Status Review of LIB or LBS

Pursuant to Article 36(3) and (4) of the Act on the Protection and Use of Location Information (the “LIA”), the KMCC is required to conduct periodic status reviews of personal location information providers at least once a year. A status review consists of a written review and, as determined by KMCC, may also include an on-site inspection. Historically, the KMCC has conducted these as an annual written inspection of location information providers and location-based service providers. While this year’s written reviews have been underway since April, with the recent reorganization of the Korea Communications Commission (the “KCC”) into the KMCC, on-site inspections are also resuming. The review scope covers all aspects of LIA compliance, including required administrative and technical measures for location information.

Generally, personal location information providers are subject to this review every year. Other business types may be specifically designated by the KMCC for review. Please verify whether your company has received an official notification from the KMCC regarding status reviews for 2025. If an inspection is scheduled, timely and complete responses within the given deadlines will be required.
 

2.

Dispositions Related to Past Status Reviews

For companies where violations were identified during the 2023 and 2024 reviews, administrative sanctions were scheduled to be finalized by resolution in 2024. However, due to various circumstances surrounding the former KCC since August 2024, it was unable to pass resolutions. As a result, a number of companies have not yet received their final administrative dispositions.

As part of a recent government reorganization, the Act on the Establishment and Operation of the Korea Media and Communications Commission was passed by the National Assembly on September 27, 2025, and became effective on October 1, 2025. This act abolished the KCC and established the new KMCC.

Accordingly, the authority to issue dispositions for violations identified in 2023 and 2024 reviews has transferred to the KMCC. These administrative sanctions are expected to resume once the KMCC commissioners are fully appointed.

If your company was subject to the location information review in 2023 or 2024, it is important to re-confirm whether the review was concluded without any findings or whether your company is the subject of pending sanctions. If administrative sanctions apply to your company, please ensure that your response to any advance notice of disposition has been submitted.

Violations can result in various sanctions, including corrective orders, fixed-amount administrative penalties (up to KRW 20 million), percentage-based administrative fines (up to 3% of relevant revenue), and even potential criminal penalties.

Please note that administrative actions may be taken, even if a significant amount of time has passed since the status review and even if you previously submitted your position to the KCC. If you wish to challenge a final disposition, you must file an administrative appeal with the KMCC or initiate an administrative lawsuit seeking revocation. Therefore, advance preparation for a potential appeal is recommended.
 

3.

Monitoring of Licenses/Permits for LIB or LBS

In parallel with these status reviews, the KMCC is actively monitoring and taking action against businesses operating without the necessary licenses or permits for LIB or LBS.

This ongoing monitoring, previously performed by the KCC, is continuing under the KMMC. If your company provides location information services, please confirm that all required licenses or permits have been duly obtained. Operating an unregistered or unreported LIB is subject to a criminal offense and may result in prosecution.