PIPC Announces 2026 Investigation Policy Direction

On January 14, 2026, the Personal Information Protection Commission (the “PIPC”) finalized its “2026 Personal Information Investigation Policy Direction” (the “Policy Direction”) at a plenary meeting, marking a shift from reactive enforcement toward a “risk-based approach” with “full lifecycle management” (Link).

In the Policy Direction, the PIPC has identified six priority investigation areas: (i) large-scale data controllers; (ii) high-risk personal information such as biometric and video data; (iii) excessive data collection practices including dark patterns; (iv) emerging technologies such as AI recruitment and blockchain; (v) data breach vulnerabilities in the public sector; and (vi) changes in data processing structures due to M&A or bankruptcy proceedings.

Proactive Inspections of Large-Scale Data Controllers

According to the Policy Direction, the PIPC plans on prioritizing inspections of businesses processing personal information of 1 million or more data subjects on a daily basis in sectors closely connected to daily life. Target selection will consider various factors, including incident frequency, service characteristics, and whether sensitive information is processed. These inspections are expected to focus on internal control systems.

High-Risk Data Processing (Biometric and Video Data)

The PIPC also plans on inspecting video data processing practices by businesses, focusing on large operators of multi-use facilities that use IP cameras and similar devices, particularly in light of recent cyber incidents. Biometric authentication providers using facial or voice recognition are likely to face scrutiny, with inspections covering processing transparency, encryption compliance, and internal controls, among others.

Unfair Data Collection Practices

According to the Policy Direction, the PIPC is expected to monitor major web and app services for dark patterns and other unfair practices that distort user choices. Inspections will also target excessive collection of children's personal information at venues such as performance halls.

Preventive Inspections in AI and Blockchain

For AI recruitment solutions, the PIPC will examine transparency measures, including guarantees of the right to refuse automated decisions, compliance with explanation obligations, and disclosure of evaluation criteria. For blockchain services (virtual asset platforms and decentralized identity applications), reviews will cover controls on personal identifiability given distributed ledger characteristics, responsibility allocation among participants, and legal grounds for cross-border transfers, among others.

Public Sector Breach Vulnerabilities

The PIPC intends to strengthen vulnerability testing requirements, including penetration testing of major public systems. Remedial measures will address the three main breach vulnerabilities: (i) human error, (ii) web vulnerabilities, and (iii) management blind spots.

M&A and Corporate Restructuring

Lastly, the PIPC will conduct advance inspections of personal information transfers and destruction during M&A and bankruptcy proceedings, examining both lawfulness and security. These efforts will link to potential institutional improvements, including privacy impact assessments and ISMS-P certification succession.

Beyond these priority areas, the PIPC announced several operational enhancements:

(1)

Pre-investigation: Restructuring the breach reporting center to focus on consultation and grievance resolution; establishing standing monitoring for sectors affecting daily life

(2)

Investigation: Pursuing compulsory compliance payments for failure to comply with document production orders; introducing evidence preservation orders; enhancing digital forensics capacity through full operation of the forensic center and establishment of a technical analysis center by year-end

(3)

Sanctions: Increasing penalty surcharges for repeat violations; pursuing introduction of punitive penalties (10%); implementing compulsory compliance payments for non-compliance with corrective orders

The Policy Direction reflects the PIPC’s commitment to proactively address emerging threats in the AI-driven digital environment. As such, businesses should closely monitor developments, particularly preventive inspections for large-scale data processors and emerging technology sectors, as well as strengthened penalty frameworks.

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