1.

Key points of the proposed amendment to the Whistleblower Reward Program
 

(1)

Complete removal of reward payment caps

The current Whistleblower Reward Program sets a cap on reward payments for each type of violation (e.g., KRW 3 billion for cartels, KRW 2 billion for unfair support, and KRW 500 million each for violations of the Fairness in Subcontracting Transactions Act, the Fairness in Distribution Transaction Act, and the Fairness in Franchising Transaction Act). The draft amendment proposes to remove these caps entirely so that the potential reward payable in cases involving very large administrative fines could increase substantially.
 

(2)

Simplified and increased reward calculation rate (Flat 10% of the administrative fine)

The proposed amendment simplifies the payout structure by replacing a complex, bracketed regressive system with a flat percentage model. Currently, rewards are calculated by applying the lower percentage rates to successively higher fine brackets. This baseline amount is then multiplied by an evidentiary reward rate, which depends on the evidentiary value of the whistleblower’s report (Highest: 100%, High: 80%, Medium: 50%, Low: 30%). For example, under the old regressive system, a report with the “Highest” evidentiary value resulting in a KRW 100 billion fine would yield a KRW 2.85 billion reward, calculated across declining brackets (10% of the first KRW 5 billion, 5% of the next KRW 15 billion, and 2% of the amount above KRW 20 billion).

The proposed amendment simplifies this system by establishing the baseline payout as a flat 10% of the total administrative fine, which is then adjusted only by the whistleblower’s evidentiary rate. Consequently, under the new system, the same KRW 100 billion fine with the “Highest” evidentiary level would result in a reward of KRW 10 billion.
 

(3)

Expanded scope of acceptable evidence for Improper Support and Private Benefit Appropriation

Currently, the Whistleblower Reward Program only accepted information regarding “transaction records” and “transaction terms” as valid evidence for rewards. The KFTC now proposes to include information demonstrating an “intent to provide support”. This change reflects the regulatory reality where for improper support and private benefit appropriation cases, an outsider rarely has the means to uncover or prove subjective corporate intent.
 

(4)

Adjustment of the timing of reward payments

Under the current rule, rewards are paid within three months after the KFTC’s decision, which results in payouts being distributed before the underlying legal disputes and litigation are fully resolved. To address this, the proposal introduces a two-stage payment system: (i) a basic reward (calculated by multiplying the minimum payout amount for each type of violation by the evidentiary rewards rate) will be paid once the respondent company initially pays the administrative fine and (ii) any remaining reward will be paid after the appeal proceedings are concluded and the administrative fine is finally confirmed and paid.
 

2.

Implications
 

(1)

Increased incentives for insider reporting

In the United States, the DOJ Antitrust Division introduced the Whistleblower Rewards Program jointly with the USPS in July 2025, offering payouts of up to 30% of criminal fines for reporting cartel conduct, with the first reward of USD 1 million being paid out in January 2026. The proposed Korean amendment is similar in purpose and expected outcome to the U.S. DOJ program: By implementing a more lucrative structure, the amendment is expected to encourage more active insider reporting in Korea, triggering new regulatory investigations.
 

(2)

Greater incentive to report in the context of the KFTC’s tougher enforcement stance

The KFTC has recently intensified its enforcement actions against cartels. In 2026, the KFTC imposed administrative fines totaling several hundred billion Korean Won in cartel cases involving food and daily consumer products, while conducting intensive on-site investigations in energy and petrochemical sectors. Under the newly effective amendment to the “Detailed Standards for the Imposition of Administrative Fines” (April 30, 2026), the KFTC significantly raised the base rates for fines and increased penalty weightings for repeat offenders. Coupled with this increase in administrative fines, the proposed amendment is expected to expand the whistleblower incentive even further.
 

(3)

Need for corporate risk assessment and stronger compliance

When the proposed amendment takes effect, the number of investigations triggered by whistleblower submissions is expected to rise. Companies that have previously faced allegations of potential violations or flagged issues during internal compliance reviews should use this amendment as an opportunity to strengthen internal antitrust training, re examine compliance procedures both within the company and in its external interactions, tighten controls over information exchange and field-level contacts, and enhance efforts to ensure compliance with antitrust and competition law.
 

3.

Next steps

After gathering opinions during the public comment period, the KFTC plans to complete the required procedures and finalize and implement the amendment within the first half of 2026.