In June 2022, the Korea Consumer Agency ("KCA") issued a press release on the growing number of consumer complaints against foreign game companies' refusal to refund mobile and PC game content purchases.  As the KCA's press release may prompt other regulatory agencies to examine the terms and conditions of foreign game companies and transaction practices in the industry, companies are advised to conduct an internal review of their cancellation and refund policies for digital game content purchases and closely monitor the regulatory developments.

According to the KCA's press release, the digital game content market continues to grow, driven by increased consumption, but there has been a significant increase in consumer complaints about companies refusing refunds for cancelled game content purchases, which are often made by minors without their legal guardians' consent.  While dissatisfied consumers frequently ask the app market operator to cancel their purchases and provide a refund, it is often difficult to resolve their grievances because foreign game companies, which sell their products through app markets, often have a no-refund policy in their own terms and conditions, do not offer customer services in Korean, and fail to provide timely responses to refund inquiries.

The Korea Fair Trade Commission (the "KFTC") has detected and sanctioned game companies in the past for unfairly restricting subscription withdrawals and continues to pay close attention to the digital sector for unfair trade practices and ways to further promote consumer rights and interests.  Because the KFTC may conduct additional review of foreign game companies' compliance with various consumer protection laws and regulations, based on the KCA's press release, with a focus on terms and conditions for refunds, we advise the companies to prepare for a possible KFTC inquiry or investigation in advance.