South Korea app store competition

Korea's First Fines Under Its In-App Payment Law Show the Rule Works Better as a Fee Test Than as a Penalty

KMCC fined Google and Apple 63.7 billion won over forced payments, a 26% fee on alternatives and slow reviews. Fee levels, not fine size, will decide the outcome.

Korea's First In-App Payment Fines People of Internet Research · South Korea 63.7B won Combined fine Google 42.9B plus Apple 20.81B won… 26% Commission on alternative payments Charged on third-party payments, p… Sep 2021 Law in force since Telecommunications Business Act am… peopleofinternet.com
Korea's First In-App Payment Fines People of Internet Research · South Korea 63.7B won Combined fine 26% Commission on alternative paym… Sep 2021 Law in force since peopleofinternet.com

Key Takeaways

On 28 October 2026 the Korea Media and Communications Commission (KMCC) fined Google 42.9 billion won and Apple 20.81 billion won, 63.7 billion won in total, in the first enforcement of South Korea's 2021 in-app payment law, according to The Korea Times. The regulator found that the companies steered developers toward their own payment systems and charged a 26 percent commission on third-party payments. It also found that they delayed app reviews without specific reasons or schedules. The commission ordered both to allow links to external payment websites and to revise their commission structures.

The strongest case for the regulator

The case for the KMCC is strong. App developers cannot reach Korean smartphone users except through two gatekeepers, and those gatekeepers also compete with developers and set the terms. A rule allowing alternative payments means little if the platform can make the alternative expensive or slow it down in review. Apple and Google both argued for years that their policies already complied. In October 2021 the then-Korea Communications Commission (KCC) ordered both to resubmit their compliance plans. It said Apple's "payment outside the app, then usage in the app" approach did not match the law's intent. It said Google's plan to allow third-party payments was "not specific enough." On the KCC's reading, the 2021 amendment exists so that developers can freely choose a payment system "whether it be inside or outside the app." The 2026 findings are a regulator saying that five years of formal compliance did not deliver that outcome.

What the decision actually targets

The 2021 law amended the Telecommunications Business Act. It bars app-market operators from using their bargaining position to force developers onto a particular payment method, and it was in force from 14 September 2021. The October 2026 findings track three distinct behaviours:

These are concrete, observable conduct, which is the right shape for enforcement. The fee finding is the most important part. A rule that lets developers use another payment processor is meaningless if the platform keeps most of the commission anyway.

Why the fine is the weakest part of the decision

The amount is small relative to the companies' global operations. The decision also took about three years from the October 2023 preliminary notice, and the pre-notice figures were broadly similar to the final ones. The delay was not the companies' doing alone. The Korea Herald reports that the decision came about three years after the notice. Reporting from JoongAng Daily adds that the KCC was replaced by the KMCC in October 2025. A fine of this size works as a signal and a precedent. It will not change behaviour on its own.

What will change behaviour is the corrective order. The Korea Times reports that the KMCC set a three-month window for the changes. Both companies have signalled they will contest the decision. Google said it regrets that the decision does not fully reflect its efforts to comply with the law. Apple said it respectfully disagrees and is evaluating its options under Korean law. Expect litigation over the fee finding in particular.

The proportionality problem

The pro-innovation concern is not that platforms should be unregulated. It is that regulators should avoid setting prices by decree. App stores provide real services: distribution, security review, payment handling, fraud protection and refunds. A commission that is higher than a competitive market would produce is a problem. A commission above zero is not. The KMCC's order to bring fees for third-party payments to "reasonable" levels is vague on exactly this point, and vague standards invite years of argument about what counts as reasonable.

A better yardstick is cost-based and testable. Regulators should ask what the platform actually spends on the services it still provides when a developer processes payments elsewhere. They should ask whether the fee gap leaves a competing payment provider room to undercut. They should ask whether review times for apps that use alternatives match those for apps that do not. These questions can be answered with data, published and re-checked. They also avoid giving a regulator a standing power to fix prices, which would chill investment in the platforms and tie the rule to one commission figure.

What to watch

Three things will show whether the decision opens the market or only produces paperwork:

South Korea was an early mover on this issue, and other regulators are watching how it handles enforcement. The lesson from the first case is that a statute alone did not change platform conduct. Enforcement took five years and ended in a modest fine, and the real test is whether the corrective order produces lower fees that developers actually use.

Sources & Citations

  1. KCC news release, 25 October 2021: Apple and Google ordered to resubmit compliance plans
  2. KCC news release, October 2021: follow-up on the law prohibiting forced in-app payments (in force 14 Sep 2021)
  3. The Korea Times: Korea fines Google, Apple over in-app payment practices
  4. The Korea Herald: Communications watchdog fines Google, Apple
  5. JoongAng Daily: South Korea fines Google and Apple over in-app payments
  6. TechCrunch (2023): Google, Apple face fines in South Korea