South Korea digital markets act

South Korea Finds Google and Apple Violated Its 2021 Anti-Steering Law — But Still Won't Say What Happens Next

KMCC ruled Google and Apple's 26% third-party payment fee guts Korea's pioneering app-payment law, five years on with no sanction yet.

Korea's Anti-Steering Law: Ruled, Not Enforced People of Internet Research · South Korea ~26% Third-party payment fee Fee Google and Apple charge on tra… ₩68B Proposed maximum fines Corrective-order fines KCC propose… 5 years Years since law took effect Korea's anti-forced-payment law an… peopleofinternet.com
Korea's Anti-Steering Law: Ruled, Not … People of Internet Research · South Korea ~26% Third-party payment fee ₩68B Proposed maximum fines 5 years Years since law took effect peopleofinternet.com

Key Takeaways

South Korea's Korea Media and Communications Commission (KMCC, formerly the Korea Communications Commission) ruled on August 12, 2026 that Google and Apple violated the country's 2021 amendment to the Telecommunications Business Act — the world's first law explicitly barring app-market operators from forcing developers onto a single payment system. At its 27th plenary meeting, the commission found that both companies still require developers to use designated payment methods on pain of app-review rejection, and that they charge roughly 26% on transactions routed through third-party payment processors — just a few points under their standard in-app commission. The KMCC said sanctions "will be decided at a later date."

A Fee Engineered to Swallow the Loophole

Korea's law never told Google and Apple what to charge. It told them they could not force developers into a single payment rail, full stop — a legislative first when the National Assembly passed it in September 2021, and one that predated the EU's Digital Markets Act by three years. The enforcement decree that took effect in March 2022 spelled out the mechanics: no blocking outlinks to alternative payment options, no discriminating against developers who use them.

What the law didn't anticipate was that "permission" could be rendered meaningless by price. The KMCC's finding is that a roughly 26% commission on third-party transactions — alongside exclusion from promotional fee-reduction programs available to the platforms' own payment systems — makes the alternative not worth using. Developers technically have a choice. Economically, they don't. That is a real and well-documented pattern in platform regulation: comply with the letter of a steering mandate while designing the fee schedule so nobody actually steers. The EU ran into an identical version of this fight with Apple's "Core Technology Fee" under the DMA, and Korean regulators are right to treat fee-engineering as a live enforcement question rather than a technicality outside their remit.

Five Years, No Fine

Here is where the steelman runs out. The KMCC's predecessor first proposed corrective orders and fines of up to ₩68 billion — ₩47.5 billion against Google, ₩20.5 billion against Apple — on October 6, 2023, nearly three years ago. That case has been re-argued, re-heard, and re-deferred since, with the August 12 plenary the latest instance of the commission hearing both companies out and then declining, again, to set a number. A law passed in 2021, with an enforcement decree in force since March 2022, has now gone more than five years without producing a single sanction against either company.

That is not proportionate regulation — it is regulation that never quite arrives. A three-year gap between "we found a violation" and "here is the penalty" does more to erode the credibility of Korea's anti-steering law than any commission structure Google or Apple could design. Developers who might restructure pricing around the promise of cheaper payment rails have had five years to learn that the promise doesn't reliably convert into relief on any predictable timeline. Platforms, for their part, have had five years to calculate that a 26% fee carries negligible regulatory risk in the near term. Delay is not neutral; it is a subsidy to whichever side can better absorb uncertainty, and that is rarely the smaller developer.

What Proportionate Enforcement Actually Requires

The fix isn't for Korea to abandon the law or to impose the maximum fine as a matter of principle — ₩68 billion is a large number attached to a specific 2023 finding, and it deserves review on its current facts, not automatic reinstatement. The fix is procedural discipline: regulators who identify a fee structure that nullifies a statute's purpose should be required to rule on remedy within a bounded window, not leave it open-ended through repeated plenary deferrals. Proportionality cuts both ways — it means not over-punishing platforms for having a commission at all, but it also means not letting "we'll decide later" function as a permanent stay of enforcement.

If the 26% fee genuinely defeats the 2021 law's purpose, Korea should say so with a number attached and a deadline for compliance, the way it did with its March 2022 decree. If Google and Apple believe a fee near their standard commission is a reasonable reflection of payment-processing, fraud, and platform-maintenance costs, they should be made to defend that number publicly rather than negotiate it in private hearings that produce no public timeline. What Korea's app-payment saga mostly demonstrates, five years on, is that writing a pioneering law is the easy part. Enforcing it against a foreseeable, obvious workaround — high fees at the door — is the part regulators have to actually deliver, and on this record they haven't.

Sources & Citations

  1. KMCC — corrective measures & up to ₩68B fine proposal (Oct. 6, 2023)
  2. KMCC — Telecommunications Business Act enforcement decree (Mar. 8, 2022)
  3. Korea Times — Media watchdog says Google, Apple violated in-app purchase laws
  4. Korea JoongAng Daily — Korea watchdog finds Google and Apple violated app payment law