As Korean data privacy laws continue to evolve, understanding whether your company needs a domestic representative in Korea has become increasingly important. This role is now legally required for many foreign companies under the amended Personal Information Protection Act (PIPA), effective October 2, 2025.
What Is a Domestic Representative in Korea?
A domestic representative in Korea is a local entity or agent designated by a foreign company to act on its behalf in matters related to Korean data protection law. The domestic representative s
erves as a direct contact for both the Personal Information Protection Commission (PIPC) and Korean data subjects.
Who Must Appoint a Domestic Representative in Korea?
According to Article 32-3 of the PIPA Enforcement Decree, the following types of companies must designate a domestic representative:
- Annual global revenue exceeding KRW 1 trillion (converted using the previous year’s average exchange rate)
- Handling data of over 1 million Korean users per day, on average, during the last three months of the previous year
- Entities that have been ordered by the PIPC to submit documents under Article 63(1) and have been deemed to require a domestic representative
These companies must appoint a representative who:
- Has a physical presence in Korea
- Can respond to privacy complaints and incidents
- Can submit reports or materials to the PIPC
The foreign company remains legally liable for any actions of the representative.
Do You Still Need a Privacy Officer?
Yes. Under Article 31 of PIPA, most companies processing personal data must designate a Privacy Officer to manage internal compliance. The officer is responsible for:
- Establishing privacy policies
- Handling complaints
- Managing data breaches
- Providing staff training
However, there are exemptions:
- Mining, manufacturing, construction, and transportation businesses with fewer than 10 employees
- Other industries with fewer than 5 employees
In those cases, the CEO or business owner automatically becomes the Privacy Officer.
Why It Matters
With increased scrutiny and recent high-profile data breaches, companies engaging with Korean users—whether through e-commerce, apps, or online services—must carefully evaluate their privacy compliance. Failing to appoint a domestic representative in Korea when required can lead to penalties, investigations, and reputational damage.
Need Help Understanding Your Obligations?
If you’re unsure whether your company needs a domestic representative in Korea, or how to appoint one, feel free to get in touch.
