Korea's E-Commerce Act Amendments: 3 Legal Risks for Platform and Commerce Operators
The proposed amendments to the Enforcement Decree and Enforcement Rules of Korea's Act on Consumer Protection in Electronic Commerce have significantly raised the legal compliance bar for platform and commerce businesses operating in the Korean market.
This is not simply a matter of updating a few lines in your terms of service. The changes affect the full scope of operational structure — from how reviews are managed, to how payment screens are designed, to the extent of liability for C2C intermediary platforms.
Here are the three risks that require the closest attention right now.
1. Review and Rating Operations: No Policy Means Liability
The amendments are designed to require platforms to clearly disclose to consumers the rules governing user reviews and ratings. Specifically, platforms will need to communicate who is eligible to write a review, how long reviews remain posted, how ratings and scores are calculated, the criteria and procedures for removing or hiding reviews, and how users can contest a removal decision.
The following situations already represent concrete legal exposure:
Selectively removing or hiding critical reviews without publicly disclosed internal criteria, displaying sponsored or paid reviews in the same format as organic user reviews, and mixing undisclosed paid advertising placement into rating or ranking algorithms — all of these create regulatory risk under the amended framework.
The bottom line is documentation. Precisely defining when reviews can be posted and when they can be taken down — across your terms of service, operational policies, and internal management manuals — is the most urgent compliance task right now.
2. Dark Pattern Regulation: A Baseline Risk for Every Commerce Operator
The amendment package, together with consumer protection guidelines already in force, is tightening regulation of so-called dark patterns — deceptive interface design practices — across pricing, discounts, shipping, refund policies, subscription structures, and cancellation UX.
The practices most likely to attract scrutiny include: overstating discounts or coupon value relative to the actual amount charged at checkout; obscuring auto-renewal or subscription conversion terms, or making cancellation buttons difficult to find; and failing to clearly display shipping costs, additional fees, or return conditions before the final payment step.
Under the revised penalty framework, a single repeat violation can now trigger a surcharge of up to 50% on top of the base penalty, and four or more repeat violations can result in a surcharge of up to 100% — with administrative fines also being raised across the board.
For startups, e-commerce operators, and platform businesses, this means UI/UX design decisions — not just contract language — now need to be reviewed through the lens of the E-Commerce Act and consumer protection law.
3. C2C Platform Liability: The Limits of Intermediary Immunity
The amended E-Commerce Act and its follow-on enforcement decree now impose affirmative obligations on C2C (consumer-to-consumer) platforms as registered e-commerce intermediaries — regardless of whether they are direct sellers.
Under the proposed rules, the range of personal information platforms must verify for individual sellers is being narrowed: the existing five-item requirement (name, date of birth, address, phone number, email address) is being reduced to two (phone number and email address). However, obligations to preserve and provide transaction records and to cooperate in consumer dispute resolution are being strengthened.
The defense that "we bear no responsibility because we are merely an intermediary" is becoming increasingly untenable. What will determine the scope of a platform's legal liability is how it has structured its terms of service liability limitations, its dispute resolution and reporting processes, and its criteria for sanctioning or removing sellers.
What Should You Be Reviewing Now?
These amendments are not an abstract legal development — they directly affect platform architecture (marketplace, C2C, cross-border), review and ranking logic, and the design of pricing, subscription, and cancellation flows.
Decent Law Firm's Corporate Practice provides integrated legal support through our E-Commerce Law, Platform Advisory, and Consumer Protection Law practices — covering full review and revision of terms and operational policies, legal guidance on UI/UX design to eliminate dark pattern exposure, and the design of documentation structures to withstand regulatory scrutiny and disputes.
If you need to assess whether your platform's review policies or payment structures are compliant with the amended framework, contact Decent Law Firm today.'
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