📌 목차 (Table of Contents)

Most foreign e-commerce sellers treat Korean compliance as something that ends once the mail-order sales business report is filed and the storefront goes live. Only after the site has been running for a while — often when a customer complaint or a Fair Trade Commission inquiry arrives — do most sellers discover that the Act on Consumer Protection in Electronic Commerce (전자상거래법) doesn’t stop at registration. It imposes a running set of obligations that apply to every page a Korean consumer sees and every step of the checkout flow, and Korean regulators have been actively enforcing the newest of these — the dark-pattern rules — since early 2025.

Registration answers the question of whether a seller is allowed to operate in Korea. The obligations covered here answer a different question: whether the way the storefront actually presents information, prices, and cancellation options is itself lawful. A site can be properly registered and still be in active violation of the Act because of how a checkout page is designed.

Table of Contents

Compliance Is an Ongoing Duty, Not a One-Time Filing

Registration Is the Starting Line

Filing the mail-order sales business report (통신판매업 신고) establishes that a seller may lawfully operate in Korea. It says nothing about whether the seller’s actual storefront — its disclosures, its advertising, its checkout flow, its cancellation process — complies with the substantive rules the Act on Consumer Protection in Electronic Commerce imposes on every transaction. Those rules apply continuously, not at a single filing moment, and a registered seller can still be found in violation over how a single page is built.

Why Foreign Sellers Miss This

The trap is treating the E-Commerce Act as a licensing statute rather than an operating-conduct statute. A foreign brand that ports over a checkout flow, a promotional banner, or a subscription-cancellation process from another market — where a pre-checked upsell box or a buried cancellation link might be unremarkable — can be replicating exactly the kind of design the Fair Trade Commission has been actively investigating and fining since Korea’s dark-pattern amendment took effect in February 2025.

Mandatory Disclosure: What Every Page Has to Show

The Core Identity and Contact Information

The Act requires an online seller to display, on the site’s initial screen (or accessible from it), its business name and representative’s name, its business location address — including where complaints are handled — its phone number and email address, its business registration number, and a link to its terms of use. Korean regulators expect this information to be genuinely accessible, not merely present somewhere in a footer link chain a consumer is unlikely to follow.

The Verification Page

Sellers also have to provide a page that lets a consumer independently confirm the authenticity of the disclosed business information — typically a link to the Fair Trade Commission’s business information verification service. This exists specifically to let a Korean consumer check, before buying, that the seller is who it claims to be, which matters more for a foreign brand with no independently recognizable Korean retail presence than it does for an established domestic seller.

Privacy Disclosures Run in Parallel

A separate but related obligation requires a continuously published privacy policy covering the purpose of processing, retention periods, third-party sharing, and destruction procedures for any personal information the site collects — a requirement that sits alongside, and has to be consistent with, the seller’s obligations under the Personal Information Protection Act generally.

Mobile Sites Get a Narrow Accommodation

Where displaying every required item on a single mobile screen isn’t practical, the information can be presented sequentially rather than all at once — but the representative’s name, the business registration number, and the terms of use still have to be reachable through a clear, accessible path, not simply omitted because the format is mobile.

Advertising Rules: What You Can’t Claim or Hide

Pricing Has to Reflect the Real Total

Advertising and promotional claims are subject to the general prohibition on false or exaggerated representations that applies across Korean consumer protection law, but the E-Commerce Act’s own advertising rules focus heavily on price presentation specifically — a promoted price has to correspond to what the consumer will actually be asked to pay, not a stripped-down figure that excludes fees or charges disclosed only later in the funnel.

Comparative and Discount Claims Draw Scrutiny

Discount percentages, “original price” comparisons, and limited-time claims are common enforcement targets when the comparison price wasn’t genuinely the seller’s own recent selling price, or when a “limited time” promotion runs indefinitely. A foreign seller’s promotional calendar and pricing display should be built around what the seller can actually substantiate if asked, not around conventions borrowed from a home-market platform with looser enforcement norms.

The Pre-Contract Confirmation Requirement

Consumers Have to Be Able to Review Before Committing

Before a contract is concluded, the seller has to give the consumer a clear opportunity to confirm, correct, or cancel the contents of the order — in practice, an order-review or confirmation screen that shows exactly what’s being purchased, at what price, with what options, before the payment step is finalized. A checkout flow that pushes a consumer straight from “add to cart” into a completed charge, without an intervening review step, doesn’t satisfy this requirement even if the transaction itself is otherwise lawful.

Order Receipt Has to Be Confirmed Promptly

Once an order is placed, the seller has to promptly notify the consumer that the order was received and confirm product availability — an obligation that matters particularly for sellers running inventory across a home-market warehouse and a Korean-facing storefront, where a stockout discovered only after the order confirmation creates its own separate consumer-protection exposure.

Dark Pattern Regulation: Korea’s February 2025 Amendment

Five Practices Now Specifically Targeted

An amendment to the Act on Consumer Protection in Electronic Commerce took effect on February 14, 2025, specifically targeting so-called dark patterns — interface designs that exploit consumer inattention rather than informing consumer choice. The amendment identifies five categories: drip pricing (showing only a partial price on the initial screen rather than the full amount necessary to complete the purchase); pre-selected paid add-ons at checkout; visual-hierarchy manipulation that uses size, color, or placement to make one option look mandatory or exclusive; making cancellation, withdrawal, or subscription termination meaningfully harder than the original sign-up process; and repeatedly re-prompting a consumer to reverse a decision they already made, in a way designed to wear down their original choice.

Subscription and Recurring-Charge Consent

The amendment separately requires a seller to obtain a consumer’s explicit prior consent before raising a subscription price or converting what was offered as a free service into a paid one — a rule aimed squarely at the “free trial that silently becomes a paid subscription” pattern common in software and content subscription models. A foreign SaaS or subscription-commerce business bringing a Korean-facing product to market should treat this as a checkout and billing-flow design requirement, not a terms-of-service disclaimer that can carry the obligation on its own.

Cancellation Has to Be at Least as Easy as Sign-Up

The “cancellation obstacles” category is broader than it might first appear — regulators have treated a cancellation flow that requires more steps, more friction, or a different channel (a phone call to cancel something signed up for online, for example) than the original sign-up as falling within the prohibited pattern. The unsubscribe path has to be genuinely comparable in effort to the signup path, not merely available somewhere in an account settings menu.

Enforcement Has Already Started

The Fair Trade Commission has been actively enforcing the dark-pattern provisions since the amendment’s effective date, with administrative fines and corrective orders issued against platforms found in violation, and further guidance and subordinate regulation continuing to refine how the categories apply in practice. A foreign seller should treat this as a live enforcement area rather than a rule still settling into dormancy.

Withdrawal Rights, Refunds, and the Escrow Requirement

The Statutory Cooling-Off Period

Korean consumers generally have the right to withdraw from a purchase within seven days of receiving the goods, without needing to justify the decision, subject to narrow exceptions such as goods made or customized to the consumer’s specific order — and even that exception generally requires the seller to have obtained the consumer’s advance written acknowledgment that withdrawal won’t be available. A foreign seller’s home-market return policy doesn’t carry over automatically.

Refunds Run on a Statutory Clock

Once a returned product is back in the seller’s hands, the refund generally has to be processed within three business days; missing that window triggers statutory interest at 15% per annum from the point the refund should have been made.

The Purchase Safety Service Sits Behind All of This

A seller collecting advance payment generally has to use a purchase safety service — an escrow or payment-guarantee arrangement — or demonstrate an equivalent safeguard, and hold the usage confirmation certificate from that provider as part of its own compliance file. This obligation, and the registration process it supports, is covered in more detail in the earlier guide to mail-order business registration for foreign e-commerce sellers.

Practical Sequencing for Ongoing Compliance

Most of the exposure foreign e-commerce sellers carry in Korea isn’t a registration gap — it’s a storefront and checkout flow built around home-market conventions that Korean consumer protection law treats very differently. A sequence that tends to work:

  1. Audit your current site against the disclosure checklist first, since missing business-identity information, an inaccessible terms-of-use link, or an absent verification page are the most easily fixed and most commonly flagged gaps.
  2. Review every promotional price, discount claim, and “limited time” banner against what you can actually substantiate, rather than assuming a promotional convention that’s unremarkable in another market will read the same way to Korean regulators.
  3. Walk your own checkout flow specifically looking for the five dark-pattern categories, particularly pre-checked add-ons and any gap between how easy it is to subscribe versus how easy it is to cancel — this is the area under the most active current enforcement.
  4. Confirm your order-review step actually lets a consumer see and correct their order before payment is finalized, not just before the cart is submitted, since a flow that auto-completes the charge doesn’t satisfy the pre-contract confirmation requirement.
  5. Rewrite your return, refund, and subscription-cancellation policies for the Korean statutory framework specifically, including the seven-day withdrawal window and the three-business-day refund clock, rather than translating a home-market policy.
  6. Treat dark-pattern compliance as a design requirement owned jointly by legal and product teams, not a policy document, since the current enforcement wave is targeting interface behavior directly rather than what a terms-of-service page says.