Korea Strengthens Content Dispute Resolution, Introducing Collective Mediation for Game User Disputes

Why It Matters

The framework gives Korean gamers a faster, coordinated remedy for systemic harms while pressuring game publishers to adopt stronger compliance and risk‑management practices.

Key Takeaways

• Collective mediation triggers for 50+ game users.
• Minister can request mediation ex officio for reported damage.
• CDRC panels up to five members; small cases single commissioner.
• Litigation stays allow mediation despite ongoing lawsuits.
• Companies must document probability item decisions to avoid class actions.

Pulse Analysis

South Korea’s gaming sector, long a global revenue engine, has faced mounting scrutiny over opaque probability‑based items and service interruptions. By revising the Content Industry Promotion Act’s Enforcement Decree, regulators aim to modernize dispute resolution, aligning it with consumer‑protection trends seen in the EU and US. The collective mediation model mirrors class‑action mechanisms, but offers a government‑facilitated, faster path to compensation, reducing court congestion and signaling a shift toward administrative adjudication for mass‑impact grievances.

The amendment empowers the Content Dispute Resolution Committee to convene mediation panels of up to five experts, while delegating minor claims (under KRW 3 million) to a single commissioner. Crucially, the Minister of Culture, Sports and Tourism can now invoke mediation ex officio when damage is reported, and the CDRC may recommend compensation plans even for non‑participants. By allowing courts to stay litigation in favor of mediation, the system creates a hybrid avenue where parties can resolve disputes without forfeiting legal rights, fostering a more predictable outcome for both users and developers.

For game publishers, the reforms raise the stakes of compliance. Proactive documentation of probability‑item design, legal review, and transparent disclosure become essential to avoid being swept into a collective mediation that could trigger class‑action exposure. The ability to refuse mediation now carries the risk of mandatory court‑ordered settlements, prompting firms to invest in internal dispute‑prevention frameworks. As other jurisdictions watch Korea’s approach, the move may set a benchmark for industry‑wide standards on fair‑play, consumer redress, and regulatory collaboration.

Korea Strengthens Content Dispute Resolution, Introducing Collective Mediation for Game User Disputes

By Doohyun “Biit” Lee · Feb 4, 2026

Law Firm Hwawoo projected on the 4th that the amended Enforcement Decree of the Content Industry Promotion Act, which took effect on the 1st, will serve as a major turning point in resolving game‑related disputes. The centerpiece of the amendment is the strengthening of the Content Dispute Resolution Committee (hereinafter “CDRC”) and the introduction of a collective dispute mediation system for cases involving 50 or more victims.

Collective dispute mediation may be requested when the number of affected users is 50 or more, and the key issues of the case are substantially common in fact or in law. However, those who have already reached an individual settlement, or who have filed a lawsuit in court, are excluded from eligibility to apply. If the CDRC decides to commence mediation, it must publicly announce the initiation and set a period of at least 14 days, during which other affected parties may also apply to join as additional participants. Even if certain parties are excluded after the procedure begins—bringing the number of users below 50—the procedure will continue.

The authority of the Minister of Culture, Sports and Tourism has also been expanded. If the minister determines that relief is necessary for a matter reported as 피해 (damage) under the Game Industry Promotion Act, the minister may request collective dispute mediation from the CDRC ex officio. The CDRC may also recommend that a business operator submit a compensation plan even for victims who are not parties to the collective dispute mediation, and the business operator must notify the CDRC within 15 days of receiving the recommendation whether it will accept it.

The CDRC’s organizational and operational framework has also been overhauled. To enable more professional and prompt dispute resolution, it may now operate mediation panels composed of up to five members, and small‑amount cases involving KRW 3 million or less will be handled by a single commissioner. The provision in the previous regulations that treated the filing of a lawsuit—or the pendency of litigation—as grounds for refusing mediation has been deleted. The CDRC may inquire with the court as to whether litigation proceedings should be stayed, and if the court grants such a stay, resolution through mediation becomes possible.

With the introduction of this system, protection for game users is expected to be strengthened. Hwawoo analyzed that, in conjunction with the special litigation provisions for probability‑based items set to take effect from August 2025, the system could serve as a practical relief mechanism in disputes involving collective harm—such as violations of probability disclosure requirements or the suspension of game services. At the same time, game companies will bear the burden of having to resolve disputes with large numbers of users in a single mediation proceeding.

Hwawoo advised that it is important for game companies to build proactive dispute‑prevention systems. Hwawoo explained, “Companies should document their decision‑making processes across the entire lifecycle of probability‑based items—planning, operation, and probability adjustments—and make prior review by the legal team mandatory.” The firm added, “Once collective dispute mediation begins, refusing to participate in mediation or rejecting the outcome could lead to class‑action litigation, so swift and strategic decision‑making is required.”

This article was translated from the original that appeared on INVEN.

Contact: Doohyun “Biit” Lee – [email protected]