
It has been confirmed that the Korea Association of Game Industry (K-GAMES) has conveyed to the National Assembly its opposition to adding new regulations under a proposed amendment to the Game Industry Promotion Act, which would mandate disclosure of the use of generative artificial intelligence (AI).
The amendment, introduced by Rep. Kim Seong-won of the People Power Party as the lead sponsor, would require game developers to indicate whether generative AI was used in the production of a game. It also includes penalties for damaging or altering such disclosures: an administrative surcharge of up to KRW 1 billion, imprisonment for up to two years, or a fine of up to KRW 20 million.
In its written opinion, the Korea Association of Game Industry stated that a general law that took effect in January already stipulates an obligation to indicate whether content was AI-generated, and therefore assessed that the game industry is likely to bear the relevant obligations in the first instance. The association made clear that, separate from compliance with existing laws, it opposes creating a duplicate obligation in the Game Industry Act.
The association argued that adding regulations through sector-specific laws could create problems such as confusion over compliance standards, duplication of regulatory costs, and unclear divisions of responsibility among government ministries. It also pointed out that, in the absence of specific criteria defining the level of AI involvement in final content that would trigger the disclosure obligation, a regime centered on strong sanctions would be excessive.
In its opinion letter, the Korea Internet Corporations Association (K-Internet) argued that a preemptive regulatory disclosure mandate could hinder the development of the game industry as a whole. As grounds, it cited major overseas legislative examples—such as the EU AI Act and California regulations in the United States—where creative-content areas such as games are excluded from coverage or regulated only in a limited manner.
The Ministry of Culture, Sports and Tourism also stated that the obligation to label AI-generated content is expected to be governed under the Framework Act on the Development of Artificial Intelligence and the Creation of a Foundation for Trust (commonly referred to as the AI Basic Act) and the Act on Promotion of Information and Communications Network Utilization and Information Protection, and therefore could amount to duplicate regulation; it added that a comprehensive review is necessary.
The National Assembly’s Senior Specialist Committee Office likewise assessed that the sanction level in the amendment is relatively higher than the AI Basic Act’s administrative fine of up to KRW 30 million, and said further discussion is needed on whether there is a sufficient basis to impose heavier penalties only on game businesses.
This article was translated from the original that appeared on INVEN.
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