Domestic Agent in Korea for PIPA Compliance

Processing the personal information of Korean users without a local entity may require appointing a locally reachable representative in Korea.

Under Korea’s Personal Information Protection Act (PIPA) (including Article 31-2 and related Enforcement Decree provisions), certain overseas personal information controllers must designate a Domestic Agent (Local Representative). KOISRA UP provides a focused Domestic Agent service that delivers the statutory minimum, with the option to extend the scope by contract—so you stay compliant while retaining operational control of your data governance.

Who Needs a Domestic Agent

The requirement generally applies to overseas companies that:

• Do not maintain a domicile or place of business in Korea (no registered branch or office); and
• Meet at least one threshold set by the Enforcement Decree (e.g., sales volume, Korean user volume), or are required to designate a Domestic Agent by the regulator due to a regulatory process or concern.

Common threshold triggers include:

• Annual global sales: KRW 1 trillion or more (converted using the prior-year average exchange rate); or
• Korean user volume: a daily average of 1 million or more domestic data subjects whose personal information is stored/managed over the immediately preceding 3 months (as of the end of the previous year); or
• Regulatory order / case context: where the Personal Information Protection Commission (PIPC) determines a Domestic Agent is needed in connection with its investigation-related processes.

Note regarding Korean subsidiaries/affiliates (effective October 2, 2025):
If you have a Korean subsidiary or affiliate over which you exercise “significant influence,” you may be required to designate that entity as your Domestic Agent rather than appointing an unrelated third party.

When the local entity is a “paper company”:
If your Korea entity has no employees or operational capacity, it may not be able to practically fulfill the statutory duties of a Domestic Agent (e.g., receiving calls, handling grievances, and coordinating timely remedial procedures). In this scenario, an outsourced operating model may be workable: your Korean subsidiary remains the legally designated Domestic Agent, but it can formally contract KOISRA UP to execute the operational duties—such as answering the phone, coordinating regulatory submissions, and managing grievance intake and routing—on the subsidiary’s behalf, under agreed procedures and reporting lines.

For more information about the requirement, please check our insight: [Korea PIPA Domestic Agent Requirements for Foreign Companies]

What a Domestic Agent Does (Statutory Minimum)

By law, the Domestic Agent is a locally reachable representative that facilitates required interactions and disclosures in Korea. Unless otherwise agreed by contract, the agent is not your global Chief Privacy Officer (CPO) or DPO; the agent functions as your Korea-based compliance contact point and execution conduit for defined statutory tasks.

• Regulatory communications and materials submission: Receive and coordinate responses to PIPC inquiries, reports, and inspection demands, including routing and organizing required materials and documentation.
• Data subject requests and grievance handling: Receive and triage requests/complaints from Korean data subjects (e.g., access, correction, deletion), route them to your global privacy team for fulfillment, and ensure timely communication of outcomes and remedial steps.
• Incident and breach response coordination: Serve as a Korea contact point during incidents and support the notification/reporting workflow. Under the Enforcement Decree, data subjects must generally be notified within 72 hours of becoming aware of a breach, and reporting to the PIPC (or the designated institution) is required within 72 hours for certain cases (e.g., breaches affecting 1,000+ data subjects, involving sensitive/personal identification information, or caused by illegal external access).
• Local reachability and disclosure: Maintain Korea contact channels (address, domestic phone, email) reachable during business hours, and ensure your Korea-facing privacy policy accurately discloses the Domestic Agent’s details.

Practical reachability matters:
A Domestic Agent must be able to actually receive and handle communications and coordinate remedial steps. For example, relying only on an automated recording or a generic email/form—without staff able to respond and coordinate complaint handling or remedial procedures—may be viewed as insufficient in practice.

Scope note:
Our role as Domestic Agent covers PIPA compliance contact and statutory coordination only. We do not provide general customer service, technical security audits, or global DPO/CPO functions unless expressly included by contract.

KOISRA UP Domestic Agent Service in Korea

We deliver the statutory minimum with a clear pathway to extend scope by contract when additional governance support is needed. The default service package includes:

• Designation and documentation: Formal written appointment as your Domestic Agent; designation confirmation for your records; guidance and a ready-to-use disclosure block for your Korea privacy policy (name, address, phone, email).
• Regulatory interface: A named Korea point-of-contact for authority communications; intake, triage, routing, and timely coordination of responses to the PIPC.
• Grievance coordination: Reception of user rights requests via dedicated local channels and routing to your global privacy team for execution, with structured follow-up and closure communication.
• Recordkeeping: Organized logs of inbound requests, submissions, and supporting evidence to strengthen traceability and audit readiness.

Optional extensions (by contract):

• Annual tabletop breach-response drills to validate the 72-hour workflow and escalation paths.
• Localization support for data inventories and “book of flow” style documentation for regulator readiness.
• Quarterly verification of privacy policy disclosures (links, contact routes, and disclosure accuracy).

How It Works

• 1) Scoping: We review your Korean user volume, global revenue triggers, and corporate structure (including any Korea subsidiary/affiliate considerations).
• 2) Contract and designation: We finalize a service agreement reflecting the statutory minimum and issue the formal written designation.
• 3) Privacy policy update: We provide the exact disclosure text block and confirm that phone/email channels route correctly.
• 4) Operating rhythm: We align responsibilities for DSAR fulfillment, incident escalation paths, and documentation availability for audit defensibility.
• 5) Live operations: We act as your Domestic Agent, handle Korea-facing communications, coordinate responses, and maintain a defensible audit trail.

Why KOISRA UP

• Focused compliance execution: Designed around the statutory minimum, with modular extensions when needed.
• Established operations in Korea: Supporting and representing foreign companies and global brands with practical, execution-first delivery.
• Representation you can rely on: Proven experience acting as a local representative and liaison across regulated and compliance-sensitive sectors.
• Bilingual, business-first communication: Korean ↔ English communication with regulators and stakeholders, plus clear updates for global teams.
• Functional contact channels: Built to maintain real reachability and responsiveness—reducing non-compliance risk tied to “paper-only” arrangements.
• Structured processes: Defined intake, response, escalation, and recordkeeping workflows to support audit readiness and predictable turnaround.
• Market familiarity: Practical understanding of PIPC expectations and cross-border personal data compliance considerations.