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[PIPA] Amendment Passes National Policy Committee: Record-High Penalty Risk Emerges

Related AreasAI/IT · Violation of Personal Information Protection Act · ESG Management

2025.Dec

Dec.2025
Personal Information Protection Act amendment clears the National Policy Committee: record-level fine risk emerges
Data Protection Alert

[Personal Information Protection Act] PIPA Amendment Clears the National Policy Committee: Unprecedented Surcharge Risk Emerges

The era of large-scale data breaches and fines of 10% of revenue has arrived.

The National Assembly has amended the Personal Information Protection Act to allow surcharges of up to 10% of revenue to be imposed on companies responsible for serious personal data breaches. This is a sanction strengthened more than threefold from the previous 3%, and personal data incidents are no longer a matter for the security team alone but a company-wide legal risk directly tied to management accountability. A structure is becoming reality in which repeated violations of the Personal Information Protection Act, large-scale breaches, and failure to comply with corrective orders lead not only to surcharges but also to damages and criminal liability. Companies have now entered an era in which they are evaluated by their management systems before an incident, rather than their response after one. We summarize the key points of this amendment and the response measures companies must review.

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Daeryun in the Press

News1

Coupang's “Half-Baked” Hearing Missing the Core: Where Is the Political “Grudge Charge” Headed?
Coupang's “Half-Baked” Hearing Missing the Core: Where Is the Political “Grudge Charge” Headed?

Ahead of a hearing on the data breach affecting 33 million people, key Coupang figures including Chairman Kim Bom-suk notified that they would not attend. In response, Daeryun's attorney Jang Ji-woon noted the limits of compulsory investigation against foreigners residing abroad and emphasized that the only path is the bold decision for Chairman Kim himself to attend voluntarily amid public pressure. The National Assembly has signaled strong follow-up legislation to hold such defiance to account.

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The Coupang data breach and the case for punitive damages: why it can no longer be delayed
The Coupang data breach and the case for punitive damages: why it can no longer be delayed

In response to the Coupang affair, in which the breach was left unaddressed for five months, our firm has begun reviewing a local class action against Coupang's U.S. headquarters. Drawing on his experience with the SKT lawsuit, Daeryun's attorney Son Gye-jun emphasized that strong punitive damages are necessary to break companies' complacent calculus, and stated that he would hold them accountable to the end on behalf of the citizens who suffered harm.

Daeryun Law LLC newsletters are provided to deliver general legal information to clients quickly and accurately. The content herein does not represent the official views of Daeryun Law LLC, nor does it constitute legally binding legal advice on specific matters. For specific inquiries, please consult with the attorneys and specialists at Daeryun Law LLC.

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