[Game & Digital Content Licensing ③] Where Should You Apply for a Game Rating in Korea? — Steam, Google Play, App Store, and Adults-Only Games

Hello, I'm Jean Ji, a Korean administrative attorney.

Imagine a game company preparing to launch a new title on October 30, 2026.

The PC version will be released on Steam, while the mobile version will launch simultaneously on Google Play and Apple's App Store.

Development is nearly complete. The publisher and marketing schedule have already been confirmed.

Then the person responsible for regulatory compliance asks a question:

"It's the same game. Can't we obtain one rating and use it everywhere?"

A search for the Korean rating authority produces two different organizations: the Game Rating and Administration Committee and the Game Content Rating Board.

Other sources suggest that mobile games can be rated directly through app stores.

To complicate matters, responsibility for adults-only PC games changed in 2025, and a further transfer of mobile game rating responsibilities is planned for 2026.

The company must determine where to apply before proceeding.

This is not simply a question of identifying the correct government agency.

Choosing the wrong application route or overlooking a required procedure may put the planned Korean launch date at risk, even when development is complete.

As of September 20, 2026, developers of ordinary PC and console games should examine the scope of the Game Content Rating Board's delegated authority.

For mobile games, the first question is whether the title qualifies for self-rating. Adults-only mobile games currently follow the direct rating route through the Game Rating and Administration Committee.

When releasing a game on multiple platforms, developers must also determine whether an existing rating remains valid and complete each platform's separate publication requirements.

This article explains how to identify the appropriate rating authority, assess existing ratings, and prepare for a simultaneous launch on Steam, Google Play, and the App Store.

The discussion follows a hypothetical company, Company A.

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Game & Digital Content Licensing Series

1. Do game developers and publishers need separate business registrations?
2. When should you apply for a game rating in Korea?
3. Where should you apply for a game rating? — This article
4. Does updating a released game require a new rating?
5. What must developers disclose when offering probability-based items?
6. Who handles Korean regulatory procedures for games developed overseas?
7. What happens when a company's representative, address, or registered business details change?
8. Is closing a game business as simple as canceling its business registration?
9. What happens to existing registrations when acquiring a game company or business?

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1. How Do You Determine the Appropriate Game Rating Authority in Korea?

The appropriate rating procedure depends on the game's actual content, age category, and distribution structure.

Developers cannot simply choose whichever rating authority is more convenient.

Article 21 of Korea's Game Industry Promotion Act (게임산업진흥에 관한 법률) establishes the general framework for game rating.

Article 21-2 governs designated self-rating business operators, while Article 24-2 addresses the delegation of rating responsibilities.

As of September 20, 2026, the main routes for commercial games can be divided into four categories.

① Ordinary PC and console games

Developers should determine whether the game falls within the delegated authority of the Game Content Rating Board.

Adults-only PC and console games were added to its delegated responsibilities on November 1, 2025.

However, statutory exclusions must be considered. A game may also fall within the scope of a designated self-rating operator, depending on its rating category and distribution arrangements.

② Mobile games with general age ratings

If a mobile game falls within the permitted scope of a designated self-rating operator, the developer may use that operator's rating procedure.

Eligibility depends on the actual content and applicable rating requirements.

③ Adults-only mobile games

Adults-only games are excluded from the self-rating system.

As of September 20, 2026, the additional transfer of mobile rating responsibilities has not yet taken effect.

Developers should therefore prepare for the direct rating route through the Game Rating and Administration Committee under the procedures currently in force.

④ Arcade games and other games excluded from delegated rating

Games intended for arcade establishments and certain statutorily excluded categories require separate consideration.

Developers must determine whether the Game Rating and Administration Committee has direct jurisdiction and whether any grounds for refusing classification apply.

A particularly important distinction is that self-rating is not exclusively a mobile game system.

PC games may also qualify when they are distributed by an appropriately designated operator and satisfy the relevant conditions.

However, Article 21-2 excludes adults-only games from self-rating.

The appropriate application route cannot be determined by platform alone. The game's actual content and anticipated age rating must be assessed first.

Let us apply these principles to Company A.

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2. Where Should Company A Apply for Its Adults-Only PC Game on Steam?

Company A has developed an action game for PC.

It plans to release the title on Steam and expects an adults-only rating because of its violent content.

A developer familiar with Korea's previous procedures might initially consider applying to the Game Rating and Administration Committee.

However, the division of responsibilities has changed.

The authority for adults-only PC and console games changed on November 1, 2025

On October 24, 2025, the Game Rating and Administration Committee entered into an additional delegation agreement with the Game Culture Foundation.

Under this arrangement, the Game Content Rating Board, an organization affiliated with the foundation, assumed additional responsibility for rating adults-only PC and console games.

The change took effect on November 1, 2025.

Applications submitted to the previous authority by October 31, 2025, remained under its responsibility. Applications submitted from November 1, 2025, were directed to the Game Content Rating Board.

Certain categories remain excluded from this delegation, including specified games that simulate gambling activities without directly providing actual financial gains or losses.

Source: Game Content Rating Board, November 4, 2025, official notice concerning the additional delegation of adults-only PC and console game rating responsibilities.

Accordingly, Company A should examine whether its PC action game falls within the Game Content Rating Board's delegated scope.

There is another distinction worth noting.

Responsibility for content modification reports concerning existing adults-only PC and console games previously rated by the Game Rating and Administration Committee was scheduled to transfer on December 1, 2025.

The effective dates for initial rating applications and content modification reports were therefore different.

This historical distinction does not directly affect Company A's new release, but it matters to developers managing games that received ratings before the transfer.

The authority that issued an original rating should not automatically be assumed to handle every subsequent administrative procedure.

Does obtaining a Korean rating mean the game is ready for release on Steam?

No.

Korea's statutory game rating and Steam's publication review are separate processes.

Steam reviews a game's store page and its actual game build.

According to Steamworks documentation, each review generally takes three to five business days.

Steam recommends allowing at least seven business days for review and possible corrections. Adult content may require additional time.

Source: Steamworks, "Review Process."

These estimates concern Steam's own review procedures.

They do not include the processing time required by the Korean game rating authority.

Company A must therefore coordinate both processes.

Obtaining a Korean rating does not automatically complete Steam's review.

Likewise, receiving Steam's approval does not establish that the Korean statutory rating requirements have been satisfied.

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3. Where Should the Adults-Only Mobile Version Be Rated?

Now consider Company A's mobile version.

Assume that the PC and mobile versions contain substantially similar content and are both expected to receive an adults-only rating.

The company has already identified the Game Content Rating Board as the relevant authority for its PC version, subject to the statutory exclusions.

Can it submit the mobile version to the same organization?

As of September 20, 2026, the mobile version must be assessed under the division of responsibilities currently in effect.

The additional delegation concerning adults-only PC and console games has already taken effect.

However, the second phase of the transfer involving mobile games has not yet been implemented.

Has the transfer scheduled for November 2026 already been finalized?

In an official announcement dated September 14, 2026, the Game Content Rating Board described the second phase of the transfer as scheduled for November 2026.

It also announced a related professional seminar scheduled for October 29–30.

Source: Game Content Rating Board, September 14, 2026, "GRIN 2026, BUSAN" seminar announcement.

A planned transfer date must not be confused with an implemented transfer.

Developers need to check the final official announcement, effective date, and application acceptance arrangements before relying on a new procedure.

Company A plans to release its game on October 30.

Under the arrangements in force as of September 20, its adults-only mobile game follows the direct rating route through the Game Rating and Administration Committee.

The company should not postpone its application merely because a transfer is expected in November.

Conversely, developers planning to submit new applications after November must verify whether the transfer has actually taken effect and when the new authority begins accepting applications.

Company A's initial application routes can now be distinguished:

• Adults-only PC version: Examine the delegated rating route through the Game Content Rating Board.
• Adults-only mobile version: Follow the currently applicable direct rating route through the Game Rating and Administration Committee.

The same title may therefore involve different rating authorities depending on the platform and application date.

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4. What Must Developers Do on Google Play and the App Store After Obtaining an Official Rating?

Assume that Company A has obtained the official Korean rating required for its mobile game.

The game has received an adults-only classification.

Can the company now publish it on Google Play and the App Store without completing any additional procedures?

Not necessarily.

The official Korean rating and each platform's publication requirements must be treated separately.

Google Play requires official rating documentation for certain games in Korea

Google Play states that developers publishing games unsuitable for users under 19 in Korea must obtain an official rating certificate from the Game Rating and Administration Committee.

It also identifies rating documentation requirements for games containing gambling or casino-style elements.

Google warns that games without the required documentation may be unavailable for distribution in Korea or removed from Google Play.

Source: Google Play Console Help, "Requirements for distributing apps in specific countries/regions."

Company A should obtain the relevant official rating documentation and complete Google Play's certification and content rating procedures.

The Korean statutory rating should not be confused with the global content rating used by an app marketplace.

The developer must confirm which rating information will actually apply to users in Korea.

Apple changed how official Korean ratings can be reflected in the App Store in August 2026

On August 12, 2026, Apple announced changes concerning age ratings in the Korean App Store.

Developers whose apps have received an official Korean rating can submit a Rating Classification Number (RCN) to align the Korean App Store age rating with that official classification.

The available Korean classifications include:

• All Ages
• Ages 12 and Up
• Ages 15 and Up
• Adults Only

The developer enters the rating classification number in the Korean age rating section of App Store Connect and selects the appropriate official rating.

To apply the updated rating, the developer must submit a new app version and complete the applicable app review process.

Sources: Apple Developer, August 12, 2026, announcement on age rating updates in South Korea; App Store Connect guidance on setting app age ratings.

Company A must therefore confirm that its official rating has been correctly reflected in the Korean App Store.

The submitted rating classification number and associated registration information must match the official rating.

The essential distinction is this:

Obtaining a statutory Korean rating is not the same as completing the publication requirements of Google Play and the App Store.

Releasing a mobile game on two app marketplaces does not automatically mean that two separate government rating applications are always required.

Equally, obtaining one official rating does not automatically complete the registration and review requirements of both marketplaces.

Company A must verify the validity of its statutory rating and the publication readiness of each platform separately.

What changes if the mobile game qualifies for an age-15 rating?

Consider a separate scenario.

Company A modifies the mobile game's actual content so that it qualifies for a 15-and-up rating rather than an adults-only rating.

If the game falls within the permitted scope of a designated self-rating operator, that operator's procedure may be available.

Article 21-4(1) of the Game Industry Promotion Act provides that a game rated by a designated self-rating operator is treated as having received a rating from the Game Rating and Administration Committee.

However, the same provision also requires a new rating when another designated self-rating operator intends to distribute the game.

Does this mean that every subsequent storefront requires the developer to complete an identical questionnaire from the beginning?

Not necessarily.

Google Play uses the International Age Rating Coalition (IARC) system.

According to IARC's guidance, an existing certification code can generally be reused when the same game is submitted to another participating storefront.

For storefronts that do not participate in IARC, the applicable storefront-specific procedures or statutory rating requirements must be followed.

Source: International Age Rating Coalition, "FAQ."

Apple maintains its own age rating questionnaire in App Store Connect.

Consequently, obtaining an IARC certification code through Google Play does not automatically complete the App Store's requirements.

Developers must distinguish two questions:

First, how far does an existing rating remain legally valid?

Second, how can that rating be used or processed by another distribution platform?

Separating legal rating validity from a storefront's technical procedures is essential to identifying unnecessary duplicate applications without overlooking mandatory steps.

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5. Can an Existing Rating Be Used When the Platform or Monetization Model Changes?

Identifying the responsible authority is not always the first issue.

Before choosing an application route, a developer may need to determine whether the PC and mobile versions are sufficiently equivalent for rating purposes.

Imagine that Company A sells its PC version as a paid game.

The mobile version, however, is free to download and generates revenue through in-game item purchases.

The core combat system and graphics remain substantially similar.

Can the company automatically reuse the PC version's existing rating for the mobile version?

Not necessarily.

Changes in actual content or operation may require an examination of whether the game remains consistent with the version originally submitted for rating.

A Korean Supreme Court decision illustrates why operational differences matter.

A free mobile game converted into a paid arcade game — Supreme Court Decision 2021Do4785

In a judgment delivered on July 21, 2021, the Supreme Court considered a case involving a game originally rated as a free mobile title.

The game was subsequently provided through an arcade-style machine installed at a PC gaming venue.

Users inserted KRW 10,000 in cash to play for three minutes.

The Supreme Court considered not only the game's content but also operational methods closely related to how that content was implemented.

The Court explained that providing a game under operating conditions different from those described in the rating application or game content description could constitute providing a game different from the version that had received a rating.

In this case, converting a free mobile game into a paid arcade game affected users' ability to participate, the extent of their gameplay, and the game's gambling-related characteristics.

The Supreme Court found an error in the lower court's legal reasoning and remanded the case.

Source: Supreme Court of Korea, July 21, 2021, Decision 2021Do4785.

This judgment concerned a specific conversion from a free mobile game to a paid arcade game.

It does not mean that every difference between a paid PC game and a free-to-play mobile game constitutes a violation.

Nor did the judgment directly determine which rating authority handles PC or mobile applications.

Its relevance is more specific.

A game title and similar graphics are not enough, by themselves, to establish that an existing rating can be used for a different version.

Developers must compare the content originally submitted for rating, the actual operating arrangements, and the modifications introduced for another platform.

Article 21-4(3) of the Game Industry Promotion Act is also relevant.

It addresses circumstances in which a game is modified for a change of information and communication platform without changes substantial enough to require a different age rating, allowing the existing self-rating to retain its effect within the prescribed scope.

Company A should therefore document the differences between its PC and mobile versions before deciding which rating procedure applies.

It must then determine whether the existing rating remains effective, whether a new rating is required, and which application route should be used.

That is the difference between merely finding the name of a rating authority and establishing the appropriate regulatory procedure for an actual game release.

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6. Poker, Go-Stop, and Betting Games: What Must Be Examined Before Choosing a Rating Authority?

The examples so far have focused on an ordinary action game.

The order of analysis changes when a game includes poker, Go-Stop, betting, or other gambling-related elements.

The game's legal characteristics must be examined first.

The Game Industry Promotion Act distinguishes gambling-related games involving actual financial gains or losses from certain games that simulate gambling activities without directly producing those gains or losses.

Developers must therefore examine not only whether a game is excluded from delegated rating but also whether it may fall into a category for which rating can be refused.

Two decisions illustrate why the actual operating structure matters.

An existing rating may become subject to cancellation — Supreme Court Decision 2017Du38973

In a judgment delivered on June 28, 2018, the Supreme Court considered the cancellation of a rating for an arcade game modeled on a slot machine.

Gaming establishments issued certificates recording users' points.

These certificates were traded between users, and points were exchanged for cash at some establishments.

The Supreme Court held that determining whether a device fell within the relevant gambling-related category required consideration of its characteristics, actual purposes and methods of use, financial or convertible rewards, and business practices such as cash conversion.

The Court applied this approach to the legality of the rating cancellation and remanded the case.

Source: Supreme Court of Korea, June 28, 2018, Decision 2017Du38973.

This was a case involving a particular arcade game.

The conclusion cannot automatically be applied to every PC or mobile title.

Nevertheless, it demonstrates that actual operating arrangements can become relevant even after a rating has been granted.

Simulating betting does not necessarily lead to the same outcome in every case

A separate administrative appeal was decided by Korea's Central Administrative Appeals Commission on August 6, 2013.

The case concerned sports-related games in which users predicted the results of real sporting events and received distributions of in-game currency.

The Commission examined whether users purchased betting tickets with cash, whether cash refunds were paid according to match results, and whether in-game currency could be exchanged for cash.

It found the refusal to rate the relevant football game and the delay in deciding the rating of a basketball game unlawful or improper and ordered the relevant rating decisions to be made.

Source: Central Administrative Appeals Commission, August 6, 2013, Case 2013-07420.

These decisions concerned different games under the legal frameworks applicable at the time.

Neither establishes a general rule that all games within a particular genre must receive the same classification outcome.

For poker, Go-Stop, and betting-related titles, developers should first examine:

• How in-game currency is purchased, used, and transferred.
• Whether users receive financial benefits.
• Whether points or in-game assets can be converted into cash.
• How the game actually operates after release.

The game's legal characteristics and appropriate application route should be determined after these matters are clarified.

If the game itself falls within a category subject to refusal of rating, submitting the application to a different authority will not resolve that underlying issue.

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7. An October 30 Simultaneous Launch: What Should Company A Do, and in What Order?

Return to Company A's launch plan.

The target date is October 30, 2026.

The PC version will launch on Steam.

The mobile version will launch on Google Play and the App Store.

Both versions are expected to receive adults-only ratings.

The company's first task is not to decide how many application forms to submit.

It must finalize the actual release versions and establish a sequence that allows the required ratings and platform reviews to be completed before launch.

Step 1. Finalize the actual game content

The development team should identify the release builds for PC and mobile separately.

It should compare the principal content and any elements involving violence, sexual content, or gambling-related mechanics.

Differences in monetization and operating arrangements should also be documented.

If the company has an existing rating, it should compare the documents originally submitted with the version now intended for release.

This provides the factual basis for deciding whether the existing rating can be used or a new rating is necessary.

Step 2. Identify the application route and responsible applicant

For the PC version, Company A should determine whether the game falls within the delegated authority of the Game Content Rating Board.

For the adults-only mobile version, it should prepare according to the current direct rating procedure of the Game Rating and Administration Committee.

Any statutory exclusions should be examined at the same time.

If the developer and publisher are separate companies, the parties must clarify who will be the proper applicant.

They should also assign responsibility for preparing materials and responding to requests for supplementary documents.

However, appointing an internal project manager is not the same as establishing the legally appropriate applicant.

The distribution agreement and the relevant authority's application requirements should be examined together.

Only after these matters are resolved can the company identify what must be submitted and by whom.

Step 3. Check Steam's 30-day and 14-day requirements

Steam applies a waiting period of 30 days between payment of the app fee and release for developers publishing their first few games.

New games must also have a publicly visible Coming Soon page for at least two weeks before launch.

For an October 30 release, Company A should arrange for its Coming Soon page to be publicly available no later than October 16 if it intends to satisfy the minimum two-week period.

Preparing earlier allows additional room for the precise publication time and potential delays.

The store page must pass Steam's review before it can be published.

Any applicable 30-day waiting period must be calculated separately.

For a company beginning its preparations on September 20, 2026, the app fee payment date and the applicable waiting-period requirements should be checked immediately.

These are Steam platform requirements.

They are not the statutory processing periods for Korean game classification.

Source: Steamworks, "Steamworks Partner Program."

Step 4. Confirm the actual meeting and review schedules of the Korean authorities

On September 18, 2026, the Game Content Rating Board announced a change to its meeting schedule because of the Chuseok holiday.

Its 24th rating meeting was rescheduled to October 2, 2026.

Source: Game Content Rating Board, September 18, 2026, official notice concerning rating meeting schedule changes during Chuseok.

The existence of an October 2 meeting does not guarantee that Company A's application will be considered or decided on that date.

The company must verify application acceptance dates, meeting schedules, completeness of its documents, and the possibility of requests for additional information.

For the adults-only mobile version, it must separately confirm the Game Rating and Administration Committee's current application procedures and review schedule.

A company targeting October 30 should not plan on completing every review immediately before launch.

Step 5. Confirm release readiness on all three platforms

For the PC version, Company A should confirm that both the Korean rating and Steam's store-page and build reviews have been completed.

For the mobile version, it should compare the official Korean rating documentation against Google Play's certification and registration requirements.

On the App Store, it should confirm that the official rating classification number and Korean age rating have been entered and reflected correctly.

If the change requires a new app version and further review, those steps must also be completed.

The company should proceed with launch only after confirming that all three platforms are ready for distribution in Korea.

This sequence reveals an important distinction.

Publishing one game on three platforms does not automatically require three separate government rating applications.

But having one game title does not automatically mean that one rating is sufficient in every situation.

The correct approach is to establish the scope of any existing rating, identify the actual distribution arrangements, and complete the procedures applicable to each release channel.

This helps the company distinguish unnecessary duplicate applications from mandatory steps while managing its launch schedule.

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8. Does Regulatory Compliance End Once the Game Has Been Rated and Released?

Assume Company A has obtained the necessary ratings.

Its Steam, Google Play, and App Store reviews are complete.

Is its rating-related work finished?

Not entirely.

Completing the initial rating process is different from ensuring that the game continues to operate consistently with its classification.

Article 21-9 of the Game Industry Promotion Act provides a mechanism through which the Game Rating and Administration Committee may require rating adjustments when self-rating results significantly conflict with the applicable standards or differ between operators.

Monitoring activities illustrate the scale of post-rating oversight.

Approximately 117,000 self-rated games were inspected in 2025

According to the results announced for the Game Rating and Administration Committee's 2025 monitoring program, approximately 200 monitors examined a total of 117,000 games during the year.

The Committee planned to review the findings and pursue follow-up measures.

At the time of the announcement, approximately 7,000 administrative measures were expected by December.

Source: NewsPim, December 3, 2025, report on the conclusion of the 2025 self-rated game monitoring program.

The figures must be interpreted carefully.

The 117,000 figure represents the reported number of inspections, not the total number of games released in Korea.

The approximately 7,000 measures were a projection at the time of the announcement, not a confirmed count of final penalties or proven violations.

The relevant point is that self-rated games can remain subject to monitoring after their initial ratings have been issued.

Imagine that Company A subsequently strengthens violent content or introduces new gameplay features.

It must then determine whether the game being offered to users remains consistent with its existing rating.

Article 21(5) and the following provisions of the Game Industry Promotion Act address reporting modifications to game content and related reclassification procedures.

The appropriate procedure may depend on the nature and extent of the changes.

A developer should not automatically assume that its original rating remains sufficient after modifying the game.

Rating compliance is not merely a one-time step before pressing the release button.

The original rating documents and the game currently offered to users must remain aligned.

The detailed rules for game updates and content modification reporting will be addressed separately.

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When Can Developers Prepare Applications Independently, and When Is Professional Review Useful?

Developers may be able to prepare rating applications independently when the game's content, anticipated rating category, and applicable procedure are clear.

They can review the authority's official guidance, assemble the required game descriptions, identify relevant content, and prepare gameplay footage and other supporting materials.

The situation becomes more complex when a title is distributed on multiple platforms or an existing rating is intended to be used for another version.

Additional questions may arise when:

• The PC and mobile versions have different content or monetization models.
• Development and publishing responsibilities are divided between different companies.
• The anticipated rating is adults-only.
• The game includes gambling-related elements.
• The validity of an existing rating is uncertain.

In these circumstances, the central issue is not simply preparing an application form.

It is determining whether an existing rating can be used, whether a new rating is required, which authority has jurisdiction, who should apply, and how the necessary procedures affect the launch schedule.

Within the lawful scope of administrative practice in Korea, an administrative attorney can assist with reviewing application routes, preparing supporting documentation, and coordinating relevant administrative procedures.

Professional review does not guarantee a particular age rating or approval outcome.

Its practical value lies in clarifying the applicable procedures before submission and identifying potential duplication or omissions.

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Conclusion: Where Should You Apply for a Game Rating in Korea?

Return to Company A's original question:

"It's the same game. Can't we obtain one rating and use it everywhere?"

The answer cannot be determined from the game's title alone.

Developers must first examine the actual content and distribution structure.

They must then identify the applicable age rating, evaluate the validity of any existing classification, determine the responsible rating authority, and complete the publication requirements of each platform.

The PC and mobile versions may involve different rating authorities.

The use of an existing rating may require additional examination.

Games with gambling-related elements may need an assessment of rating eligibility before the appropriate application route can be determined.

After release, developers must also ensure that the actual game remains consistent with its rating.

The essential task is not memorizing the names of Korean rating authorities. It is identifying the procedures that apply to the actual game and completing them within the launch schedule.

If you are developing a game or preparing to release one in Korea, you can request a free initial review of your game's content, intended platforms, anticipated age rating, and distribution arrangements to determine whether an existing rating can be used, which application route applies, and what additional administrative steps may be required.