The Complete Guide to Using AI as a Legal Professional in South Korea in 2025

South Korea's new AI Framework Act, promulgated in January 2025 and taking effect on 22 January 2026, turns abstract AI risks into concrete obligations that matter directly to lawyers: a risk‑based regime that mandates labeling for generative AI, stricter controls for “high‑impact” systems in healthcare, energy and public services, broad extraterritorial reach and a dual‑regulator landscape where MSIT and the PIPC overlap on safety and data protection - details well explained in the FPF summary of the Act (FPF summary of South Korea's AI Framework Act) and practical preparedness steps in OneTrust's guide (OneTrust guide to South Korea's AI law and preparedness).

For counsel advising clients on contracts, cross‑border compliance, or domestic representative duties, this guide translates those statutory touchpoints into checklists and training paths - consider starting with targeted upskilling like Nucamp's AI Essentials for Work (Nucamp AI Essentials for Work syllabus) to turn regulatory complexity into practical, court‑ready compliance.

The AI Framework Act (aka the AI Basic Act), promulgated 21 January 2025 and taking effect 22 January 2026, reshapes how legal teams must think about AI in Korea: a risk‑based law that mandates labeling for generative AI, tighter controls for high‑impact systems in sectors like healthcare, energy and public services, broad extraterritorial reach, and a domestic‑representative rule for qualifying foreign providers - details well summarized in the FPF analysis (FPF summary of South Korea's AI Framework Act) and practical preparation notes in OneTrust's guide (OneTrust guide to South Korea's AI law).

Compliance will mean documenting risk management, human oversight, and transparency plans, preparing for MSIT investigations (including on‑site inspections) and overlapping PIPC scrutiny of personal data; a vivid early signal of enforcement was the PIPC's temporary suspension of new downloads of the Chinese generative model Deepseek in February 2025.

With Presidential Decrees still due to set computational and revenue/user thresholds, counsel should prioritize scoping, labeling workflows, and a domestic‑representative strategy now so obligations don't arrive as a surprise at the gates.

South Korea's AI Framework Act reaches beyond its borders: it applies to AI acts abroad that

impact South Korea's domestic market or users

so legal teams must assume that services aimed at or affecting Korean users fall within scope - think of an overseas model that tailors a contract for a Seoul client and therefore lands squarely under Korean rules.

The law keeps a clear exemption for national defense/security systems, but otherwise creates practical hooks for regulators: foreign operators meeting thresholds set by Presidential Decree will need a domestic representative, and MSIT's investigatory powers (including on‑site inspections) operate alongside PIPC scrutiny where personal data is involved, producing a dual‑regulator reality that requires coordinated compliance.

Early priorities: map which products

touch

Korean users, track the forthcoming thresholds for compute/revenue/user triggers, and build domestic‑representative and labeling workflows now to avoid surprise enforcement or fines (administrative penalties reach KRW 30 million).

For a concise legal read on these territorial rules see the FPF summary of South Korea's AI Framework Act extraterritorial reach and the Debevoise overview of the Basic Act.

Classifying AI under Korea's new Framework Act is a practical exercise with real consequences for counsel: the law draws three overlapping buckets that lawyers must map to products and vendor contracts - (1) all covered AI systems, which trigger baseline duties like risk assessments and potential domestic‑representative rules; (2) “high‑impact” AI (aka high‑risk) used in sectors such as healthcare, energy, public services, biometric analysis, transportation and education, which requires documented risk‑management plans, human oversight, explanations/model cards and, where possible, prior verification; and (3) generative AI and large‑model/compute‑threshold systems, which carry transparency and labeling duties (clear user notice and explicit AI‑generated labeling, plus obvious labeling or watermarking for realistic deepfakes) and extra lifecycle controls once computational thresholds are met - DeBevoise flags that those thresholds are likely to capture frontier foundation models (examples called out include GPT‑5 or Llama 4) and Centraleyes/Centralized guidance echoes the need to align internal controls with MSIT reporting.

These distinctions matter in practice: the PIPC's February 2025 temporary suspension of new Deepseek downloads is a vivid reminder that labeling and data controls are enforceable today, not just abstract obligations; for a concise legal framing see the FPF analysis of South Korea's AI Framework Act, the MSIT announcement of the AI Basic Act, and Debevoise's analysis of definitions and compute thresholds for compliance planning.

“We consider the passage of the Basic Act on Artificial Intelligence in the National Assembly to be highly significant as it will lay the foundation for strengthening the country's AI competitiveness. Amid the intense global competition for AI, enactment of this AI Basic Act is a crucial milestone for Korea to truly take a leap forward as one of the world's top three AI powerhouses, resolving corporate uncertainty and stimulating large-scale public-private investment.” - Minister of Science and ICT (MSIT)

South Korea's Basic Act turns transparency from a best practice into a concrete, enforceable duty for anyone deploying generative AI: providers must notify users in advance that a product or service uses AI and must label outputs as AI‑generated, with an “obvious” label or watermark where synthetic media could be mistaken for reality - obligations explained in the FPF summary of the Act (FPF summary of South Korea's AI Framework Act) and in Debevoise's practical analysis of generative AI duties (Debevoise on South Korea's generative AI requirements).

For counsel this means baked‑in UX and metadata controls (clear pre‑use notices, persistent output labels, and watermarking for realistic deepfakes), tight logging of which systems produced which outputs, and cross‑checks with data/privacy workflows because the PIPC has already shown it will act (the temporary suspension of new Deepseek downloads in Feb 2025 is a vivid early warning).

Where models exceed forthcoming compute thresholds, extra lifecycle reporting and safety measures kick in, so legal teams should coordinate contracts, model‑inventory tagging, and compliance playbooks now to avoid last‑minute remediation when Presidential Decrees land and MSIT inspections begin.

Data and privacy are no longer background items for counsel advising on AI - South Korea's PIPC has moved to the centre of risk management with its

Guidelines for Personal Data Processing for Generative AI

(unveiled at an August 6 seminar), which make clear that using public web data can rest on PIPA's

legitimate interests

but that non‑public personal data must follow one of three protected pathways and layered technical safeguards; read the PIPC announcement for the primary text (PIPC Guidelines for Personal Data Processing for Generative AI - official PIPC announcement).

Practically, the guidance demands demonstrable steps - verify sources, strip high‑risk identifiers (resident registration numbers, account or card numbers), apply pseudonymization or seek consent, log provenance, and adopt

machine‑unlearning

or deletion protocols where appropriate - so legal teams should document legal‑basis decisions, involve the CPO early, and treat the Guidelines as the de facto standard regulators will use in investigations (Lexology summary: PIPC processing of publicly available personal information and compliance routes).

so what?

Firms that bake these controls into model inventories, contracts and PIAs gain a strong defensive record - failure to do so risks costly regulatory scrutiny and operational halts long before the AI Framework Act's final decrees arrive.

For counsel advising clients in Korea, the Act's “high‑impact” label is a practical triage tool: systems used in healthcare (think AI that helps develop or triage medical devices), energy and water supply controls, public services and transportation, biometric analysis, and high‑stakes hiring or student evaluation all carry stricter duties - pre‑deployment review, documented risk‑management plans, human‑oversight measures and model cards that explain decisive logic - so a hospital using an AI triage aid or a utility deploying demand‑management algorithms should have human‑in‑the‑loop protocols and certification plans ready before launch.

Start by mapping which products touch those sectors, run the preliminary review the law requires (and consider asking MSIT for confirmation where uncertain), bake mandatory user notices and AI‑output labeling into UX, and ensure contracts push vendors to provide provenance, logging and remedial rights; these steps reflect the tiered obligations flagged in the FPF summary of the Act and the practical compliance framing in Debevoise's analysis, while DLA Piper highlights the upfront review obligation that makes this sectoral mapping non‑optional for operators and deployers.

The payoff is concrete: teams that document impact assessments, model cards and oversight rules create a defensible record against MSIT inspections or PIPC scrutiny instead of scrambling to patch governance after a suspension or corrective order.

“AI services are expected to offer significant efficiency improvements to professional users, including law firms, sole practitioners and in‑house counsel.” - Asia Business Law Journal / Law.asia

Turn the law's requirements into a practical, prioritized playbook: start by creating a central AI system inventory and classify each tool by high‑impact status and compute use so teams can spot systems that will trigger Article 31/32 duties (cataloguing and risk‑classification guidance is foundational - see Nemko's recommended inventory approach AI Regulation in South Korea); run privacy‑forward impact assessments aligned with the PIPC's generative AI guidance and record the legal basis for any non‑public training data (PIPC Guidelines for Personal Data Processing for Generative AI); hardwire transparency into UX and contracts - advance user notices, persistent labels/watermarks for generative outputs, and vendor obligations to log provenance and enable deletion; track forthcoming compute/revenue/user thresholds and be ready to appoint a domestic representative and report to MSIT (prepare for on‑site inspections by keeping risk‑management records searchable and current); assign clear ownership (CPO or AI compliance lead), train counsel on human‑in‑the‑loop obligations, and build an incident response path that ties model monitoring to legal remediation; practical roadmaps and checklists from compliance vendors can speed implementation - OneTrust's readiness playbook is a useful operational reference (OneTrust: preparing for South Korea's AI law).

The payoff: a searchable, dated record of inventories, PIAs, labels and vendor assurances that turns a potential MSIT or PIPC inspection from a panic into a paper trail that limits exposure to administrative fines (up to KRW 30 million).

Enforcement in South Korea is practical, prompt and multi‑layered: the MSIT can open fact‑finding probes, compel documents and conduct on‑site inspections for failures like missing generative‑AI labels, absent risk‑management systems or breaches of safety rules, and has authority to issue corrective or suspension orders that carry administrative fines up to KRW 30 million and, according to implementation commentary, even the prospect of criminal penalties in the most serious cases - points set out in the FPF summary of the Act and OneTrust's preparedness guide (Future of Privacy Forum analysis of South Korea's AI Framework Act, OneTrust guide to preparing for South Korea's AI law).

The Personal Information Protection Commission has already shown it will act (the temporary February 2025 suspension of Deepseek downloads is a vivid early signal), and foreign operators risk separate sanctions tied to the domestic‑representative regime - financial penalties of up to KRW 20 million for representative‑related breaches are flagged in the legal commentary - so legal teams should prepare searchable, dated risk‑management records, appoint a clearly empowered domestic representative where thresholds may apply, harden provenance and logging for model outputs, and rehearse document production for MSIT/PIPC inspections so an audit becomes a defensible paper trail rather than a scramble.

Legal teams advising on Korea's AI regime should move from theory to checklists now: begin with a searchable AI system inventory and risk classification so high‑impact or compute‑heavy models are flagged for Article 31/32 duties (see Nemko guide to AI regulation in South Korea for the timeline and core requirements); run privacy‑forward impact assessments and bake transparency/labeling and human‑in‑the‑loop controls into contracts and UX as Schellman outlines for provider obligations and domestic‑representative duties (Schellman analysis of South Korea's AI Basic Act); align governance with ISO 42001 principles to make evidence production auditable and repeatable; and close the skills gap with targeted upskilling such as Nucamp AI Essentials for Work bootcamp.

Treat preparation as insurance: documented inventories, PIAs, labels and vendor assurances sharply reduce enforcement risk (administrative fines can reach KRW 30,000,000) and turn inspections from disruption into defensible proof of compliance.