This article was published on May 6, 2025, at 5 p.m. on the ChosunBiz RM report site.
The Fair Trade Commission is conducting a large-scale written survey to examine unfair practices harming consumer rights in subscription service markets such as online video services (OTT) and music. In particular, it plans to conduct a thorough investigation into various consumer issues, including price increases before, during, and after contracts, hindrances to cancellations, and deceptive inducements, with a view to improving policies.
According to the government on the 6th, the Fair Trade Commission plans to publish a policy report on the topic of 'subscription economy and consumer issues' by the end of the year. The commission will begin its written survey of 40 major domestic and international subscription service corporations in May and June.
The Fair Trade Commission is looking into various industrial sectors, such as OTT, music, delivery, distribution, laundry, clothing, and connected cars, as subjects of the investigation. In the OTT sector, Netflix, TVING, Watcha, and Coupang Play are noted, while Melon, Spotify, and YouTube Music are in the music sector. The distribution field is expected to focus mainly on the paid membership services of large online commerce platforms such as Coupang (Wow Membership) and Market Kurly (Kurly Members).
Not only delivery app subscription products like Yogiyo Pass and Baedal Minjok Baim Pass but also lifestyle subscription services such as laundry subscription service Lundrigo, car subscription service SOCAR, and clothing rental subscription service Closet Share may also be included in the subjects of investigation. The Fair Trade Commission plans to carefully examine whether the types and operational methods of subscription economy services, which are spreading across industries, are infringing on consumer rights.
The inspection items include ▲ inducement methods before contracts ▲ price increases and information provision methods during subscriptions ▲ cancellation procedures, etc. In particular, 'automatic paid conversion after a free trial' or 'complicated cancellation inducement' are key inspection targets under the Electronic Commerce Act's regulation of dark patterns (deceptive sales tactics).
According to the revised enforcement ordinance of the Electronic Commerce Act, which was amended last February, if an online subscription service converts to paid after a free trial, the consumer must receive 'explicit consent' again. Even if consent was obtained at the time of the initial contract, if the 'will to consent' is not confirmed again, conversion to paid service is not possible. Simple advance payment notifications or email guidance do not have legal effect. The same principle applies when renewing subscriptions.
However, there are still dark pattern blind spots that evade such regulations. A typical example includes design structures that make cancellation difficult and methods that create emotional pressure by highlighting the benefits lost upon withdrawal. The Fair Trade Commission believes that such deceptive user interface (UI) designs infringe on consumer choice.
Subscription inflation, where prices rise while benefits remain unchanged, is also a subject of inspection. In reality, many platforms are increasing subscription fees without altering benefits, which is raising the burden on consumers.
The Fair Trade Commission has already taken action against the subscription service operating methods of several platforms last year. Coupang's Wow Membership was operated to maintain service until the end of the month without refunds, even if a mid-term cancellation was requested, which was judged to be a violation of the Electronic Commerce Act, leading to the issuance of an inspection report. The commission also deemed the UI that considers pressing the 'payment button' as consent to price increases without consumer agreement as a dark pattern.
These sanctions extended not only to Coupang but also to Naver Plus Membership and Market Kurly's Kurly Members. The Fair Trade Commission sent out inspection reports following on-site investigations last May and subsequently initiated sanctions against OTT companies such as Netflix, Wavve, and Watcha, as well as music platforms such as Spotify and Bugs.
The objective of this policy report is to systematically diagnose structural issues in the overall subscription economy beyond individual enterprise sanctions. In an environment where regular payments have become the norm, it aims to explore ways to minimize consumer harm caused by complex conditions and hindrances to cancellations.
A Fair Trade Commission official noted, 'We will look into the entire cycle, from the process of consumers being induced before subscription contracts to mid-term price increases and cancellation procedures,' adding, 'We will conduct an in-depth analysis of the subscription economy market to include it in the policy report.'