South Korea's new app store regulations challenge developers

App developers are closely monitoring downloads and sales in South Korea following the introduction of stringent new regulations aimed at strengthening consumer protection, including requiring explicit consent from users for trial-to-paid conversions.

Banishing 'dark patterns': The new rules, which took effect on February 14, 2025, focus on enhancing transparency in subscription-based services and eliminating deceptive design practices, cracking down on misleading user interfaces commonly known as dark patterns. The Korea Fair Trade Commission has issued guidelines identifying six types of dark patterns and warned that non-compliance with the regulations can result in fines up to 5 million KRW (approximately $5,000).

Apple and Google respond: Protocols for complying with the regulations have been published by Apple and Google. The app store owners say, among a range of requirements, developers offering free trials or discounted introductory periods must now obtain explicit user consent before transitioning to paid subscriptions. Failure to obtain active user confirmation must result in automatic cancellation of the subscription at the end of the trial period.​

Other dark patterns outlawed by the Korea Fair Trade Commission that app developers need to be aware of include:

• Sequential Price Disclosure: Revealing additional charges only at later stages of the subscription process.
• Incorrect Hierarchy: Designing interfaces where the "purchase" button is prominent, while the "cancel" option is obscure.
• Repeated Coercion: Bombarding users with pop-ups to reverse a cancellation or repeatedly soliciting personal data consent.

Initial impact of the changes: An analysis by Revenue Cat showed conversion rates for 5-9 day trial Android apps dropped sharply in the first few days after the introduction of the new regulations, while iOS rates remained comparatively stable. Time will tell, but the change did not necessarily spell doom and gloom for the South Korean app market, the development platform provider said in a post.

"For starters, on iOS they seem to be faring fine so far (though there's a bit of uncertainty on Apple’s interpretation of these new rules)," the company said. "On the flip side, Play's dramatic conversion drop doesn't look like an acceptable end-state for trials on the platform, so we'd expect to see some changes there over the coming weeks."