Korea's advertising law defines the message, not the messenger

The persona

No named endorser sits at the center of this entry; the relevant document defines a category instead. South Korea's Act on Fair Labeling and Advertising, in its officially translated current text, defines 'advertising' as any message a 'business entity' widely communicates to consumers through newspapers, broadcasting, telecommunications, or other prescribed methods, and defines 'business entity' by reference to Korea's competition law rather than by who or what appears in the message. Nothing in the definition depends on whether the message is delivered by a person, a brand account, or an operator-run virtual character.

What the documents establish

The Act prohibits unfair or deceptive labelling and advertising by any business entity, and Korea's Fair Trade Commission implements that prohibition through subject-specific rules. Its own English-language Guidelines for Examination of Internet Advertisements, in force since December 2016, states that 'advertisement through consumer reviews' posted on a business's own site is examined for unfair concealment of unfavorable content, and that illegality in other Internet advertising conducted in the form of consumer reviews is governed by a further KFTC guideline on labelling and advertising for recommendations and guarantees. That further guideline was not available to this note in an English rendering, so its specific disclosure-format requirements are not asserted here.

Character versus company

A virtual persona's sponsored post in Korea would read, to a follower, as the character's own recommendation. The Act's framework does not evaluate that voice; it regulates the business entity's communication to consumers, and the internet-advertising guideline extends scrutiny to review-style promotion specifically because it can obscure a commercial relationship behind an apparently independent voice. The obligation to comply, and the exposure to a corrective order under the Act, attaches to the business entity operating the account, not to the persona.

What to watch

Because the specific recommendation-and-guarantee guideline was not accessible here in English, a reader who needs its exact disclosure wording or format should consult the Korean-language original or request an official translation before citing it. It is also worth watching whether KFTC issues guidance naming virtual influencers specifically, since neither document reviewed here does. This is an editorial caution rather than a finding.

• Does the specific recommendation-and-guarantee guideline add disclosure-format requirements beyond the Act's general prohibition?
• Which business entity would a corrective order under the Act name for an undisclosed virtual-influencer promotion?
• Has KFTC issued any guidance addressing synthetic or virtual endorsers by name?

The documents available in English establish scope, not specifics: any business entity's communication is covered, but the granular disclosure format for endorsement-style content remains, on this record, a Korean-language document this note could not independently confirm.