# Korea's Framework Act Is Still in Subcommittee. The Rules Arrived Anyway.

*ium Research — James, Co-Founder — August 24, 2026*
*Canonical: https://iumlabs.io/blog/korea-digital-asset-act-stalled-administrative-rulemaking-2026*

## Key Takeaways

- The Digital Asset Basic Act has been in the National Assembly's Political Affairs Committee since June 11, 2025 — proposed, tabled, referred to subcommittee, and still there fourteen months later
- While the statute stalled, the binding rules arrived through the AML track instead: the amended Specified Financial Transaction Information Act took effect August 20, 2026 with a rewritten VASP entry regime
- The two live disputes in the bills — who may issue a won stablecoin, and what equity limits apply to a VASP's major shareholders — are the same two questions the administrative track has already started answering
- For an operator this inverts the planning order: build against the enforceable AML regime now, treat the framework act as an upgrade path, and stop sequencing a Korea entry around a legislative date

Every quarter since mid-2025, the same sentence has appeared in Korean crypto coverage: the Digital Asset Basic Act will pass this year. It has been true of two different years now.

The bill that started the cycle is on the record and easy to check. Bill 2210736, the Digital Asset Basic Act, proposed by Representative Min Byoung-dug and 37 others on June 11, 2025. Tabled at the Political Affairs Committee on August 26, 2025 — presented, reviewed, debated, referred to the legislative review subcommittee. That is where it has been ever since.

Meanwhile, on August 20, 2026, a different law changed the rules for entering the Korean market. Nobody had to wait for it.

*[Figure: Source: National Assembly Legislative Status, Bill 2210736, "디지털자산기본법안," Min Byoung-dug and 37 others, June 11, 2025. The proposal statement is still the clearest description of the gap the bill is meant to close.]*

## 1. What the Bill Says It Is For

The proposal statement is worth reading in the original, because it concedes the point that most commentary tiptoes around: the law Korea already has was never meant to do this job.

> **"현행 「가상자산 이용자 보호 등에 관한 법률」은 이용자 자산 보호와 불공정거래행위 규율에 초점을 맞춘 1단계 법률로, 발행·유통·공시·거래지원 등 디지털자산 생태계 전반을 포괄하기에는 한계가 있음"**
> ("The current Act on the Protection of Virtual Asset Users is a first-stage law focused on protecting user assets and regulating unfair trading practices, and has limits in covering the digital asset ecosystem as a whole, including issuance, distribution, disclosure and trading support." Translated from the Korean original.)
> Bill 2210736, Digital Asset Basic Act, statement of proposal, Representative Min Byoung-dug and 37 others, June 11, 2025

The bill would introduce authorisation for issuers of asset-linked digital assets, build a tiered authorisation, registration and notification regime for digital asset businesses under the Financial Services Commission, prohibit unauthorised operation, give statutory footing to an industry self-regulatory body, and hand the FSC inspection and enforcement powers across issuance, disclosure and trading support.

A second bill takes the same territory from a different angle. Bill 2213449, the Digital Asset Promotion Framework Act, proposed by Representative Choi Bo-yun and 10 others on October 1, 2025 and referred the next day, writes stablecoin rules into Articles 95 through 112 — issuer authorisation, redemption reserves, redemption liability — and governance controls into Articles 28 through 53, including approval for changes of major shareholder.

Neither has moved out of subcommittee.

## 2. The Two Fights That Are Actually Holding It

Strip away the procedural language and the blockage reduces to two questions, both of them about who is allowed to hold something.

**Who may issue a won stablecoin.** This is the fight between the Financial Services Commission and the Bank of Korea, and it is not a drafting problem. It is a question about whether a non-bank can issue a claim on won at scale, and about who supervises reserves when it does. Neither institution can concede it without conceding jurisdiction. We covered the substance of that dispute in [the won-stablecoin endgame](/blog/korea-won-stablecoin-digital-asset-basic-act-2026).

**What equity limits apply to a VASP's major shareholders.** Less discussed, more consequential for anyone building here. A limit on how much of a Korean exchange a single shareholder may hold is a limit on who can buy one, and Korea currently has a large pending transaction that turns on exactly that question.

Both bills carry provisions on the second point. Bill 2213449 puts change-of-major-shareholder approval into its governance chapter. And this is where the story turns, because that question did not wait for the statute.

## 3. The Rules Arrived Through the Other Door

On August 13, 2026, the Financial Intelligence Unit and the Financial Supervisory Service published a completely rewritten VASP reporting manual, keyed to the amended Specified Financial Transaction Information Act that took effect on August 20.

That amendment extends criminal-record and soundness screening from the operator and its executives to its major shareholders — defined to include the largest shareholder, holders of 10% or more of voting stock, shareholders in a special relationship with the largest shareholder, and, where the largest shareholder is a corporation, that corporation's own largest shareholder and representative. It converts changes of major shareholder from post-notification within 14 days to pre-notification 30 days ahead, and makes both a ground for rejecting a filing.

We took that document apart in detail in [the VASP entry exam](/blog/korea-vasp-reporting-manual-2026-major-shareholder-screening). The point here is narrower and, for planning purposes, more important:

**The question the framework act cannot settle is already being answered administratively.** Not identically, and not with the same force — an AML statute regulates entry to a reporting regime, not ownership of a market. But if you are asking "what does Korea require of my shareholders," you now have an answer with a date on it, and it did not come from the bill everyone is watching.

> **14 months** — Time bill 2210736 has spent between subcommittee referral (August 26, 2025) and this writing, while the AML track produced an amended statute, subordinate decrees and a rewritten manual (Source: National Assembly Legislative Status, bill 2210736; FSC release, August 13, 2026)

## 4. Why Legislative Dates Keep Slipping, Structurally

It is tempting to read fourteen months as dysfunction. It is more useful to read it as a description of how Korean financial regulation actually moves, because the pattern repeats.

The first-stage law — the Act on the Protection of Virtual Asset Users — passed relatively quickly because it did one thing that nobody had to fight over: protect users from operators. There is no institutional turf in that.

The framework act does the opposite. It allocates authority over a new money-like instrument between the central bank and the financial regulator, and it decides who may own market infrastructure. Those are exactly the provisions that cannot be resolved by a committee's goodwill, because the resolution costs one institution something permanent.

Administrative rulemaking has no such constraint. The FIU can tighten entry conditions under an existing statute without anyone conceding jurisdiction, because AML supervision is already theirs. That is why the AML track keeps shipping while the framework track keeps slipping — and there is no reason to expect that asymmetry to reverse.

## 5. What This Means for Sequencing a Korea Entry

Most Korea plans we see treat regulation as a gate: wait for clarity, then enter. That was defensible in 2024. It is now a way to lose two years.

The practical reading is that Korea has two regulatory surfaces moving at different speeds, and only one of them binds you today.

| Surface | Status | What it decides | Planning treatment |
|---|---|---|---|
| AML track (특금법, FIU) | In force August 20, 2026 | Whether you can register a Korean entity at all; who your shareholders may be; where your data sits | Build against it now |
| Framework act (DABA) | In subcommittee since August 2025 | Stablecoin issuance, disclosure, trading-support rules, industry authorisation tiers | Track, do not sequence around |

The second column is the useful one. The framework act mostly governs activities that a foreign project entering Korea does not perform directly — issuing a won stablecoin, operating an exchange, running trading support. The AML track governs the thing every entrant touches: getting a legal presence.

If you are launching a token, listing on a Korean venue and running Korean distribution, your dependency is on the [listing process](/blog/korean-exchange-listing-strategy-upbit-bithumb-2026) and on counterparties who are themselves registered, not on DABA passing. Our [GTM Index](/blog/korea-crypto-gtm-index-2026-benchmarks-25-market-entries) work across 25 market entries found sequencing errors, not regulatory ambiguity, to be the dominant cause of failed Korean launches. Waiting on a statute is a sequencing error with better PR.

## 6. What Breaks It

**A merged government bill could move fast.** The FSC has signalled it wants a single unified bill rather than ten competing member bills. A government bill with ruling-party backing behaves differently from a member bill in subcommittee; if the stablecoin jurisdiction question gets settled politically, the rest can pass quickly. Our confidence that this slips again is a judgement about institutional incentives, not a prediction of the calendar.

**A statutory equity limit could override the manual.** If DABA sets a shareholder cap different from the AML regime's 10% screening threshold, entry structures built against the manual may need revisiting. That is an argument for documenting your structure clearly, not for waiting.

**The AML track could overreach and get pulled back.** The manual is interpretive guidance. The FIU has explicitly invited industry feedback on provisions that prove unworkable, and the draft-to-final softening on data residency — from all computing facilities to only those handling identifiers and credit information — shows that invitation is real.

## The Radar Read

Korea has been described as a market waiting for legal clarity for three years running. That framing has always been slightly wrong, and it is now clearly wrong.

Clarity is arriving, just not through the door everyone is watching. The statute that gets the headlines allocates power between institutions and will move when that fight resolves, on nobody's schedule. The regulations that decide whether you can operate here are being issued under laws that already exist, with effective dates, published manuals and briefing sessions for the industry.

Plan against the second one. Read the first one for where the market is going, not for when you can start.

## Sources

- National Assembly Legislative Status, Bill 2210736, "디지털자산기본법안," Representative Min Byoung-dug and 37 others, proposed June 11, 2025; Political Affairs Committee, tabled and referred to subcommittee August 26, 2025. [opinion.lawmaking.go.kr](https://opinion.lawmaking.go.kr/gcom/nsmLmSts/out/2210736/detailRP)
- National Assembly Legislative Status, Bill 2213449, "디지털자산 육성 기본법안," Representative Choi Bo-yun and 10 others, proposed October 1, 2025, referred October 2, 2025. [opinion.lawmaking.go.kr](https://opinion.lawmaking.go.kr/gcom/nsmLmSts/out/2213449/detailRP)
- Financial Services Commission / Korea Financial Intelligence Unit / Financial Supervisory Service, "가상자산사업자 신고제 강화에 맞춰 신고매뉴얼을 전면 개정합니다," August 13, 2026. [fsc.go.kr](https://www.fsc.go.kr/no010101/87521)