[Edaily Reporter Lee So-Hyun ] Following the enforcement of the amended Information and Communications Network Act—commonly known as the “False and Manipulated Information Act”—the Korea Internet Self-Regulatory Organization (KISO) has released its first review results on self-regulation regarding false and manipulated information. While the large-scale deletion and blocking of posts that had been feared early in the law’s implementation did not materialize, actual reports were found to be concentrated on lifestyle-related posts—such as reviews of accommodations, restaurants, and cosmetic procedures—rather than political or election-related “fake news.”

KISO is a private self-regulatory body comprising internet service providers such as Naver and Kakao. Separate from government reviews and sanctions, it assists member companies in administering content policies based on common standards. Naver, Kakao, Daum, Nate, and Karrot Market participated in this round of false and manipulated information deliberations. Although Karrot Market is not classified as a “large-scale information and communications service provider” under the law, it proactively joined the self-regulatory efforts.

No Deletion Decisions in All 27 Cases Reviewed in First Round of Deliberations

The KISO Special Committee on Deliberation of False and Manipulated Information held a briefing in Gwanghwamun, Seoul, on the 2nd and disclosed the status of deliberations on 27 reports of false and manipulated information submitted by member companies following the enforcement of the amended Information and Communications Network Act on July 7. This marks the first time KISO has disclosed actual cases of the application of its self-regulatory standards for false and manipulated information.

According to KISO, of the 27 cases received, 23 underwent final review, excluding four that were deleted during the review process or subject to provisional measures due to defamatory infringement of rights. The outcome for all 23 cases was “not applicable.” There were no cases where content was deemed false or manipulated information under the guidelines and subjected to measures such as deletion or blocking. However, KISO did not disclose the number of review requests by platform, noting that this information could serve as an indirect indicator of each company’s user base or market share.

The posts submitted for review consisted mostly of information on products and services, user reviews, and promotional content, rather than political or social issues. “Information, review, and promotional” posts totaled 19, accounting for 70% of the total. These included information on travel agencies and accommodations, reviews of restaurant receipts, reviews of cosmetic procedures, and information on product discounts.

Kim Min-ho, Chair of KISO’s Special Committee on Deliberation of False and Manipulated Information, explained, “Initially, we expected there to be many politically sensitive issues, but the reality was completely different,” adding, “Posts conveying information, providing reviews of products and services, or promoting products accounted for over 70%.”

Even if False or Manipulated, Purpose and Harmfulness Were Considered

The fact that no deletion decisions were made is a result of KISO’s strict interpretation of the criteria for false and manipulated information. According to KISO guidelines, false or manipulated information must meet all three of the following criteria: △ it must be false or manipulated; △ the publisher must have acted with the intent to cause harm or gain an unfair advantage while knowing it was false or manipulated; and △ it must infringe upon another person’s personal rights, property rights, or the public interest. Satire and parody are excluded.

KISO did not classify as false or manipulated information minor errors—such as content that differs slightly from the facts but does not substantially affect the core message or the general public’s perception of the facts—as well as certain inaccurate expressions, a lack of timeliness, or the potential for misunderstanding.

However, not all 27 cases were rejected in the first stage. Chairman Kim explained, “There were some cases that, while they constituted false or manipulated information, were deemed inapplicable because they lacked intent or were not infringing.” Examples included a hotel and guesthouse listing that featured a photo of a foreign luxury hotel lobby instead of the actual location; a post that promoted a specific substance as a cure-all while citing unrelated treatment cases; and images that appeared to be AI-generated or合成. However, since no intent or harmfulness was confirmed, these were ultimately deemed “not applicable.”

Professor Kim Hyun-kyung of the Graduate School of IT Policy at Seoul National University of Science and Technology, a member of KISO’s Special Committee on False and Manipulated Information, explained, “Simply because the content is false or manipulated does not mean it constitutes false or manipulated information.” She added, “It must satisfy three requirements: intent to cause harm or the purpose of obtaining undue benefit; the presence of false or manipulated information; and infringement of another person’s personality rights, property rights, or the public interest.”

It was also determined that AI-generated content and deepfakes do not constitute manipulated information merely because they have undergone technical alterations. Regarding the criteria for determining manipulated information, Professor Kim explained, “It is not the mere alteration itself, but whether it possesses a deceptive appearance likely to cause users to mistake it for an objective fact.” Whether the context has been distorted through spatial or temporal rearrangement, partial editing, or false attribution is also a factor in the determination.

“A Domain of Self-Regulation, Not Illegal Information”

Chairman Kim emphasized that false and manipulated information does not fall under the category of “illegal information,” which includes pornography, drugs, firearms, explosives, and defamatory content. He explained that while illegal information falls under the purview of public regulation, false and manipulated information is handled through a system in which large-scale information and communications service providers receive reports and make autonomous judgments and take appropriate action.

KISO’s decisions are more binding under the terms of an agreement than legally binding. Chairman Kim explained that member companies—including Naver, Kakao, Daum, Nate, and Danggeun Market—operate in accordance with an agreement in which they have committed to following KISO’s deliberation decisions. However, specific measures—such as deletion, blocking access, restricting visibility, or limiting monetization—are determined by the member companies themselves.

The possibility of overseas platforms participating was also mentioned. Chairman Kim stated that KISO is open to both domestic and international operators, adding, “Discussions are underway with at least two global Big Tech companies, contingent upon their membership.” However, he did not disclose the specific names of these companies. Previously, the Korea Communications Commission (KCC), in accordance with the revised Information and Communications Network Act, designated a total of nine entities—five domestic operators (including Naver, Kakao, Daum, Nate, and DC Inside) and four overseas operators (including Google, Meta, X, and TikTok)—as large-scale information and communications service providers subject to obligations to address false or manipulated information.

Concerns were raised regarding the potential curtailment of freedom of expression, prompting calls for caution. Chairman Kim explained that while KISO had expressed strong concerns about regulations prohibiting the distribution of false and manipulated information prior to the law’s enforcement, the actual enforcement process does not entail taking action based solely on content being false or manipulated. He stated, “I can clearly state that there are no indiscriminate deletions or blocks on domestic platforms that would infringe upon freedom of expression.”

Professor Hwang Yong-seok of the Department of Media and Communication at Konkuk University, a member of KISO’s Special Committee on False and Manipulated Information, remarked, “This has the effect of provisionally assigning platform operators the role of judging the truthfulness of information circulating in the world and filtering it accordingly.” He added, “Platforms acting as filters for societal information amounts to the concentration of power in the hands of platforms, so this must be checked.” He further emphasized that the concept of false and manipulated information should be applied as narrowly as possible.

The need for institutional improvements was also raised. Chairman Kim said, “If improvements are to be made, I hope that vague concepts will be clearly defined,” adding, “Since elements such as intent, purpose, infringement, and public interest are all ambiguous, I hope they can be transformed into precise concepts that anyone can easily understand.”

KISO plans to accumulate review cases and disclose the results to enhance the predictability and reliability of self-regulation.