[E-Daily Reporter Lee So-Hyun ] Labor unions at South Korea’s two major platforms, Naver (NAVER(035420)) and Kakao(035720), have jointly called for “unified collective bargaining,” arguing that the current structure—in which affiliates are operated separately while key decision-making authority remains with the parent company and responsibility for labor-management negotiations is delegated to each affiliate—must be changed. The Naver union is also initiating corrective proceedings with the Labor Relations Commission against management, which has rejected the demand for unified collective bargaining.

The Chemical, Textile, and Food Industry Labor Union of the Korean Confederation of Trade Unions (KCTU) held a “Press Conference Calling for Unified Bargaining in the IT Industry” on the 1st at the National Assembly Communication Center in Yeouido, Seoul, in collaboration with the office of Rep. Lee Yong-woo of the Democratic Party of Korea. They demanded that the government and the National Assembly amend the system, noting that substantive negotiations with the parent company have not taken place even after the revised Trade Union and Labor Relations Adjustment Act (Trade Union Act) went into effect.

Article 2 of the amended Trade Union Act expanded the definition of “employer” to include any party that, even if not a party to the employment contract, holds a position that allows them to substantively and specifically control or determine working conditions; such parties are considered employers within that scope. The amendment took effect on March 10.

However, the actual determination of employer status is not based on a blanket assessment of the entire company but rather on whether there is substantive control or decision-making authority regarding specific working conditions. Prior to implementation, the Ministry of Employment and Labor issued interpretive guidelines containing relevant criteria and has been operating a “Committee to Support the Determination of Collective Bargaining.”

Naver Union Finally Files Complaint with Labor Relations Commission… “No Public Notice for Over 40 Days”

On August 20, the Naver branch union held a ceremony at Naver’s headquarters to declare integrated collective bargaining and officially requested negotiations to discuss common working conditions for Naver and its affiliates.

However, according to the union, Naver responded by stating that it “is not in a position to substantively and specifically control or determine the working conditions of union members at its affiliates,” and failed to comply with the requirement to publicly announce the request for collective bargaining. With more than 40 days having passed since the request was made, the union decided to file an “application for corrective action regarding the public announcement of the request for integrated collective bargaining” with the Gyeonggi Regional Labor Relations Commission on the 2nd.

Oh Se-yoon, chairman of the Naver branch, argued that Naver has exercised influence not only over the affiliate companies’ equity structures, board compositions, and dependence on Naver’s business and revenue but also over working conditions such as personnel transfers and employee benefits. He cited instances where the results of Naver’s collective bargaining were applied to its affiliates, as well as cases where Naver directly participated in past negotiations with affiliates, as evidence supporting Naver’s status as an employer.

Chairman Oh stated, “There are affiliates in which Naver holds a 100% stake, that are entirely dependent on Naver’s business, and that derive 100% of their revenue from Naver,” adding, “If Naver is not considered the employer even for such companies, then where in South Korea is there a principal contractor that could be deemed an employer under the ‘Yellow Envelope Act’?”

The union emphasized the need for “after-sales service” for the ‘Yellow Envelope Act.’ Noting that disputes over employer status are likely to drag on in the field despite the Ministry of Employment and Labor having already issued interpretive guidelines, the union called for clearer administrative standards.

Furthermore, they urged the National Assembly to review the implementation status of the amended law during this year’s parliamentary audit and, if necessary, to further specify the criteria for determining employer status and the scope of collective bargaining.

Kakao Joins the Call… “One Company When Managing, Another When Taking Responsibility”

The Kakao branch also joined the call for unified bargaining.

Seo Seung-wook, chairman of the Kakao branch, argued that group-level decision-making influenced Kakao’s investments, business direction, organizational restructuring, and the sale or spin-off of affiliates—as well as compensation policies—during the process of business spin-offs, acquisitions, and reorganizations. “When it comes to management, we’re one community, but when it comes to taking responsibility, we become different companies,” Chairman Seo said, adding, “Those with authority should not hide behind others when it comes to taking responsibility.”

However, the unified bargaining proposed by the union does not mean aligning wages and working conditions across all affiliates. Branch Chairman Seo explained, “Consolidated bargaining is not about making every company identical,” adding, “The intent is to recognize the business characteristics and performance of each legal entity while jointly discussing common issues that can be decided at the group level—such as employment measures following business divestitures or closures, the impact of organizational restructuring, and redeployment or retraining resulting from business failures.”

The Naver union is also pursuing a multi-tiered structure: rather than eliminating all separate negotiations by subsidiary, it aims to address common agenda items—those actually decided by the parent company—through consolidated bargaining, while matters within the decision-making authority of individual subsidiaries will continue to be handled through existing subsidiary-level negotiations.

Beyond Naver and Kakao: Toward an IT Industry-Wide Bargaining Structure

The Textile, Chemical, and Food Workers’ Union plans to expand the call for consolidated bargaining at Naver and Kakao beyond mere labor-management issues at individual companies to address the restructuring of bargaining frameworks across the entire IT, gaming, and platform industries.

Currently, the Textile, Chemical, and Food Workers’ Union includes unions from major IT and gaming companies such as Naver, Kakao, Nexon, and NCSoft. Following a “Forum on Exploring an Integrated Bargaining Structure for the IT Sector” held at the National Assembly last August, the union intends to use this joint press conference as an opportunity to continue pressing the government and the National Assembly for institutional reforms.

Shin Hwan-seop, chairman of the Textile, Food, and Chemical Workers’ Union, emphasized, “We must establish a structure that allows for negotiations with the entities that hold actual decision-making authority within IT companies, whose business operations are fragmented across multiple legal entities.”

Naver is expected to be the first test case. If the Naver branch files a corrective action request with the Gyeonggi Regional Labor Relations Commission on the 2nd, the key issue will likely be determining the extent to which Naver exercises “substantive and concrete control and decision-making authority” over the working conditions of its affiliates. Since employer status under the amended Trade Union Act is determined on a case-by-case basis for individual working conditions, the crux of the matter will be how the Labor Relations Commission evaluates the data presented by the union regarding shareholdings, personnel, welfare, and wages.