AI law comparison · Data verified 2026-08-22
GDPR Article 22 vs South Korea PIPA
GDPR Article 22 and South Korea PIPA are two of the 169 AI and data regulations Aegis Firma tracks. They have different scopes, effective dates, and penalties — and many businesses fall under both. Here is the side-by-side, drawn directly from the regulatory registry.
Find which laws apply to my businessSide by side
Summary of publicly available regulatory text. Verify against current official sources before relying on this for compliance decisions. Not legal advice.
The key difference
South Korea PIPA takes effect first, so it is usually the more urgent of the two. GDPR Article 22 tracks 5 compliance requirements and South Korea PIPA tracks 4. They are not interchangeable — meeting one does not discharge the other. The practical question is not which law is “stricter,” but which of them — or both — actually applies to your business.
EU GDPR Article 22 — Automated Decision-Making & AI Profiling
GDPR Article 22 (in force since May 25, 2018) gives EU and EEA residents the right not to be subject to decisions based solely on automated processing — including AI profiling — that produces legal or similarly significant effects (credit scores, hiring, insurance pricing, content moderation). Organizations must inform individuals of automated processing, provide meaningful explanations of logic, implement human revi…
Full GDPR Article 22 requirementsSouth Korea Personal Information Protection Act (PIPA) — AI Provisions
South Korea's PIPA (Personal Information Protection Act) is one of Asia's most comprehensive privacy laws, significantly strengthened by 2023 amendments effective March 2024. Enforced by the Personal Information Protection Commission (PIPC), it applies to any organization processing personal data of South Korean residents. Article 37-2 (2023) adds automated decision-making rights for Korean data subjects. PIPC fine a…
Full South Korea PIPA requirementsCommon questions
Could both GDPR Article 22 and South Korea PIPA apply to my business?
Yes. GDPR Article 22 and South Korea PIPA are separate regulations with separate scopes — a business can fall under both at once. GDPR Article 22 covers GDPR Art. South Korea PIPA covers Extraterritorial reach: applies to any organization processing personal information of South Korean residents, regardless of where the organization is located. If your operations meet both scopes, you must comply with both. Aegis Firma's free scan checks all 169 tracked regulations against your business profile so you do not have to read each law to find out.
Which has the higher maximum penalty — GDPR Article 22 or South Korea PIPA?
GDPR Article 22: €20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5)) South Korea PIPA: KRW 3,000,000,000 (₩3 Billion / ~$2.2M USD) OR 3% of global revenue, whichever is higher (current, through 2026-09-10). From 2026-09-11, a PIPA amendment raises the ceiling to 10% of total turnover for repeated/serious violations (intentional or grossly-negligent repeat breaches within 3 years; damage affecting 10M+ people; non-compliance with corrective orders) — nearly 3.3x the current cap. Criminal sanctions: up to 5 years imprisonment. Penalty structures differ by regulator and violation type — read each law's full page for the cure periods and per-violation detail.
When does each law take effect?
GDPR Article 22 — effective 2018-05-25. South Korea PIPA — effective 2011-09-30, enforcement from 2024-03-15. Dates last verified against official sources on 2026-08-22 and 2026-08-22 respectively.
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