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On September 3, 2026, the Ministry of Employment and Labor (MOEL) issued new guidelines elaborating the scope of "labor disputes" under the Trade Union and Labor Relations Adjustment Act (TULRAA), entitled the "Guidelines on the Scope of Labor Disputes, Including Company Performance-Based Bonuses" (New Guidelines). For context, the latest amendments to the TULRAA—also known as the Yellow Envelope Act—significantly expanded the scope of permissible "labor disputes" by including disagreements concerning the "determination of working conditions" (e.g., wages, working hours, welfare, termination and employee status) as well as "managerial decisions that affect working conditions." Since the Yellow Envelope Act took effect on March 10, 2026, labor unions have increasingly sought to bargain over matters that are traditionally viewed as falling within the realm of management-level decision-making – e.g., bonuses tied to a certain percentage of operating profit or strategic investment decisions made by management. As these topics have garnered more public attention in recent months, there has been considerable confusion about the meaning and scope of "managerial decisions" over which employers must engage in collective bargaining under the amended TULRAA. The New Guidelines—built upon the general interpretive framework set out in its earlier guidelines issued in February 2026—represent the MOEL’s latest attempt to provide more concrete standards for interpreting and applying the amended TULRAA in the context of collective bargaining, labor-dispute mediation, industrial action, and unfair labor practice proceedings. Below, we address key aspects of the New Guidelines and their practical implications for employers.    

1. Whether Profit-Based Bonuses Fall Within the Scope of Permissible "Labor Disputes"

    Profit-based bonuses can take various forms depending on how their eligibility, calculation, amount, and timing are structured. Such wide variance has created uncertainty as to whether—and under what circumstances—such bonuses would fall within the scope of permissible "labor disputes" requiring employers to engage in collective bargaining.     The New Guidelines clarified that:     ■ Bonuses directly linked to a fixed percentage of company profits—such as revenue, operating profit, or net income—generally fall outside the scope of "labor disputes." MOEL reasoned that requiring employers to bargain over such demands could result in a fundamental restriction against a company’s managerial freedom to conduct its business or interfere with the rights and interest of third parties, including shareholders.     ■ In contrast, MOEL reiterated that concerning employees’ wages, benefits, bonuses tied to individual performance (or fixed bonuses) or other terms and conditions of employment do fall within the scope of "labor disputes" and therefore require employers to engage in collective bargaining.  

2. Meaning of "Managerial Decisions Affecting Working Conditions"

    MOEL’s earlier guidelines issued in February 2026 took the position that a "managerial decision" may become subject to a labor dispute where it results in "substantive and specific changes" to working conditions. Conversely, where the managerial decision’s potential impact on working conditions remains merely abstract or speculative at the time of the decision, the managerial decision would fall outside the scope of permissible "labor disputes".     The New Guidelines clarified that:     ■ As a general rule, a managerial decision, in and of itself, does not constitute a mandatory subject of collective bargaining. Thus, at a stage where a "managerial decision" is under review or merely announced, the mere possibility that the "managerial decision" may ultimately affect employees’ working conditions is insufficient to trigger an obligation to engage in collective bargaining.     ■ However, the "managerial decision" may become a mandatory subject of collective bargaining if it moves into the implementation stage and detailed plans (e.g., workforce arrangements) are formulated so that changes to employees’ working conditions can be objectively anticipated. The New Guidelines further illustrate how this framework is intended to operate in practice through examples such as corporate investments (e.g., plant establishment or relocation to abroad), business acquisitions or sales, or the introduction of new technologies like AI.  

3. MOEL’s Enforcement Approach

    The New Guidelines also explain how MOEL intends to approach cases where a labor union nevertheless seeks to bargain over a managerial decision itself or demands that a fixed percentage of company profits be allocated as bonuses:     ■ Mediation through LRC. At the mediation stage, the Labor Relations Commission (LRC) will encourage the union to modify its bargaining demands and present a reasonable alternative. If the union declines to do so, the LRC may issue administrative guidance (i.e. declining the union’s filing) on the basis that the relevant demand does not fall within the scope of permissible "labor disputes" under Article 2(5) of the TULRAA.     ■ Industrial Action Over Out-of-Scope Matters. Where a union engages in industrial action primarily to pursue matters that fall outside the scope of permissible "labor disputes," the legitimacy of such industrial action will be assessed in accordance with the standards established by Supreme Court precedent. In other words, industrial action may be found unlawful.     ■ Unfair Labor Practice Implications. An employer’s refusal to bargain over matters falling outside the scope of permissible "labor disputes" would not constitute an unfair labor practice, given that managerial decisions themselves (or demands for profit-based bonuses) do not trigger an obligation to engage in collective bargaining.  

4. Implications

    The New Guidelines provide meaningful clarification by confirming that profit-based bonus demands and managerial decisions with only an abstract or speculative impact on working conditions generally fall outside the scope of permissible "labor disputes".     That said, the New Guidelines are unlikely to eliminate uncertainty altogether for the following reasons:     ■ First, the exclusion for profit-based bonuses appears to focus on bonuses directly linked to certain profit metrics (e.g., revenue, operating profit or net income), potentially leaving room for unions to formulate bonus demands using other metrics.     ■ Second, because profit-based bonuses have not been categorically excluded and bargaining over this matter is not prohibited, unions may continue to pursue such demands alongside other matters that fall within the scope of permissible "labor disputes."     ■ Third, the legal basis for certain aspects of the New Guidelines may itself be subject to challenge, particularly as to whether MOEL has gone beyond the scope of authority delegated to it under the TULRAA. If these uncertainties persist, they may also lend further momentum to legislative proposals to amend the Korean Commercial Code to require shareholder approval for the payment of company performance bonuses that an employer is not contractually obligated to provide. Lee & Ko’s Labor and Employment Practice Group has been closely monitoring recent developments surrounding the amended TULRAA (i.e., Yellow Envelope Act) and continues to engage with clients through newsletters and seminars addressing key issues arising under the Yellow Envelope Act. On September 10, 2026, Lee & Ko will host a seminar on the Serious Accidents Punishment Act and the Yellow Envelope Act, where we will provide a more detailed explanation of the New Guidelines and discuss practical response strategies for corporate clients. Lee & Ko remains committed to providing clients with timely guidance and legal support as they navigate the amended TULRAA. If you need assistance with the New Guidelines or related labor-management issues, please do not hesitate to contact Lee & Ko. Author Chang Soo JIN Partner, Hyunseok SONG Partner, Young Jin KIM Partner, JungwooLEE Partner, William KIM Senior Foreign Attorney, Shawn HAN Senior Foreign Attorney

On July 3, 2026, the Seoul High Court (Court) rendered a significant decision (Case No. 2024Na2037832), holding that a delivery rider working through a delivery-agency platform qualifies as an “employee” within the meaning of the Labor Standards Act (LSA). The Supreme Court’s TADA ruling in 2024 (Case No. 2024Du32973) established the general framework for determining employee status of platform workers generally; this is the first decision applying the TADA framework to recognize a delivery-platform rider as an employee. The significance and ramifications of this decision are analyzed in greater detail below: 1. Rationale     In determining employee status, courts examine the substance of the parties’ relationship rather than its contractual form—specifically, whether the individual performed work to earn wages in a subordinate employer-employee relationship. Here, taking into account the particular characteristics of platform businesses, the Court pointed to several factors supporting a subordinate employer-employee relationship between the platform company (Company) and the delivery rider (Rider):     ■ The Company’s operation was not limited to matching riders with customers—it built and operated the entire delivery service platform, and Riders could work only through the Company’s application.     ■ The Company set key terms for the job in advance, including delivery procedures and compensation mechanisms.     ■ Through the application’s algorithm and direct instructions from managers, the Company exercised significant supervision and control over how Riders carried out their work.     ■ The Company exercised de facto control over Riders’ work hours and location through a combination of penalties and incentives.     ■ The circumstances did not support an independent-contractor characterization, since Riders’ operations depended entirely on the application and they were unable to develop their own clientele.     Importantly, the most decisive factor was the manner and extent to which the Company controlled and supervised the Riders in the course of their work. The ruling rests on the finding that the Company exercised direct control over how the work was performed—not just its outcome—based on evidence that the Company’s managers tracked Riders’ location, routes, and delivery counts in real time; used group chats to circulate work rules; encouraged Riders to cancel dispatch or log on for work; and, in some cases, directly canceled certain dispatches or blocked certain Riders’ ability to cancel their own dispatches. 2. Analysis     One of the key factors in determining employee status is the presence of the employer’s supervision and control. The Court’s ruling reinforces this stance; in an independent-contractor arrangement, the Company would be expected to evaluate only the outcome of the work. Here, however, there existed numerous instances in which the Company monitored and directly intervened in the process of the Riders’ work in real time, which the Court found to be a sufficient basis to recognize an employment relationship.     That said, there are several aspects of the Court’s reasoning that are vulnerable to criticism:     ■ In finding that the Riders were subject to the Company’s control, the Court cited not only the penalties used by the Company—e.g., limitations on the number of bundled deliveries a Rider could accept—but also incentives designed to encourage Riders to accept dispatches, characterizing both as evidence of “de facto compulsion” over Riders’ work hours and location.     ■ The Riders were given the freedom to decide whether to work or not as well as their own work hours. The Court did not assign sufficient weight on this factor, despite the fact that one’s freedom to decide work hours has typically weighed against a finding of employee status.     ■ The Riders were permitted to use multiple delivery platforms concurrently. The Court nonetheless found that the Riders were “exclusive” to the Company during the hours the Rider was logged into the Company’s application.     ■ The Court also stated that, pending legislative reform, courts should exercise greater latitude in applying the LSA’s framework rather than routinely denying employee status. This reasoning bears structural resemblance to the 2018 landmark JEI Corporation decision in which the Supreme Court expanded the scope of “employees” under the Trade Union Act. Importing such logic into the determination of “employee” status under the LSA—a narrower, more specifically defined concept—is likely to elicit criticism. More significantly, much of the Court’s reasoning was drawn not from the Company’s own management practices, but from the structural features of the delivery-platform business model. For instance, the Court pointed out that (i) Riders were integrated into the organization as workforce performing the Company’s core service function; (ii) the compensation structure was set unilaterally by the Company; and (iii) fluctuations in a Rider’s economic gains reflected the Company’s own policy choices, rather than business risk genuinely borne by an independent contractor. These elements are not unique to the Company—they are systemic features common to most delivery agencies or platforms that operate their own delivery teams. 3. Implications     If upheld by the Supreme Court, the legal framework the Court created could extend to other platform-based services—e.g., couriers, logistics, manpower provision. Moving forward, it remains to be seen whether structural factors alone—without clear evidence of supervision and control—will be sufficient to establish employee status in litigation. Given the growing momentum behind legislative proposals to introduce a “presumption of employee status” for gig workers—which would shift the burden onto companies to prove that a worker is not an employee—it is fair to expect that the Court’s ruling, if upheld, could have a far-reaching impact on platform business models across industries.     In light of this decision, platform companies are advised to proactively assess their employee-status risk before a dispute materializes. Because employee status determination is a fact-intensive inquiry that requires a closer look into the underlying circumstances of each case, companies should recalibrate their contract structure and operational practices to minimize the indicators of supervision and control that the Court relied on in this decision. In doing so, the following checklist may be a useful starting point:     ■ Field-level Supervision Practices         Whether local managers get directly involved in how the work is performed (e.g., location tracking, group-chat directives, or intervention in work decisions).     ■ Algorithm and App Design         Whether the application’s incentive structures or penalties could be perceived as “de facto compulsion” over work hours or location.     ■ Contract Terms and Structure         Whether the grounds and procedures for terminating a service agreement with independent contractors are clearly documented and properly structured. Lee & Ko’s Employment and Labor Practice Group has successfully handled a wide range of litigation and advisory matters concerning the employee status of platform workers. Drawing on this experience, we are able to offer practical, tailored solutions to the legal issues that may arise in the wake of this decision, as well as effective strategies for addressing them. Should you need any assistance in this area of law, please do not hesitate to contact Lee & Ko.

The amended Trade Union Act and Labor Relations Adjustment Act (Trade Union Act), scheduled to take effect on March 10, 2026, expands the scope of ‘employer’ to include ‘any person in a position to substantially and specifically control or determine the working conditions of employees’ (Article 2) and recognizes further grounds for labor disputes to include ‘business management decisions affecting working conditions’ (Article 5). To minimize concerns about increased legal uncertainty and reduced predictability arising from these significant amendments, the Ministry of Employment and Labor (MOEL) issued an administrative notice regarding its draft interpretive guideline (December 26, 2025 ~ January 15, 2026). Key points of the MOEL’s latest guidelines are as follows: 1. On the Expansion of the ‘Employer’ Scope     A. Key Criteria for Determining Employer Status         Article 2(2) of the Trade Union Act specifies ‘substantial and specific control over working conditions’ as the criterion for determining the ‘employer’ status. The MOEL has proposed ‘structural control over working conditions’ as a key factor for this determination.         ‘Structural control over working conditions’ is a criterion for determining ‘employer’ status that has been outlined for the first time in the latest guidelines. It establishes that ‘structural control’ exists when the principal contractor structurally constrains the subcontractor’s determination of working conditions for its workers, thereby fundamentally and continuously limiting the subcontractor’s discretion in setting those conditions. For example, this would include cases where: (a) where the number of the subcontractor’s workdays, etc. are determined unilaterally pursuant to the contract prepared by the principal contractor, and a non-compliance thereof may result in the termination of the relevant subcontract, such that changing the number of workdays, etc. through any mutual agreement between the subcontractor and the relevant workers is effectively difficult in practice; (b) where the working hours of the relevant workers are, in substance, determined by factors such as the volume of work, the number of logistics vehicles and their departure times under subcontracting agreements controlled by the principal contractor, including also the scale of work equipment and number of deployed or assigned personnel.         Conversely, when the principal contractor makes general requests or consults/coordinates with the subcontractor regarding the performance or procedures of the subcontracted work, such measures are understood as performance of contractual obligations, and are thus distinguishable from ‘structural control over working conditions’. Examples of such distinguishable acts include: (1) requiring compliance with agreed delivery deadlines and quality requirements; (2) amending subcontract terms through mutual agreement; (3) requesting work performance based on individual purchase or work orders, etc.     B. Factors and Cases to Consider when Determining Employer Status         In its draft interpretation guidelines, the MOEL explains that factors that Korean courts have to date regarded as indicia of employer status under the Trade Union Act—such as the subcontractor’s integration into the principal contractor’s business and the subcontractor’s economic dependence on the principal contractor—will now be considered as supplementary factors for assessing ‘structural control over working conditions’. Under this approach, circumstances such as (a) where the subcontractor is directly incorporated into the principal contractor’s business system, (b) where the principal contractor is the subcontractor’s sole customer, or (c) where the subcontractor’s continued existence depends on the continuation of the subcontract agreement with the principal contractor, may be taken into account in determining whether there is ‘substantive and specific control’ and ‘decision-making over working conditions’.         Furthermore, the MOEL provided several illustrative cases recognizing ‘employer’ status under the Trade Union Act, to facilitate practical use of the draft guidelines. For instance: where (a) from an occupational safety perspective, the principal contractor controls the overall safety and health management system, including work processes and safety procedures, or the subcontractor is structurally unable on its own to improve facilities or equipment by eliminating risk factors or installing safety devices; (b) from a welfare perspective, the principal contractor effectively determines subcontractor employees’ access to convenience facilities or exerts influence over the rules for use; (c) from a working-hours perspective, the principal contractor holds substantive decision-making authority over, or exercises approval rights in respect of, the subcontractor’s production planning, work schedules, working hours, break times, and overtime; or (d) from a compensation perspective, the principal contractor effectively determines labor costs based on the number of subcontractor workers deployed and their working hours, or directly sets wage increase rates or standards for various allowances, thereby fundamentally constraining the subcontractor’s managerial discretion.         These points are summarized in the table below. For more detailed information, please refer to the Attachment.   2. On the Expanded Scope of Recognized Grounds for Labor Disputes     A. Business Management Decisions Affecting Working Conditions         In its draft interpretation guidelines, the MOEL explains that ‘business management decisions as defined in Article 2(5) of the Trade Union Act’ may manifest as a series of combined actions. Among such actions, business management decisions that are subject to labor disputes should be assessed based on whether they cause substantive, specific changes to working conditions. If the impact on employees’ working conditions is merely abstract or speculative at the time of the decision, it would be difficult to recognize such a decision as a permissible ground for a labor dispute.         According to the MOEL’s view, a business management decision aimed to accomplish organizational restructuring (such as a merger, division, transfer, or sale) does not, in and of itself, readily qualify as having a substantive and specific impact on working conditions. Therefore, such decisions cannot be said to fall within the scope of collective bargaining. However, when implementing such a decision, measures that cause substantive and specific changes to employees’ status or working conditions (such as layoffs or reassignments arising from restructuring) may become subject to collective bargaining. In addition, labor unions would now be entitled to demand collective bargaining on employment-security measures not only where workforce adjustment is imminent as a result of a merger, division, sale, or transfer decision, but also where such adjustment is objectively foreseeable.     B. Determination of Working Conditions Related to Employee Status         In its draft interpretation guidelines, the MOEL explains that ‘disagreements over the determination of employee status’ refer to disputes between labor and management concerning the establishment or modification of principles, standards, or procedures related to changes in employment type, disciplinary actions, promotions, etc. The MOEL states that interest disputes concerning matters such as the conversion of non-regular employees to regular employees, and demands to establish or revise disciplinary and promotion criteria, are included within the scope of labor disputes.         Accordingly, once the amended Trade Union Act takes effect, labor unions are anticipated to demand collective bargaining or engage labor disputes not only regarding the conversion of non-regular employees to regular employees but also regarding a wider range of existing HR governance systems, including disciplinary actions and promotions.     C. Employer’s Violation of Collective Agreement         Where an employer clearly violates a collective agreement that stipulates matters relating to working conditions under Article 92(2) of the Trade Union Act – specifically, items (a) through (d) (including wages, welfare benefits, severance pay, working hours, dismissal, occupational safety and health, etc.) – such violation would become a subject of a labor dispute.         In its draft interpretation guidelines, the MOEL stipulates that ‘clear violation of a collective agreement’ may be found where the employer fails to comply with the collective agreement terms without a justifiable reason, despite the agreement’s language being unambiguous and leaving no room for alternative interpretation. Specifically, this includes situations where the employer acknowledges the violation yet refuses to comply, or where the violation is objectively confirmed during labor dispute mediation by the Labor Relations Commission or during labor-management negotiation guidance by local employment and labor offices. 3. Implications     The amended Trade Union Act, while expanding the scope of ‘employers’ and the grounds for labor disputes, provides only abstract criteria for determination, which has raised significant concerns that the legislative change would result in greater uncertainty in practice. Against this backdrop, MOEL’s draft interpretation guidelines are expected to help alleviate some of the difficulties and anxiety. However, as the draft guidelines are currently not yet finalized, they are subject to revision based on future feedback from labor and management. Therefore, continuous attention and monitoring are necessary. In response to the rapidly changing labor policies under the new administration, Lee & Ko acquired Ahn Kyung-duk – the former Minister of Employment and Labor – as a senior advisor on May 14, 2025, and launched a Labor Compliance Team. We have been continuously communicating with clients regarding the Trade Union Act and its Enforcement Decree through newsletters and client seminars. In addition to the MOEL’s draft interpretation guidelines, we anticipate that additional operational manuals for procedures related to the consolidated bargaining channels will be released soon. Lee & Ko will make every effort to communicate with our clients regarding these issues and provide necessary legal support. Should you require assistance regarding the content of the Trade Union Act (effective March 10, 2026), or related corporate response strategies, please feel free to contact us at any time. Attachment : Interpretative Guidelines for the Revised Labor Union Ace (Draft)

The National Assembly passed amendments to Articles 2 and 3 of the Trade Union and Labor Relations Adjustment Act (commonly referred to as the Yellow Envelope Act or the Labor Union Act), which are now pending promulgation and enforcement. The Yellow Envelope Act derives its name from the 2014 incident involving the SsangYong Motor strike, when citizens delivered condolences and support funds to workers in yellow envelopes in response to large-scale damage claims brought by the employer. The amendments substantially expand the definition of “employer,” significantly strengthen the autonomy of trade unions and the scope of lawful union activities, and impose broad restrictions on employers’ ability to claim damages against employees and unions. 1. Key Amendments to the Labor Union Act     ■ Expansion of the Definition (Article 2, Subparagraph 2)     ■ Relaxation of Requirements for Labor Unions (Article 2, Subparagraph 4)     ■ Expansion of the Scope of “Labor Dispute” (Article 2, Subparagraph 5)     ■ Limitation on Claims for Damages (Article 3)     ■ Exemption from Liability (Article 3-2) 2. Analysis and Outlook     ■ Expansion of the Scope of “Employer” (Article 2, Subparagraph 2)         Under the current Trade Union Act, only the direct employer has been recognized as the “employer.” However, under the amended Act, any person who has substantial and specific authority to control or determine employees’ working conditions will also be deemed an employer. As a result, labor unions composed of indirectly employed workers—such as subcontracted, dispatched, subsidiary, or affiliate employees—may demand collective bargaining not only with their direct employer but also with the principal contractor or parent company.         The precise meaning of “substantial and specific control or determination” as an element of the employer concept will inevitably be clarified in the future through decisions of the Labor Relations Commission and judicial precedents. In the interim, however, considerable uncertainty and disputes regarding its scope appear unavoidable.         From the corporate perspective, companies are recommended to:             ▶ Assess the impact of subcontracting structures on labor–management relations;             ▶ Review whether collective bargaining provisions under the Act apply when entering into new subcontracting arrangements; and             ▶ Consider the size and operating model of subcontractors to develop strategies that minimize the principal company’s legal exposure.             ▶ Given that similar risks are likely to recur, this is an opportune time for companies to conduct a compliance review of their labor relations management systems regarding subcontractors, subsidiaries, and affiliates, and to reinforce internal compliance processes accordingly.     ■ Strengthening of Rights to Join and Participate in Labor Unions (Article 2, Subparagraph 4)         The amended Act abolishes the existing restriction that prohibited non-employees from joining labor unions. As a result, workers in “special employment” relationships and platform workers will now be able to join labor unions.         This development not only affects individual companies but also has broader implications for entire industries where the use of special employment and platform workers is prevalent. Companies should therefore:         ▶ Review the operational practices across their industry regarding special employment and platform workers;         ▶ Strengthen channels of communication with such workers; and         ▶ Maintain transparency and actively share information about changes, thereby reducing the risk of conflict and tension in advance.     ■ Expansion of the Scope of “Labor Dispute” (Article 2, Subparagraph 5)         Under the current Trade Union Act, only the “determination” of working conditions was subject to labor disputes. The amendment expands the scope of labor disputes to include not only business management decisions that affect working conditions but also material breaches of collective agreements.         Originally, the amendments sought to encompass all matters relating to “working conditions” within the scope of labor disputes. However, due to concerns that this would excessively broaden the range of permissible industrial action and significantly increase the costs of workplace conflict, the scope was partially narrowed during the legislative process.         From the corporate perspective, companies are recommended to:         ▶ Conduct a comprehensive review of “working conditions,” with particular focus on provisions in collective agreements and rules of employment that were not previously subject to disputes;         ▶ Strengthen communication with labor unions or works councils, especially in relation to major managerial decisions such as mass layoffs, restructurings, mergers, acquisitions, and corporate spin-offs; and         ▶ Review the adequacy of disciplinary, dismissal, and occupational safety regulations in anticipation of a broader range of potential labor dispute issues.     ■ Limitation on Union Liability for Damages and Restriction on Damages Amounts (Article 3)         The amendment restricts employers from seeking damages against labor unions for losses arising from industrial action, thereby protecting unions and employees from large-scale damages lawsuits, except in unavoidable cases.         From the corporate perspective, companies are recommended to:         ▶ Review and update internal manuals on claims for damages, covering the entire process from the initiation to the conclusion of industrial action; and         ▶ Examine the internal decision-making procedures related to claims for damages to ensure alignment with the intent of the amended Act, and to establish a robust process for determining when and how such claims may be pursued.     ■ Exemption from Liability (Article 3-2)         A new statutory provision has been introduced allowing employers to voluntarily exempt labor unions or employees from liability for damages or other responsibilities arising from collective bargaining, industrial action, or other union activities. The intent is to alleviate employers’ concerns about potential criminal breach-of-trust claims when granting such exemptions. From the corporate perspective, companies may consider the option of liability exemption as one possible measure in the resolution of labor disputes.     ■ Effective Date         The amended Trade Union Act will take effect six months after its promulgation. However, the new provision allowing employers to exempt labor unions and employees from liability will apply retroactively to damages arising prior to the Act’s enforcement.         As the amendments address the scope of employers, the scope of labor disputes, and restrictions on claims for damages against unions, they represent a fundamental shift in the paradigm of labor–management relations. While the amendments are expected to significantly strengthen union autonomy and broaden the rights associated with union activities, they may also impose substantial burdens on companies. Employers should, therefore, ensure thorough preparation in advance and adopt appropriate response measures afterward to maintain sound and stable labor relations. 3. Conclusion     The amended Trade Union Act both fundamentally reshapes the paradigm of labor–management relations and reflects the broader policy direction of the new administration—many of its key elements had been anticipated. Lee & Ko established its Labor Compliance Team in May 2025, led by former Minister of Employment and Labor Ahn Kyung-Deok, to prepare for such sweeping changes in labor policy. Should you require assistance regarding the amended Trade Union Act, including its substantive contents or practical strategies for corporate response, please do not hesitate to contact the attorneys listed in this newsletter.