Korean regulators propose stricter on-site audits for ISMS-P certification

The Personal Information Protection Commission of South Korea has announced a plan to overhaul the Information Security Management System-Privacy certification process. This regulatory shift moves the audit framework away from a reliance on document review toward mandatory on-site verification of security controls. The proposed amendments to the Enforcement Decree of the Personal Information Protection Act will be open for public comment from September 16 to October 26.

Under the new rules, certification audits will combine written reviews with physical inspections. This change allows auditors to verify that security measures function correctly in actual operating environments, rather than just confirming their existence on paper. The Personal Information Protection Commission stated that this approach is designed to enhance the practical effectiveness of the certification system. The proposal builds on a strategic plan for strengthening certification effectiveness that was published in April.

The regulations specifically address companies that experience data breaches or security incidents while holding a valid certification. In such cases, qualified technical experts will be authorized to conduct on-site vulnerability assessments and simulated penetration tests. These technical inspections will utilize specialized diagnostic tools to identify weaknesses in the organization's infrastructure. The technical personnel performing these checks must hold intermediate or higher qualifications as defined by the Enforcement Rules of the Act on the Promotion of the Information Security Industry.

Post-certification audits, which are currently conducted annually, will also undergo similar changes. These ongoing reviews will permit the combination of written and on-site examinations. If necessary, auditors may also perform vulnerability checks during these annual reviews. This ensures that the security posture of certified organizations is monitored continuously, rather than only at the time of initial certification.

The proposed amendments also introduce a tiered approach to certification standards. Regulators will consider the scale of personal data processing and the potential social impact of a data breach when setting requirements. Organizations that process large volumes of data or could affect many users may be subject to stricter management and technical protection measures. This creates a legal basis for differentiating compliance standards based on risk profile.

The enforcement mechanisms for mandatory certification targets are also being adjusted. Companies that lose their certification will be granted a one-year grace period before administrative fines are imposed for failing to meet certification obligations. This delay is intended to give organizations time to rectify the issues that led to the cancellation and to implement preventive measures. However, this grace period will not apply to companies that obtained certification through fraud or dishonest means.

The Personal Information Protection Commission plans to gather feedback from relevant government agencies and industry stakeholders during the public comment period. Following this consultation, the commission will proceed with the legislative review process. Related notifications are also expected to be revised within the year to support the overall strengthening of the certification system. Public comments on the proposed amendments can be submitted through the National Participation Legislation Center, email, or postal mail until the end of the comment period.