On July 26, 2026, the Art Services Business Registration System came into effect under the Art Promotion Act. Businesses operating in six categories—galleries, art auctions, art advisory services, art rental and sales, art appraisal, and art exhibitions—are now required to register with the relevant local authority.
 
To minimize confusion arising from the introduction of the new system, the government will provide a one-year grace period through July 25, 2027. During this period, businesses will be informed of registration procedures and sector-specific obligations, and administrative penalties will not be imposed. Once the grace period ends, however, unregistered business operations or violations of statutory obligations may be subject to sanctions, including the suspension of business activities. The system is intended to provide a clearer understanding of the art services sector, strengthen transaction standards and consumer protection, and use the resulting information as a basis for future policies and support programs.
 
The inclusion of art service businesses—many of which had previously operated outside a formal, sector-specific registration framework—within an institutional system is significant. Yet it remains unclear whether the new system will provide a foundation for the growth of the Korean art market or function instead as another administrative regulation and barrier to market entry.
 
Registering businesses will not automatically make art transactions transparent. Nor will stronger administrative oversight generate market confidence on its own. Even when the stated purpose of a policy is reasonable, the field may experience it primarily as control and restriction rather than activation if it fails to reflect the actual operating structure of the art ecosystem.
 
Before implementing the registration system, the Ministry of Culture, Sports and Tourism held regional briefing sessions. However, the fact that briefings and consultations took place does not necessarily mean that the diverse realities of the art field were fully reflected in the policy. Galleries, auction houses, artists, independent curators, small exhibition spaces, appraisal professionals, and collectors all operate under different conditions. Whether the system adequately addresses those conditions must be assessed by examining how carefully the government identifies and corrects administrative burdens, sector-specific blind spots, and conflicts with existing policies during the grace period.
 
The one-year grace period should therefore be more than a temporary suspension of penalties. It should serve as a substantive period of review in which problems encountered in the field are investigated, the effectiveness of the system is reassessed, and the necessary complementary policies are developed.
 
 
 
A Single Policy Cannot Transform the Market
 
The art market is not simply a place where works are bought and sold. It is a complex ecosystem in which artistic production and exhibitions, contracts and settlements, appraisal and authentication, taxation and accounting, artwork records and provenance, public museum acquisitions, support programs, overseas promotion, criticism, and archives are closely interconnected.
 
If business registration is strengthened in isolation while standard contracts, payment settlements, the accountability of appraisal institutions, tax standards, artwork records, transaction information, and public museum acquisition procedures remain unchanged, the market’s fundamental problems will persist. The result may simply be the addition of another administrative procedure.
 
 
The problem with Korean art policy is not a lack of institutions or support programs. Public organizations such as the Arts Council Korea and the Korea Arts Management Service have played important roles in supporting artistic production, international exchange, overseas promotion, market development, and professional training.
 
However, support programs, the market, and museums have often operated separately from one another. It is frequently unclear how works produced through public support are documented and circulated after an exhibition, how overseas exhibitions lead to criticism, research, acquisitions, and long-term international networks, or how accumulated information is used in subsequent policies and market analysis.
 
When new obligations are introduced without fundamental structural reform or coordination with related policies, they are likely to be experienced in the field as control and burden rather than support. A single policy cannot transform the entire market. Registration, contracts, taxation, settlement, appraisal, authentication, public collecting, and transaction-information policies must move together.
 
The Art Promotion Act already provides a legal basis for standard contracts, consumer protection, certificates of authenticity, market surveys, and an integrated art information system. The important task is not to implement each provision separately, but to ensure that they function together as a coherent structure within the actual art ecosystem.
 
 
 
A Market Without Transparent Prices Cannot Be Analyzed
 
One of the most significant structural limitations of the Korean art market is the difficulty of determining how much artworks have actually sold for.
 
In the auction market, auction listings and winning bid prices are publicly available. In the primary market, however—particularly in galleries and art fairs—information on whether a work has been sold and at what final price generally remains known only to the parties involved. Transactions conducted directly by artists, through art advisers, or between corporations and private individuals are also difficult for outsiders to identify.
 
The listed price of a work may differ from the final contract price, while discounts, installment payments, exchanges, and other transaction conditions are rarely disclosed. There is also a lack of systematic information that would allow collectors or researchers to determine when comparable works by the same artist were sold and at what prices.
 
The Korea Arts Management Service operates K-ARTMARKET, the Korean Art Market Information System, which provides market analysis, reports, statistics, and auction results. Users can access information on recently auctioned works from major Korean auction houses, including artists’ names, titles, and winning bid prices, while the annual art market survey provides time-series data on the overall scale of the market. These initiatives have made an important contribution to building an information base for the Korean art market.
 
Yet the publicly accessible data remain largely concentrated on auction results. Transactions by galleries and art fairs may be reflected in aggregate statistics such as total sales and the number of works sold, but users cannot access individual transaction records showing which work by which artist was sold, when the sale took place, and at what price.
 
This is not solely a limitation of K-ARTMARKET. It reflects a structural problem in the Korean art market, where actual transaction data from galleries, art fairs, and direct artist sales are not consistently collected, verified, and accumulated according to common standards.
 
Without reliable sales-price data, it is difficult to analyze changes in prices and transaction volumes across artists, generations, and artistic genres. It is equally difficult to evaluate the difference between primary-market and auction-market prices, the actual expansion or contraction of the market, or the genuine level of demand for a particular artist.
 
Collectors lack sufficient information to assess whether a price is reasonable. Artists may also be unable to determine at what prices and under what conditions their works are circulating. Policymakers, meanwhile, are forced to estimate the size of the market on the basis of incomplete samples and voluntary survey responses.
 
Statistics, analysis, and forecasting must all begin with reliable primary data. A market in which actual sales prices cannot be verified cannot be accurately analyzed, and a market that cannot be analyzed cannot be reasonably forecast.
 
 
 
Public Art Museums Must Also Explain How Prices Are Determined
 
Transparency is not a principle that applies only to the private art market. Public art museums that acquire works with public funds also have a responsibility to explain, in a reasonable manner, how works are selected and acquisition prices are determined.
 
In a recent civil petition submitted through Korea’s national e-People petition system, an artist stated that a public art museum had twice proposed an acquisition price more than 65 percent below the artist’s initial proposed price, without providing a sufficient explanation of the valuation criteria or the reasons for the adjustment.
 
The artist was not simply asking the museum to pay a higher price. The request was for standard guidelines governing public museum acquisitions, explanations of the criteria and reasons applied when prices are adjusted, and written notification following the review process stating the reasons for selection or non-selection and the basis for any price adjustment.
 
According to the Ministry of Culture, Sports and Tourism, the National Museum of Modern and Contemporary Art, Korea conducts acquisitions through a three-stage process involving a value assessment committee, a price advisory committee, and an artwork acquisition review committee. The ministry stated, however, that the development of standard guidelines for all public art museums, as well as the disclosure of committee members and individual assessment details, should be approached cautiously in consideration of the independence of deliberation, privacy protection, and potential effects on the art market. It also explained that actual transaction prices and recent sales records would be reviewed, and that opinions from art historians and specialists in relevant fields would be sought when an artist had only a limited market history.
 
This case alone is not sufficient to conclude that the museum’s valuation was improper. Public museums operate within budgetary constraints, and an artist’s proposed price may legitimately differ from an institution’s assessed value.
 
However, the existence of a review procedure does not necessarily mean that those affected by it can understand or trust how it works. When a price is substantially adjusted, the institution should be able to explain, within reasonable limits, what data and valuation principles were applied and through what process the final decision was reached.
 
Fairness is not achieved merely by establishing a procedure. Public confidence emerges only when fairness is accompanied by accountability.
 
The acquisition of works by public art museums is not simply a purchasing transaction. It is an act of selecting the cultural heritage of a particular period and preserving it within the public record. It may also have a long-term effect on an artist’s career, art-historical evaluation, and market pricing. The processes of selection, valuation, and documentation must therefore maintain a careful balance among professional expertise, institutional independence, and transparency.
 
 
 
For the System to Become a Foundation for the Art Industry, Not Another Regulatory Burden
 
For the Art Services Business Registration System to contribute to the development of the art industry, it must go beyond registration and enforcement. The system should not merely count the number of businesses. It should also enable the accumulation of actual transaction data and artwork records, which can then be used for market analysis and policy development.
 
At the same time, immediately disclosing every private transaction price and the identity of every buyer would not be realistic. A graduated information system is required—one that protects personal information, commercial confidentiality, and the autonomy of price negotiations while still generating sufficient data to analyze the market as a whole.
 
One possible approach would be to require businesses to report basic artwork information and actual transaction prices confidentially to the relevant authority. Publicly accessible data could then provide anonymized statistics such as price ranges, median prices, transaction volumes, and rates of price change, while excluding information that could identify buyers. Art fairs, overseas promotion programs, and public museum acquisitions funded by public money should be subject to more detailed disclosure of sales results and valuation criteria.
 
K-ARTMARKET should also move beyond its present role of providing auction results and market-survey statistics. It should develop into a national art-market data infrastructure that connects transaction information from galleries, art fairs, public art museums, and publicly funded projects.
 
A standardized identification system for individual works is also necessary so that basic artwork information, certificates of authenticity, exhibition histories, transaction records, and changes in ownership can be connected. Procedures for verifying omissions and false reporting will be required, but new administrative costs must not simply be transferred to small galleries and individual artists.
 
If registration duties are imposed, the government should also provide standard contracts, accounting and tax guidance, accessible digital reporting tools, and systems for managing artwork records. Rather than merely adding regulation, it must build the administrative and technological infrastructure that allows market participants to comply with and benefit from the system.
 
Above all, an ongoing consultation mechanism should be established during the one-year grace period, involving not only major galleries and auction houses but also small and mid-sized galleries, independent spaces, regional exhibition businesses, artists, and curators. Problems arising during implementation should be investigated, and administrative guidelines and related policies should remain open to revision.
 
The effectiveness of the policy should not be assessed by the number of registered businesses or the volume of penalties imposed. It should be measured by whether transactions and settlements have become more transparent, whether reliable price information has been accumulated, whether the burden on small operators has been reduced, and whether previously fragmented public support and market systems have begun to connect.
 
 
 
There Can Be No Internationalization Without Industrialization
 
A market is a space in which artworks are exchanged, but an industry is a system in which creation and distribution, contracts and settlements, appraisal and authentication, collecting and documentation, policy and capital circulate continuously within an interconnected structure.
 
For Korean art to evolve from a market into an industry, systemization, rationalization, and capitalization must operate together on the basis of reliable information and data.
 
Systemization means managing artworks, transactions, institutions, and businesses according to consistent standards. Rationalization means making the grounds for pricing, deliberation, appraisal, and settlement objectively explainable. Capitalization—understood here as the accumulation and reinvestment of resources—does not simply mean raising the prices of artworks or transforming art into a financial product. It means ensuring that the capital and achievements invested in artistic production, research, professional personnel, archives, exhibitions, and distribution are reinvested in and accumulated within the broader ecosystem.
 
The Art Services Business Registration System may become a starting point for this process of industrialization. Yet without transparent transaction information, accountable public museum acquisition procedures, standard contracts and settlement practices, artwork record management, and stronger connections between public support and the market, it may ultimately be experienced as little more than another layer of regulation.
 
Korean art already possesses accomplished artists, museums, galleries, and support systems. What is lacking is not the individual components themselves, but a transparent and rational system capable of connecting them.
 
A market in which actual sales prices cannot be verified cannot be properly analyzed. A market that cannot be analyzed cannot be forecast, and a market that cannot be forecast will struggle to attract long-term capital or build international confidence.
 
The task facing the Korean art world is therefore not simply to expand the size of the market. It is to determine how market transactions and achievements can be recorded, disclosed, and transformed into sustainable industrial assets—assets that allow creation and distribution, public collecting and research, public support and international exchange to circulate within a continuing structure.
 
Internationalization, in the end, is not a final stage pursued separately from industrialization. It is the result of a transparent and rational industrial system extending outward and connecting with the wider world. For Korean art to establish itself as an important center of artistic production and a sustainable cultural industry, it must first build an internal structure that participants both at home and abroad can trust.
 
In that sense, the direction Korean art must take is clear: there can be no internationalization without industrialization.
 
 
 
References
 
- Ministry of Culture, Sports and Tourism, “Art Services Business Registration System to Take Effect on July 26,” press release.
 
- Ministry of Culture, Sports and Tourism, “Regional Briefing Sessions on the Art Services Business Registration System,” press release.

- National Law Information Center, Art Promotion Act.
 
- National Law Information Center, Enforcement Decree of the Art Promotion Act.
 
- Korea Arts Management Service, Art Market Survey.
 
- Korea Arts Management Service, K-ARTMARKET: Korean Art Market Information System.

Jay Jongho Kim graduated from the Department of Art Theory at Hongik University and earned his master's degree in Art Planning from the same university. From 1996 to 2006, he worked as a curator at Gallery Seomi, planning director at CAIS Gallery, head of the curatorial research team at Art Center Nabi, director at Gallery Hyundai, and curator at Gana New York.

From 2008 to 2017, he served as the executive director of Doosan Gallery Seoul & New York and Doosan Residency New York, introducing Korean contemporary artists to the local scene in New York. After returning to Korea in 2017, he worked as an art consultant, conducting art education, collection consulting, and various art projects.

In 2021, he founded A Project Company and is currently running the platforms K-ARTNOW.COM and K-ARTIST.COM, which aim to promote Korean contemporary art on the global stage.