How to Comply with South Korea's English‑language Disclosure Requirement for KOSPI Companies (may 2026)

Last reviewed: July 27, 2026

From May 2026, a significantly larger group of KOSPI‑listed issuers must publish key corporate disclosures in English, a requirement that demands operational changes across legal, finance, investor‑relations and audit functions. Understanding how to comply with the English disclosure requirement in South Korea 2026 is now an immediate priority for in‑house counsel, company secretaries, CFOs and IR teams at every affected issuer. The obligation arises from the Financial Services Commission’s (FSC) phased expansion of mandatory English‑language disclosure rules, with Phase II taking effect on 1 May 2026 and capturing KOSPI‑listed companies meeting the prescribed total‑asset threshold.

This guide sets out the eligibility test, the documents you must translate, a step‑by‑step production workflow, realistic cost estimates and the common pitfalls that trigger regulatory action.

Overview of the English Disclosure Requirement KOSPI 2026

South Korea’s capital‑market regulators, the FSC, the Financial Supervisory Service (FSS) and the Korea Exchange (KRX), have introduced a phased framework requiring eligible KOSPI‑listed companies to file and publish certain disclosures in English alongside their Korean originals. The stated policy objective, as set out in FSC press releases published between January and March 2026, is to increase foreign investor access, improve market transparency and align KOSPI disclosure standards with international best practice. UNCTAD’s Investment Policy Monitor has flagged the measure as part of a broader effort by South Korea to strengthen investor‑disclosure obligations for foreign companies listed on KOSPI.

At its core, the compliance process follows six stages: confirm whether your company falls within scope; procure certified translations of the required documents; obtain legal and board‑level sign‑off; secure auditor review of translated financial statements; file the English disclosures via the KRX system; and establish ongoing investor‑communication workflows. The sections below break each stage into actionable steps with named owners, deliverables and realistic timeframes.

Eligibility and Requirements

Not every KOSPI‑listed company is captured immediately. The English disclosure requirement KOSPI 2026 Phase II expansion applies to issuers that meet both of the following conditions: they are listed on the KOSPI market (not KOSDAQ or KONEX), and their total assets, as reported in the most recent audited financial statements, equal or exceed KRW 2 trillion, the threshold cited in the FSC’s announcement of the Phase II expansion. Companies that were already subject to Phase I obligations (generally the largest KOSPI‑listed issuers by total assets) remain covered, and their scope may broaden to additional disclosure categories.

Determining the asset threshold

The threshold is applied on the basis of total assets as stated in the issuer’s most recent audited balance sheet. Industry observers expect that the relevant figure is the consolidated total‑asset figure where consolidated financial statements are the primary reporting basis, and the separate‑entity figure only where consolidation is not applicable. To perform the scope test, retrieve the total‑assets line from your latest audited annual financial statements, confirm whether the figure equals or exceeds KRW 2 trillion, and document the analysis in a short scope memorandum for board records. Where total assets are close to the threshold, engage external counsel to confirm the calculation methodology and any transitional provisions.

Foreign‑domiciled issuers listed on KOSPI

Foreign‑domiciled companies listed on KOSPI are subject to the same English‑language disclosure obligations, applied by reference to KOSPI listing status and the asset threshold rather than the issuer’s country of incorporation. In practice, foreign issuers face additional operational complexity: their audit reports may already be in English and prepared under IFRS, but must still be reconciled against the Korean‑language filings submitted to the KRX. Where a foreign issuer’s home‑country audit report differs in format or accounting treatment from KRX templates, coordination between the issuer’s Korean and home‑country counsel and auditors is essential. The KCMI’s research on continuous disclosure obligations highlights the growing role of foreign issuers in KOSPI and the importance of aligning cross‑border reporting standards.

How to Comply with the English Disclosure Requirement: Step‑by‑Step Filing Steps

The following six‑step procedure covers the end‑to‑end workflow from initial scope confirmation through to ongoing investor disclosure. Each step identifies the responsible function, key deliverables and typical duration.

Step 1: Scope confirmation and kickoff

Assign a project lead, typically the Disclosure Officer or Company Secretary, to own the English‑disclosure compliance programme. The project lead’s first task is to perform the scope test described above and prepare a scope memorandum confirming whether the company meets the KRW 2 trillion total‑asset threshold. At the same time, compile a complete inventory of all Korean‑language disclosures currently filed with the KRX and published on the company’s IR website. Map each document to the English disclosure requirement to produce a master list of items requiring translation.

Deliverables at the end of this step include: the scope memorandum (signed by the CFO or General Counsel); the master document list; and a project schedule with milestones aligned to the timeline and key deadlines discussed in the timeline section below. Circulate the schedule to the Board or Audit Committee for awareness and resource allocation.

Step 2: Translation and certified translation process

Select an external translation provider with demonstrated experience in financial and legal translation for Korean capital‑market documents. The translation process for KOSPI disclosures is not a simple language conversion, it requires precise rendering of accounting terminology, regulatory nomenclature and legal terms of art. Before translation begins, develop a bilingual glossary and style guide covering key financial line items, regulatory terms (such as “timely disclosure,” “material event” and “audit opinion”) and company‑specific terminology (product names, subsidiary names, business‑segment labels).

The glossary should be jointly approved by the Legal and IR functions to ensure consistency across all translated documents. Engage translators who can provide a translation certification or translator affidavit, a formal statement confirming the translator’s qualifications and attesting that the English text is a complete and accurate rendering of the Korean original. For large annual reports, allow 5–15 business days for initial translation, depending on page volume and complexity. Build in a buffer for terminology queries and revision rounds.

Common pitfalls at this stage include inconsistent translation of financial line items across different documents (for example, translating the same Korean accounting term differently in the annual report and the earnings presentation) and failure to update the glossary when Korean originals are revised before filing.

Step 3: Legal review and board approval

Once the translated documents are received, external counsel should conduct a line‑by‑line review against the Korean originals to verify accuracy, regulatory compliance and consistency. The legal review focuses on three areas: substantive accuracy (do the English numbers, dates and descriptions match the Korean versions exactly?); regulatory language (are required statutory phrases and disclaimers correctly translated?); and forward‑looking statements (are appropriate cautionary language and qualifications included in investor presentations and MD&A sections?).

After legal review, the translated documents must receive internal approval. For material disclosures, particularly the annual report and audited financial statements, the likely practical effect of the rule is that board or Audit Committee approval will be required before filing. Prepare a board resolution in the following form: “Resolved that the Board approves the English‑language versions of the [annual report / financial statements / timely disclosure] dated [date], as reviewed by external counsel, and authorises the Disclosure Officer to file same with the Korea Exchange and publish on the Company’s investor‑relations website.” The Company Secretary should retain a signed copy of the resolution in the corporate records.

Where the Audit Committee is separately constituted, early indications suggest that best practice is to route translated financial statements through the Audit Committee before board sign‑off, mirroring the approval workflow for the Korean originals.

Step 4: Auditor review and accounting cross‑checks

For translated audited financial statements, request that your external auditor perform a review of the English text against the Korean audited financials. This review, sometimes formalised as an auditor comfort letter on the translation, confirms that the translation does not introduce any material change in financial substance, that numerical data is consistent across both language versions, and that footnotes and accounting‑policy disclosures are correctly rendered.

While the FSC rules do not prescribe a specific form of auditor comfort, industry practice among major Korean audit firms is moving towards providing a short‑form letter confirming the accuracy of translated financials. The CFO should coordinate this step in parallel with the legal review to avoid sequential delays. Allow 3–10 business days for auditor review, depending on document volume and the auditor’s workload during peak filing season. Reconcile any footnote discrepancies before proceeding to filing.

Step 5: Filing and publication

File the approved English disclosures through the KRX electronic disclosure system (the same portal used for Korean filings). The Disclosure Officer should confirm the required file format (PDF is standard; HTML may also be required for certain filings) and ensure that file‑naming conventions comply with KRX templates. Simultaneously upload the English documents to the company’s investor‑relations website, ensuring that English and Korean versions are cross‑referenced and that publication dates are synchronised. The filing steps for each disclosure event should be completed within 1–2 business days after final approval.

Where the KRX disclosure rules prescribe a deadline for filing the English version relative to the Korean filing, confirm the applicable time window and diarise the deadline. For investor disclosure purposes, publish the English version as close to the Korean filing date as practicable.

Step 6: Investor communications and ongoing compliance

After publication, the IR team should issue a brief notification to analysts, institutional investors and any English‑language distribution lists confirming the availability of the English disclosure. For earnings releases, prepare a bilingual press release and schedule an English‑language Q&A session or conference call where the company’s investor base includes significant foreign participation.

Update the company’s internal disclosure SOPs to embed the English translation and approval workflow as a permanent process, not a one‑off project. Assign ongoing ownership to the Disclosure Officer and schedule quarterly reviews to capture any changes in regulatory requirements or KRX filing templates.

Documents Needed for English Disclosure Compliance

The table below sets out the full list of documents that may require English translation under the disclosure requirement, together with notes on who issues each document, format requirements and practical considerations.

Maintaining a document tracker, a simple spreadsheet mapping each item to its Korean source, translator, reviewer, approval status and filing date, significantly reduces the risk of missed or inconsistent filings.

Timeline and Key Deadlines for the English Disclosure Requirement

The statutory effective date for Phase II of the English disclosure requirement is 1 May 2026, as announced by the FSC. From that date, newly captured KOSPI issuers must file English‑language versions of covered disclosures in accordance with the timelines prescribed by the KRX disclosure rules.

In practice, companies should treat the effective date as a backstop and aim to have their English‑disclosure production workflow fully operational before 1 May 2026. The table below provides recommended lead times for the most common disclosure events.

For annual‑cycle disclosures (annual report, governance report), build the English translation into the existing annual‑reporting project plan. The critical path typically runs: Korean draft finalised → translation commissioned → legal review → auditor review → board approval → filing. Compression is possible if translation and legal review overlap, but auditor review should follow legal review to avoid rework.

For ad‑hoc timely disclosures (material events such as M&A announcements, profit warnings or changes in major shareholders), the KRX expects the English version to be filed as close to the Korean filing as practicable. The recommended approach is to draft the English version concurrently with the Korean original so that both can be filed within the same trading day or within 1–3 business days. Companies that routinely deal with material‑event disclosures should maintain template English‑language drafts for common event types (board changes, dividend declarations, earnings revisions) to accelerate turnaround.

Diarise key dates, including the annual‑report filing deadline, quarterly earnings dates and the 1 May 2026 effective date, in the corporate calendar and assign explicit ownership of each filing deadline to the Disclosure Officer.

Costs, Fees and Tax Considerations

The cost of complying with the English disclosure requirement varies by issuer size, disclosure volume and the complexity of the company’s financial statements. The table below provides estimated cost ranges based on market rates for certified translation, legal review, auditor comfort and IR‑website localisation in South Korea.

Professional fees incurred for translation, legal review and auditor comfort are generally deductible as ordinary business expenses under Korean corporate tax rules. However, companies should confirm the specific deductibility treatment and any documentation requirements with Korean tax counsel, particularly where fees are paid to foreign service providers.

What Changes in 2026: The Phase II Expansion

The English disclosure requirement KOSPI 2026 framework follows a phased approach announced by the FSC. Phase I, introduced earlier, applied to the largest KOSPI‑listed issuers by total assets and covered a narrower set of disclosure categories. Phase II, effective 1 May 2026, expands the obligation to KOSPI‑listed issuers with total assets of KRW 2 trillion or more, substantially increasing the number of companies within scope.

For companies previously exempt, the Phase II expansion means immediate action is required. The recommended sequence for newly captured issuers is as follows:

1. Perform the scope test (total‑asset check against the KRW 2 trillion threshold) within one week of the FSC’s final announcement.
2. Allocate budget for translation, legal and auditor costs in the current fiscal year.
3. Engage a certified translation provider and brief external counsel on the company’s disclosure calendar.
4. Notify the Board and Audit Committee and secure a standing resolution authorising the Disclosure Officer to coordinate English filings.
5. Establish the production workflow described in the step‑by‑step procedure above, with target go‑live before 1 May 2026.

The FSC has indicated that further phases may follow, potentially lowering the asset threshold or extending the obligation to KOSDAQ‑listed issuers. Companies approaching but not yet meeting the KRW 2 trillion threshold should monitor FSC announcements and consider early voluntary compliance to avoid a rushed implementation if the threshold is reduced.

Common Pitfalls and How to Avoid Them

• Late translations. Filing the Korean disclosure on time but missing the English‑version deadline is the most common compliance failure. Mitigation: draft Korean and English versions concurrently; maintain standing translation arrangements with pre‑agreed turnaround times.
• Inconsistent numbers between Korean and English versions. Numerical discrepancies, even rounding differences, between the two language versions can trigger regulatory queries and investor confusion. Mitigation: run a line‑by‑line numerical reconciliation as a discrete quality‑assurance step before filing.
• Missing board resolution. Failing to record board approval for translated disclosures creates a governance gap that may surface during FSS inspections. Mitigation: include English‑disclosure approval as a standing agenda item at each board meeting where disclosures are approved.
• No auditor comfort on translated financials. Publishing translated financial statements without auditor review exposes the company to the risk that translation errors are treated as misstatements. Mitigation: engage the external auditor early and include the comfort‑letter step in the project plan.
• Data privacy breaches in English publications. English disclosures that include personal data (director names, contact details, shareholder information) must comply with the Personal Information Protection Act (PIPA) and PIPC guidance on cross‑border data transfer. Mitigation: have the Legal or Privacy Officer review every English document against the PIPC checklist before publication.
• Inadequate IR coordination. Publishing the English disclosure without notifying analysts and institutional investors undermines the policy objective and wastes the compliance investment. Mitigation: integrate English‑disclosure publication into the IR communication calendar and issue a distribution notice for each filing.

If a compliance failure does occur, for example, an incorrect English disclosure is published or a filing deadline is missed, the remediation sequence is: prepare a corrected English disclosure immediately; publish a corrective notice on both Korean and English channels; record corrective board minutes; notify the KRX and FSS if the error was material; and engage external counsel to manage regulator communications and minimise penalties.

Sources

1. Financial Services Commission (FSC), Press Release on English Disclosure Expansion
2. Korea Exchange (KRX), Disclosure Rules and KOSPI Listing Rules
3. Financial Supervisory Service (FSS)
4. Personal Information Protection Commission (PIPC)
5. UNCTAD, Investment Policy Monitor (Korea)
6. Korea Capital Market Institute (KCMI), Continuous Disclosure Paper