Public Interest Audit Request on NPS’s Coal Exclusion Policy

On July 24, 2025, a group of 300 South Korean citizens filed a public interest audit request with Korea's Board of Audit and Inspection (BAI) pursuant to Article 4(1) of the BAI's Public Interest Audit Processing Regulations. Article 4(1) allows citizens to request an audit of the affairs of public institutions — including the duties of their affiliated public officials — where such affairs are deemed unlawful or improper. The request targeted the National Pension Service Fund Management Committee (FMC) and the National Pension Service (NPS), alleging that the FMC's December 19, 2024, resolution on coal investment restrictions was unlawful and contrary to the public interest.

Specifically, the petitioners contended that the FMC: (i) selected the weakest of three options proposed in a 2022 research report — restricting investment only in companies where coal revenues exceed 50% of total sales, far below the international standard of 30%; (ii) added an unresearched five-year private engagement period before any investment restriction takes effect; (iii) deferred application to domestic assets until 2030; and (iv) failed to act on the research findings for over two years.The petitioners further alleged that, despite the FMC's own May 2021 coal-exit declaration, the NPS had significantly increased investments in coal-dependent companies — raising holdings in KEPCO bonds from approximately KRW 9 trillion to KRW 15 trillion, and increasing investments in major overseas fossil fuel companies (ExxonMobil, Shell, BP, Chevron, TotalEnergies) from approximately KRW 770 billion to KRW 4.2 trillion between 2020 and February 2024.

On November 5, 2025, the BAI closed all five claims without proceeding to a full audit. Claims on the 50% threshold and the 2030 domestic implementation timeline were dismissed as important policy decisions made through a rational deliberative process, exempt from audit review. Claim on the absence of implementation guidelines was closed after the FMC adopted internal guidelines on September 30, 2025. Claim on the alleged failure to report or discuss the 2022 research findings for over two years was rejected on the grounds that the FMC had in fact conducted internal consultations through sub-committees and relevant agencies during that period. Finally, the claim on increased investments in coal-dependent companies after the 2021 coal-exit declaration was closed because a civil damages lawsuit raising the same issues (Kim Min et al. v. Kim Tae-Hyun et al.) had become final on July 12, 2025, rendering the matter a confirmed case excluded from audit review.