Busan-gwangyeoksi

Jeollanam-do

Gyeonggi-do

Daegu-gwangyeoksi

Gyeongsangbuk-do

Gangwon-teukbyeoljachido

Sejong

Incheon-gwangyeoksi

Gyeongsangnam-do

Chungcheongbuk-do

Gwangju-gwangyeoksi

Jeju-teukbyeoljachido

Chungcheongnam-do

Daejeon-gwangyeoksi

Seoul-teukbyeolsi

Jeollabuk-do

Ulsan-gwangyeoksi

South Korea

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On January 20, 2026, Solutions for Our Climate (SFOC), a climate advocacy group, filed a complaint with the Financial Supervisory Service (FSS) against NICE Investors Service and Korea Ratings, alleging that their credit rating reports for Samcheok Blue Power's unsecured corporate bonds violated Article 335-11(1) of the Capital Markets Act and Article 8-19-9(1) of the Financial Investment Business Regulations by assigning an A+(Stable) rating in a manner inconsistent with their own publicly disclosed rating methodologies.

The complainant argued that the A+ rating was driven by an inflated business risk grade of 'AA' that was not reasonably possible under the agencies' own published methodologies once three critical negative factors were properly weighted: (i) the government's 2040 coal phase-out policy, formally declared at COP30 in November 2025, which would force Samcheok Blue Power into early closure within approximately 15 years — far short of its 30-year design life; (ii) the prolonged delay in the East Coast transmission line construction, which had already been extended to at least June 2027 and had resulted in an actual operating rate of their power plants less than 15% as of mid-2025; and (iii) the risk to retail investors, who had become the primary buyers of the bonds as institutional investors withdrew on ESG grounds. 

On March 26, 2026, the FSS closed the complaint without finding a violation, concluding that while the two parties disagreed on the assumptions and methodology underlying the rating, no explicit violation of the Capital Markets Act was identified, noting that  the agencies acknowledged the coal phase-out policy as a key factor but stated they would reassess business risk only if the forthcoming 12th Basic Plan for Electricity Supply and Demand contained concrete adverse changes for Samcheok Blue Power.

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. 

On April 29, 2025, Consumers Korea, a consumer group, filed an unfair terms review request with the Korea Fair Trade Commission (KFTC) against five major non-life insurers — Samsung Fire & Marine Insurance, DB Insurance, Hyundai Marine & Fire Insurance, Meritz Fire & Marine Insurance, and KB Insurance — seeking a declaration that the natural disaster exclusion clauses in their Personal Automobile Insurance Policies (Articles 8(1)(4), 14(5), 19(5), and 23(3)) are unlawful and void under Articles 6 and 7(2) of the Terms and Conditions Act, and an administrative guidance that the clauses be deleted or amended.

The petitioner's core argument was that the traditional "force majeure" justification for such exclusions is no longer tenable: the respondent insurers have themselves materially contributed to the climate crisis — and thereby to the increased frequency and severity of natural disasters such as typhoons, floods, and wildfires — through their insured emission and financed emissions attributable to underwriting and investing in fossil fuel industries, making it unjust for them to invoke force majeure to deny coverage for losses caused by the very disasters their own activities have helped intensify, while profiting from selling separate natural disaster riders to policyholders who seek coverage that should already be included in the base policy.

On June 11, 2025, the KFTC closed the petition without a full review on the ground that it is impossible to conduct a review based solely on the submitted petition.

On February 7, 2025, a group of South Korean youths and shareholders of Korea Gas Corporation (KOGAS), a state-owned gas company, filed an injunction application to block KOGAS’s board resolution to invest USD 562 million in the Mozambique Area 4 Coral II (North) FLNG project. The plaintiffs argued that the investment violated their rights, including environmental rights under the Constitution and related statutes, as well as shareholder rights to dividends, and posed risks of irreparable economic and environmental harm. They emphasized the urgency of intervention due to Mozambique’s political instability, weak governance, declining global LNG demand, and prior project failures.

The plaintiffs contended that the board resolution exceeded the company’s proper authority and breached directors’ fiduciary duties. They argued that environmental rights require protection against overseas investments that create substantial ecological risks, the resolution constituted mismanagement threatening company value and dividends, and urgent relief was needed because the investment could not easily be undone once executed. They also highlighted that participation of other international companies made unilateral reversal difficult and that the project’s continuation could exacerbate environmental harm and international disputes.

On July 17, 2025, the Daegu District Court dismissed the plaintiffs’ application, finding that they did not have a legally recognized right to challenge the board resolution. It held that environmental rights and statutory provisions did not create enforceable claims for the board resolution at issue and that the plaintiffs failed to demonstrate sufficient urgency to justify injunctive relief, as potential economic and environmental harms were either speculative or addressable in the main litigation.

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South Korea

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