Selling trading bots in Korea, what must the seller register and what can the buyer get back?

2026-10-24

A contract and a laptop sit on a table. On one side is someone who wrote an auto-trading program and wants to sell it; on the other, someone who wants to buy it and plug it into their own account. Both have the same question.

How far does the law reach into this deal?

This post does not talk about prices or scams. It takes only what the Financial Services Commission and Financial Supervisory Service press releases, the E-Commerce Act and an exchange's terms say, and sorts it into the seller's side and the buyer's side. The rules are Korean ones.

1.Software sale, or financial investment business?

In a June 2025 press release listing violation types among quasi-investment advisers, the Financial Supervisory Service gave "sale of auto-trading programs that make trades automatically in the customer's account" as an example of unregistered discretionary investment management. A footnote names copy trading and AI stock auto-trading (2024 inspection of quasi-investment advisers).

The provision behind it is Article 17 of the Capital Markets Act.

Discretionary management: running an investor's assets for them. A program that trades by itself in the account counts.

The FSS guide for reporting illegal finance also lists "sale of auto-trading programs" as a report type (FSS report guide).

2.Seller's side: how filing differs from registration

A quasi-investment adviser only has to file with the Financial Services Commission under Article 101 of the Capital Markets Act. The FSS guide says that anyone not disqualified can start business after a simple filing (quasi-investment adviser overview).

Investment advisory and discretionary management are different.

They are financial investment businesses that must register with the Commission after meeting capital, major shareholder and professional staff requirements.

The fork narrowed on 14 August 2024. The amended Capital Markets Act that took effect that day allows quasi-investment advisers only to give non-individual advice to the general public through one-way channels (FSC press release).

Running a paid membership on a two-way channel such as SNS or an open chat room is regulated as investment advisory business. Doing it without registration makes the seller an unregistered adviser, facing up to three years in prison or a fine of up to 100 million won.

The filing itself got rules too. A filing with a false representative, name or officers is treated like no filing at all, with up to one year in prison or a fine of up to 30 million won. A filing is valid for five years, and renewal must be applied for between three months and one month before it expires.

Grounds for deregistration grew as well. A filing can be struck off if the seller ignores corrective orders under the E-Commerce Act, or receives two or more fines or surcharges within five years.

There are inspection figures. In 2024 the FSS inspected 745 quasi-investment advisers, found suspected violations at 112 of them, and has already referred the 18 firms facing criminal charges for investigation. By type, there were 16 cases of unregistered advisory business and 3 of unregistered discretionary management.

If the program places orders by itself in the customer's account, what the seller needs is discretionary management registration, and a quasi-investment adviser filing does not cover it.

!A filing number does not cover an auto-ordering program. The FSS lists that as unregistered discretionary management.

Anyone can look up a seller's filing on the FSS FINE portal (quasi-investment adviser filing lookup). It is also where a buyer should look before signing.

3.Buyer's side: can the money come back within seven days?

Article 17 of the E-Commerce Act lets a consumer withdraw from a distance purchase of goods or services within seven days of receiving the written contract (E-Commerce Act Article 17). If delivery came later than the document, the seven days run from delivery.

There is a digital content exception in item 5 of paragraph 2 of the same article. Once supply of digital content has begun, the consumer cannot withdraw against the seller's wishes. A program that has been downloaded and installed falls here.

The exception comes with a condition. Paragraph 6 requires the seller to state clearly, where the consumer can easily see it, that withdrawal is not possible, or to provide a trial product, and if those steps are missing the consumer can still withdraw even under items 2 to 5 of paragraph 2. If the checkout screen showed no notice limiting withdrawal, the seven-day right is still alive.

If what arrived differs from the listing or the advertisement, paragraph 3 applies. The deadline is three months from delivery, or 30 days from learning of the difference.

The Consumer Dispute Resolution Standards are the yardstick used when parties settle or a recommendation is made.

The computer software item says a defect raised within 10 days of purchase gets an exchange or a refund of the purchase price. A major defect within one year gets an exchange, or a refund if exchange is impossible (Consumer Dispute Resolution Standards).

The FSS investor notice covers refunds too. It says to refuse a contract that unfairly limits refunds, and to contact the Korea Consumer Agency over cancellation, refund and penalty disputes.

4.Exchange terms: paid transfer of programs and API keys

In its October 2023 revision, Upbit's Open API terms added to Article 6(3) that a user may not transfer, distribute or license a program that uses the Open API to others for a fee, and may not use a program obtained from others that way (Upbit Open API terms revision notice).

Article 6(4), new in the same revision, says account access information including the API key is for the user alone and may not be provided, disclosed, shared, transferred or delegated to anyone else. The developer centre notice says both the person who made such a program and the person who used it can face sanctions (Upbit developer centre notice).

Under the exchange's terms, the seller and the buyer are caught by the same clause together. Other exchanges' and brokerages' terms were not checked at source, so they are left out.

5.Lines to check before signing

Hiddenpick is a Windows program that keeps on its server the betting rules that pick owners do not make public, and runs them as they are on the PC of the person who received them through a referral code. It currently runs on Evolution live baccarat at Stake (stake.com). The Capital Markets Act rules above concern financial investment products, and Hiddenpick handles neither those nor exchange API keys. How it starts and stops is in the baccarat bot guide.

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