The service told the office of Rep. Lee Jeong-moon of the ruling Democratic Party (DP) that open-ended conversation lacks the machinery that makes a game a game.
"Free conversation does not contain rules that evaluate user input, goals that must be reached, or outcomes such as success and failure," it said.
Korea's 2006 game law defines a game as a video work, or a device built to run one, made with information technology for amusement.
The word amusement alone cannot separate chat services from games, the service said, since webtoons, video and social media all carry the same label.
Where the apps borrow game grammar, the service drew a sliding scale.
Affection meters and anniversary logs are incidental staging such as level gates, dice rolls and branching endings begin to look like rules. Paid currency wagered on a probability outcome is the most likely to be pulled under the law, with gambling review to follow.
That places Crack's "cracker baking" event, in which users staked paid currency for a chance to multiply or lose it, on the boundary.
The service said the event is hard to classify outright as a gambling game because nothing leaves the app, while the Game Rating and Administration Committee said in August that such structures may constitute games.
Sexual and violent role-play, the harder complaint, falls outside the game law's reach either way.
Ratings must be issued before distribution, the service said, an impossible fit for content generated anew for every user, and the same problem blunts any attempt to register the apps as material harmful to youth.
Crack and Zeta ranked sixth and eighth by revenue in Google Play's entertainment category last month, and Crack operator Wrtn Technologies became the first non-game company to lead G-Star, Korea's largest game show.
AJP Takeaways
- The National Assembly Research Service said on Sept. 21, 2026 that AI character chat apps including Zeta and Crack are unlikely to qualify as games under South Korea's Game Industry Promotion Act.
- Paid currency wagered on a probability outcome is the feature most likely to pull such apps under the law, the service said, leaving Crack's "cracker baking" event on the boundary.
- Pre-distribution rating cannot apply to content generated anew for each user, the service said, leaving sexual and violent role-play outside the game law's reach.
Copyright ⓒ Aju Press All rights reserved.