Rep. Inchul Jo Proposes Bill to Include CDN Operators in Service Stability Obligations

“Including ‘CDN Operators’ in the Regulatory Framework to Strengthen the Digital Safety Net”

As global CDN (Content Delivery Network) and cloud outages increasingly disrupt daily life and industrial services in Korea, legislative efforts are underway to include CDN operators as entities responsible for ensuring service stability. The intent is to strengthen the digital safety net by bringing CDN operators—previously in a regulatory blind spot due to current law’s focus on “number of users”—under the regulatory framework.

Inchul Jo, a lawmaker from the Democratic Party of Korea (Gwangju Seo-gu Gap), announced on April 28 that he has sponsored a partial amendment to the Telecommunications Business Act to explicitly include CDN operators among value-added telecommunications providers required to ensure service stability.

Jo Incheol

CDN is a technology that temporarily stores content on cache servers deployed worldwide or across Korea, delivering data to users from the server closest to them. It serves as a core infrastructure underpinning a wide range of digital services such as OTT, gaming, e-commerce, and AI services.

The issue is that when failures occur in this infrastructure, the resulting damage is not limited to a single service, but can quickly spread across society—impacting aviation, finance, distribution, platforms, and other critical sectors of daily life and industry.

In fact, in July 2024, an outage of Microsoft’s cloud services caused delays and operational disruptions in domestic airline and gaming services. Similarly, in November 2025, a Cloudflare outage led to connection errors in major services such as ChatGPT and X (formerly Twitter), demonstrating a pattern in which global infrastructure failures repeatedly lead to user disruption in Korea.

Under the current Telecommunications Business Act, the obligation to ensure service stability is imposed on value-added telecommunications operators with an average of over 1 million daily users and at least 1% domestic traffic share, making major platform providers such as Google, Netflix, Facebook, Naver, and Kakao the primary targets of regulation.

However, due to the B2B (business-to-business) structure of CDN operators, they rarely have direct contractual relationships with end users, making it difficult to meet user number criteria. Even though they handle massive traffic volumes and have a significant impact on digital service stability, current standards have left a regulatory gap that excludes them from these obligations.

This amendment aims to address such structural problems by elevating the criteria for major value-added telecommunications operators from the current enforcement decree to the law itself and establishing CDN operators as newly regulated entities with service stability obligations.

Key provisions include stipulating in the law the existing criteria for major value-added telecommunications operators—over 1 million average daily domestic users and at least 1% domestic traffic share—while also newly designating as obligated parties those CDN operators who temporarily store and deliver copies of data from original servers to domestic cache servers for the provision of others’ information and communications services.

Notably, this legislation is a follow-up to what has been called the “Network Stabilization Act,” which Mr. Jo sponsored in January. While the previous bill focused on strengthening advance notification and stability obligations for actions by major value-added telecommunications operators that could significantly affect domestic communications services (such as rerouting traffic or withdrawing cache servers), the new amendment broadens the regulatory scope to include CDN operators, reinforcing stability mechanisms across the entire digital infrastructure.

Inchul Jo stated, “CDN and cloud outages are a digital infrastructure crisis that directly affects the nation’s core industries—aviation, finance, distribution—as well as daily life. Excluding CDN operators from the safety net simply because they do not meet the user number criteria, despite handling enormous traffic, is a regulatory approach disconnected from reality.”

This content was produced with the assistance of AI translation services.