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Comparing Special Regulatory Zone Systems in Korea and Japan Focusing on Direction, operational system, and institutional design

  • Journal of Regulation Studies
  • 2025, 34(2), pp.69~107
  • DOI : 10.22954/ksrs.2025.34.2.003
  • Publisher : 한국규제학회
  • Research Area : Social Science > Public Administration
  • Received : October 24, 2025
  • Accepted : December 15, 2025
  • Published : December 31, 2025

Lee, Hyukwoo 1

1배재대학교

Accredited

ABSTRACT

Both Korea and Japan actively utilize special regulatory zones. Korea primarily employs a decentralized strategy, excluding the Seoul metropolitan area for balanced regional development. In contrast, Japan adopts a centralized strategy that includes its metropolitan areas to drive national growth around key hubs. In terms of operation, Korea often uses a bottom-up approach led by local governments, whereas Japan's top-down approach, directly led by the Prime Minister, has enabled powerful regulatory reforms to tackle so-called "bedrock regulations." Additionally, while Korea's regulatory design has been limited by a "menu-based" system that only permits pre-defined regulations, Japan has allowed for flexible additions to regulations and introduced regulatory sandboxes, enabling innovative experiments. Based on these findings, Korea's special regulatory zone system should be improved by reconsidering the exclusion of the Seoul metropolitan area, establishing a strong, presidential-level regulatory reform framework, and pursuing flexible and comprehensive regulatory reform. Ultimately, special regulatory zones should serve as a crucial tool for enhancing national competitiveness alongside regional revitalization, requiring a comprehensive approach that combines regulatory relief with financial support.

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