Hello, this is Attorney Lee Young-kyung of Cheongchul Law Firm.

On September 29, 2026, the Korea Fair Trade Commission (KFTC) announced that it had decided to impose surcharges totaling KRW 219 million, together with corrective orders and publication orders, on two moving service companies (hereinafter ‘Company A’ and ‘Company B’) that ran false or exaggerated advertising or deceptive advertising about the price, number of users and quality of their moving services without any objective basis. The KFTC stated that it opened an ex officio investigation in March 2026 and that the advertisements in question were corrected through deletion or revision during the investigation. This case is instructive for every service business that runs online advertising, because it shows that in an ‘experience goods’ sector like moving services, where quality is hard to judge before use, the numbers and rankings that consumers tend to trust were in fact used without any basis.

Cheongchul Law Firm is composed of attorneys specializing in fair trade law who have both represented the KFTC and had the lawfulness of its dispositions upheld in court, and represented numerous companies in investigations, hearings and litigation. This column is based on the KFTC press release (dated September 29, 2026, for the morning papers of September 30), and the names of the individual businesses have been anonymized as Company A and Company B.

Case Summary at a Glance

● Stage: KFTC sanction decision (reported September 29, 2026)

● Investigation: Ex officio investigation into unfair advertising by moving service companies (March 2026)

● Applicable provisions: Act on Fair Labeling and Advertising Article 3(1)(i) (false or exaggerated advertising) and (ii) (deceptive advertising) (표시·광고의 공정화에 관한 법률 제3조 제1항 제1호·제2호)

● Measures: Surcharges totaling KRW 219 million (Company A KRW 132 million, Company B KRW 87 million) + corrective orders (orders prohibiting future violations) + publication orders

● Types of violation: ① false or exaggerated advertising about price ② deceptive advertising about awards ③ false or exaggerated advertising about the number of users

● Background: Consumer redress applications filed with the Korea Consumer Agency rose from 603 in 2023 → 785 in 2024 → 961 in 2025

1. Background – Characteristics of the Moving Service Market

A Market of Small Businesses with Low Entry Barriers

According to the KFTC's reference materials, the moving service market has low entry barriers and can be entered without major investment, so it consists mostly of small businesses; 67% of operators have capital or appraised assets of KRW 100 million or less. There were 3,475 moving cargo transport brokers as of the end of 2023.

A Transaction Structure Where the Brand and the Actual Service Provider Differ

Moving services are divided into directly operated, brokerage/dispatch, franchise/agency and platform models. The brokerage/dispatch model, in which the brand operator handles advertising, call centers, quotes and contracts while the actual transport is carried out by individual freight carriers or partner companies, is especially common in the industry. Under this structure, consumers often choose a company based on its advertising alone, so the price, ranking and user numbers shown in advertisements have a strong influence on their choice.

Experience Goods and Rising Consumer Harm

Moving services are experience goods whose quality is hard to assess before they are actually used. The fact that consumer redress applications to the Korea Consumer Agency have been rising every year was also part of the background to this ex officio investigation.

2. The Three Types of Advertising the KFTC Found Problematic

Type ① False or Exaggerated Advertising about Price (Company A)

From February 1, 2021 to April 13, 2026, Company A advertised on its website, blog and elsewhere using expressions such as ‘lowest price nationwide’, ‘minimum-price discounts on every type of move’ and ‘the most affordable way to move’, presenting its moving service prices as the cheapest in the industry without any objective basis. Superlative expressions such as ‘lowest price’ and ‘most affordable’ must be supported by objective data on what is being compared and as of when. In this decision, the problem was that such advertising continued for about five years without that basis.

Type ② Deceptive Advertising about Awards (Company B)

From January 1, 2021 to May 14, 2026, Company B advertised on its website and in search platform ads using phrases such as ‘Korea's no.1 moving brand’ and ‘No.1 in Korean quality satisfaction’. The KFTC found, however, that these phrases were merely the names of awards received from a particular organization, and that because the advertisements did not present information about the awards, such as the awarding body, the evaluation criteria and the method of selection, they misled consumers into believing that the company had been objectively rated as high-quality within the industry. A notable feature of this type is that it was classified as ‘deceptive advertising’ rather than ‘false’ advertising. Even where an award was actually received, the way it is presented can make the advertisement unlawful.

Type ③ False or Exaggerated Advertising about the Number of Users (Company A and Company B)

From October 2, 2024 to April 6, 2026, Company A described its cumulative consultation count in platform search ads with phrases such as ‘used by ○○0,000 people nationwide’ and ‘○○0,000 cumulative customers in 2026’, and from January 1, 2021 to May 12, 2026, Company B described its number of quote inquiries on its website with phrases such as ‘the happy choice of ○○ customers’. The KFTC found that these figures were merely counts of consultations or quote inquiries, yet were inflated to look like actual user numbers.

3. Applicable Provisions and Measures

The KFTC applied Act on Fair Labeling and Advertising Article 3(1)(i) (false or exaggerated labeling or advertising) and (ii) (deceptive labeling or advertising) (표시·광고의 공정화에 관한 법률 제3조 제1항 제1호·제2호). The measures consist of surcharges, corrective orders (orders prohibiting future violations) and publication orders.

● Company A: Surcharge of KRW 132 million, corrective order, publication order (advertising media: website, Naver blog, Naver, Google, Instagram)

● Company B: Surcharge of KRW 87 million, corrective order, publication order (advertising media: website, Naver blog, Naver, Google, Daum)

It is also worth noting that the advertising media were not limited to the companies' websites but spanned blogs, search ads, social media and other channels. Because the advertising ran for four to five years or more, the duration can affect how the violation period is calculated and the level of the surcharge, so regular reviews are needed to ensure that advertising copy is not simply posted once and then left unattended.

4. Takeaways from This Decision

Takeaway ① Secure Supporting Evidence before Using ‘Lowest Price’ or ‘No.1’

Superlative expressions such as lowest price, minimum price, No.1 and no.1 must be backed by objective evidence before advertising, including the scope of comparison, the surveying body, the survey date and the evaluation criteria. If there is no such basis, the expression should be toned down or removed.

Takeaway ② Present Awards with Information, Not Just the ‘Name of the Award’

The fact of having received an award can be advertised, but unless the awarding body, evaluation criteria and method of selection are presented together, consumers may mistake it for an objective quality assessment. Particular care is needed where the name of the award includes expressions such as ‘No.1’ or ‘satisfaction’.

Takeaway ③ Consultation and Quote Counts Are Not ‘User Numbers’

Presenting quote inquiries or consultation counts as if they were ‘the number of customers who used the service’ can create the misimpression that actual user numbers are higher than they are. When using figures, clearly distinguish what was counted (consultations, quotes, contracts or completed services).

Takeaway ④ Prepare for Ex Officio Investigations – Self-Review and Correction before Any Investigation

In this case, the KFTC stated that the advertisements were corrected through deletion or revision during the ex officio investigation. However, correction does not exempt a company from sanctions for advertising that has already run, so reviewing advertising content in advance is the most effective form of risk management.

5. Checklist for Advertising Managers

● Is there objective data on the comparison targets and dates for price superlatives such as ‘lowest price’, ‘most affordable’ and ‘minimum price’?

● For claims such as ‘No.1’, ‘no.1’ and ‘No.1 in satisfaction’, are the source, surveying body, evaluation criteria and method of selection presented together on the advertisement?

● Are figures such as ‘used by ○○0,000 people’ and ‘cumulative customers’ based on actual completed services or contracts, or on consultation and quote inquiries?

● Are the same standards applied across all channels, including blogs, search ads and social media, and not just the website?

● Is advertising copy posted years ago regularly checked against current facts?

● When advertising copy is changed, are the change history and supporting materials retained?

6. Frequently Asked Questions (FAQ)

Q1. What evidence is needed to use the expression ‘lowest price’?

You need objective data on the range of competitors being compared, the date of comparison and the method of calculating prices. In this decision, the problem was that ‘lowest price nationwide’ and similar claims were advertised for a long period without such a basis.

Q2. If we actually received an award, can we advertise that we are ‘No.1’?

Even if the award is real, unless the awarding body, evaluation criteria and method of selection are presented together, consumers may be misled into thinking the ranking resulted from an objective evaluation. In this case, the KFTC treated this as ‘deceptive advertising’.

Q3. Can we advertise our number of quote inquiries as our number of customers?

Presenting inquiry counts as if they were actual user numbers can amount to advertising that inflates the facts. The safe approach is to state clearly what the figure measures.

Q4. Can we avoid sanctions by deleting the ads during a KFTC investigation?

In this case, too, the advertisements were corrected through deletion or revision, yet surcharges, corrective orders and publication orders were all imposed. Correction matters for preventing future violations and as a mitigating factor, but it does not automatically exempt past conduct from sanctions.

Q5. What is a publication order?

It is a measure requiring the business concerned to publicly announce the fact of its violation in a prescribed manner. Because it can affect consumer trust and brand reputation, it is a sanction that can be as burdensome as a surcharge.

7. Cheongchul Law Firm's Advisory Services for Labeling and Advertising Investigations, Hearings and Litigation

Cheongchul Law Firm is composed of attorneys specializing in fair trade law with extensive experience in advisory work, investigations, hearings and litigation representing both companies and the KFTC across the laws under the KFTC's jurisdiction, including the Act on Fair Labeling and Advertising (표시·광고의 공정화에 관한 법률). In the labeling and advertising field, we provide the following services.

● Pre-publication legal review of advertising copy, landing pages and search ads, and organization of supporting materials

● Response to KFTC ex officio and on-site investigations, and voluntary correction strategy

● Preparation of written opinions at the examination report and hearing stages, and representation in oral statements

● Representation in administrative litigation to revoke surcharges, corrective orders and publication orders

● Advertising compliance guidelines and employee training

If your company uses numerical or ranking expressions such as ‘lowest price’, ‘No.1’ or ‘number of users’, as in this moving service unfair advertising case, it is advisable to review your advertising as a whole before any investigation. Corporate officers who need assistance with responding to a labeling and advertising investigation or with a pre-publication review are welcome to contact Cheongchul Law Firm.