The South Korean government said the Yellow Envelope Law is stabilizing after more than 100 days of implementation [1].

The law aims to improve working conditions for subcontracted workers by expanding the definition of an employer. Its stability is critical as business groups feared a surge in labor disputes and fragmented bargaining units across the industrial sector.

Government officials said there has been no explosive increase in bargaining demands or excessive subdivision of bargaining units [1]. According to government data, 439 primary contractors received bargaining requests from subcontractor unions [1]. The majority of these requests arrived early in the process, with 363 requests filed in the first month after the law took effect [1].

Activity slowed in subsequent months. The government recorded 42 additional bargaining requests in April [1] and 23 more in May [1]. These figures suggest that the initial wave of filings has subsided, a trend the government uses to argue the law is settling into the current economic landscape.

Despite the reported stability, the law is beginning to produce concrete legal precedents. On June 15, the Central Labor Committee recognized Hanwha Ocean as the employer for subcontracted cafeteria workers [1], [2]. This decision acknowledges the primary contractor's responsibility toward workers employed by a third-party vendor.

Labor groups had long advocated for the legislation to give indirect employees more leverage. Conversely, management groups expressed concern that the law would lead to a "tsunami" of demands that could disrupt corporate operations [1].

The government continues to monitor the impact of the legislation on industrial relations. While the number of new requests has decreased, the Hanwha Ocean ruling indicates that the law will continue to shift the legal boundaries of employer liability in South Korea [1], [2].

“The government said there has been no explosive increase in bargaining demands.”

The recognition of Hanwha Ocean as a 'user' or employer for subcontracted staff marks a pivotal application of the Yellow Envelope Law. While the government is highlighting a decline in the volume of new bargaining requests to soothe business concerns, the actual legal shift allows subcontracted workers to bypass their immediate employers and negotiate directly with the companies that control their working conditions. This creates a precedent that could gradually expand the liability of primary contractors across various sectors of the South Korean economy.