It was confirmed on the 11th that global online platforms AliExpress and Trip.com issued "coins" that effectively function as payment instruments under the Electronic Financial Transactions Act while not registering as prepaid service providers with the financial authorities. Both companies claim they meet the legal exemption requirements. However, observers point to a regulatory gap because the structure prevents financial authorities from directly verifying this.
According to industry sources, AliExpress awards coins through shopping activities or game participation, and Trip.com provides Trip Coins depending on airline ticket and lodging reservations, writing reviews, participating in promotions, and so on. Users use them to deduct payment amounts at checkout. They can be used repeatedly like cash. The structure of being awarded as a reward for specific actions and actually used could fall under the category of payment instruments under current law.
The Electronic Financial Transactions Act requires operators who issue and operate prepaid electronic payment instruments to register with the Financial Services Commission. Registration entails regulations such as funds protection measures, subscription to refund guarantee insurance, and reporting issuance records. In principle, issuing without registration is illegal. However, registration obligations are exempt under some conditions, such as if the place of use is limited to a single merchant, if annual issuance is under 50 billion won, and if the quarter-end balance is under 3 billion won.
Trip.com said Trip Coins are reward/accumulation-type points rather than rechargeable funds and are not subject to registration obligations, and that their use is limited to the Trip.com platform, meeting the statutory exemption requirements. It added that because there are no prepaid funds, they are not subject to the obligation to manage payment guarantee insurance, and that Trip Coin details and expiration dates can be transparently checked through the My account. It also said it subscribes to travel guarantee insurance for domestic operations and renews it annually.
AliExpress said it met one of the requirements that allow participation in coin issuance and management without separate registration under the Electronic Financial Transactions Act, and that it continuously monitors the entire coin issuance and management process to strictly comply with relevant laws and regulations. It added that it is continuously strengthening internal control procedures for transparent and responsible operation and is prioritizing the protection of consumer rights.
However, industry players and experts regard this as an arbitrary interpretation. The law is based not on whether charges are made but on whether consumers can use the instrument repeatedly. Accordingly, reward and accumulation-type points can qualify as prepaid electronic payment instruments if they meet certain requirements. Claiming an exemption merely because something is "not rechargeable" is not persuasive, they say.
In particular, the coins issued by AliExpress and Trip.com differ from free giveaway points in that they are rewards linked to actual transaction and consumption activities, not simple event-based credits. Because they accumulate and are used repeatedly as users make more payments and reservations, it is reasonable to classify them effectively as prepaid electronic payment instruments.
Trip.com's claim of "platform-limited use" also effectively involves payments at numerous merchants worldwide because it is connected to thousands of hotels, airlines and local vendors. AliExpress likewise allows coins to be used with numerous marketplace sellers and partners, making it difficult to meet the "single merchant" requirement. An industry source said travel guarantee insurance is limited to guaranteeing refunds for canceled travel products or insolvency, and is not a mechanism to guarantee against the risk of Trip Coins becoming irredeemable, noting that it is entirely different from the refund guarantee insurance required by law.
Key indicators such as issuance volume and balances are managed at overseas headquarters levels, making it difficult for the Financial Supervisory Service to directly examine the situation. Trip.com Korea and Alibaba Korea disclose some accounting information as audited entities, but this is limited to domestic marketing and operations and does not include the scale of coin issuance, balances or whether guarantees exist.
A Financial Supervisory Service official said they are looking into the issuance amounts and balances of the coins to determine whether Alibaba Korea and Trip.com Korea are exempt from registration as prepaid service providers under the Electronic Financial Transactions Act.
Consumer protection measures are also incomplete. AliExpress says it has a debt payment guarantee contract, but that does not apply to credit card transactions. There are also criticisms that Trip.com circumvents payment instrument functions by allowing gift card purchases through changes in country and language settings.
A domestic online travel agency industry official said the problem is the structure in which foreign platforms can interpret exemption criteria arbitrarily and financial authorities cannot verify it, arguing that while domestic companies are forced to accept responsibility, foreign platforms operating the same functions effectively outside the system create a regulatory discriminatory disadvantage.
Oh Jung-geun, a professor in the Department of Financial IT at Konkuk University, said the current structure, in which financial authorities cannot even ascertain whether exemption requirements are met, threatens consumer protection and fair competition, and that in such circumstances consumers who suffer losses after using coins would find it difficult to obtain refunds or compensation because standards are unclear.
Kim Jae-seop, a People Power Party lawmaker, said the current system allows overseas platforms to claim they meet the exemption requirements with no way for financial authorities to directly verify it, calling it a loophole that is close to a voluntary reporting system. He said he will work in the National Assembly to revise the system so registration and supervision can be determined based on actual usage patterns.