100 Days Since Yellow Envelope Act Enactment: 1,161 Bargaining Requests from Subcontractor Unions

363 in March, 42 in April, 23 in May
Minister Kim: "No Negotiation Tsunami as Feared"
12 Out of 29 Workplaces Approved for Bargaining Unit Separation

One hundred days after the implementation of the Yellow Envelope Act, it has been tallied that 1,161 subcontractor unions have requested negotiations with 439 principal workplaces. This averages 2.6 requests per principal company. Kim Younghoon, Minister of Employment and Labor, commented, "Contrary to some concerns, there has been no negotiation tsunami or reckless splitting of negotiation units."

Kim Young Hoon, Minister of Employment and Labor, is attending the Emergency Economic Headquarters meeting and the Economic and Real Estate Ministers' meeting held at the Government Seoul Office in Jongno-gu, Seoul, on the morning of the 15th. Photo by Yonhap News Agency

The Ministry of Employment and Labor announced on June 22, 2026, the results of its analysis of requests for negotiations by subcontractor unions at principal workplaces following the revised Trade Union and Labor Relations Adjustment Act, which took effect on March 10. Most requests were concentrated in the first month of implementation (March 10–31), targeting 363 principal workplaces, with an additional 42 in April and 23 more in May. On average, there were 2.6 negotiation requests per principal workplace (with an average of 375 union members per workplace). Of these, 249 workplaces (56.7%) were from the private sector and 190 (43.3%) from the public sector. By umbrella union, the breakdown of negotiation requests was as follows: Korean Confederation of Trade Unions (KCTU) at 47.0%, Federation of Korean Trade Unions (FKTU) at 43.6%, and unaffiliated unions at 9.4%.

After the negotiation requests, 141 principal workplaces underwent labor commission procedures regarding user status and related matters. Among these, 103 workplaces were recognized as employers by the labor commission (including cases involving requests for correction of non-disclosure and applications for separation of bargaining units). Excluding 32 workplaces that have not yet received the commission's written decision, 54 out of the remaining 71 are conducting bargaining channel unification procedures in accordance with the commission's judgment. Of these, 51 have completed the bargaining channel unification process and are currently in practical discussions regarding negotiation agendas and schedules. Ten workplaces, including Incheon Metropolitan City Medical Center, have entered the main negotiation phase, including introductory meetings. A Ministry of Employment and Labor official stated, "Other companies currently undergoing bargaining channel unification are either in the process of announcing the final list of unions requesting negotiations or going through procedures to determine the lead negotiator union, so it is expected that negotiations will begin soon."

Meanwhile, among the 439 principal workplaces where negotiations were requested, 256 have not undertaken additional follow-up measures such as applying for correction at the labor commission. A Ministry of Employment and Labor official explained, "Rather than negotiations being uniformly delayed or principal companies refusing to follow procedures, it appears that in many cases, parties are waiting to see the outcome of preliminary labor commission decisions or the results of government-labor consultations, depending on the circumstances of each industry and workplace."

The labor commission has decided on whether to separate bargaining units for 29 principal workplaces. Of these, separation was approved for 12 workplaces (41.4%). In terms of the types of separation, the most common was separation by business division (9 workplaces), followed by separation by umbrella union (2 workplaces), and by individual union (1 workplace), depending on the specific application.

In cases where bargaining unit separation was recognized, the units were generally split into two. The largest case so far has involved three units. For the 12 principal workplaces where separation was approved, the average number of bargaining units was 2.2. A Ministry of Employment and Labor official assessed, "There has been no sign of excessive fragmentation of bargaining units."

Minister Kim stated, "When the labor commission has made a decision, I hope management will actively participate in negotiations between the parties, in line with the intent of the amended law for coexistence and the principle of labor-management autonomy, rather than waiting for a court ruling." He also urged, "Unions should focus on agendas where the principal company has practical control or decision-making power, and strive to achieve substantive problem-solving and negotiation outcomes."

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