티메프 사태를 계기로 살펴 본 PG 및 이커머스 플랫폼의 정산자금 관리 개선 방안

The 2024 settlement delay incident involving TMON and Wemakeprice revealed critical structural vulnerabilities in the financial soundness and fund management systems of e-commerce platforms in Korea. The resulting damage amounted to approximately KRW 1.3 trillion, affecting more than 48,000 merchants. This event led to a sharp decline in consumer trust, weakened consumption, and deteriorating performance in the retail sector, underscoring the urgent need to reform the institutional framework governing the management of customer funds on e-commerce platforms. In response, the Korean government proposed amendments to the Electronic Financial Transactions Act and the Large-Scale Retail Business Act, including mandatory segregation of settlement funds, the imposition of payment deadlines, and enhanced regulation of payment gateway (PG) service providers. This study evaluates these legislative efforts by conducting a comparative analysis of regulatory frameworks adopted in major foreign jurisdictions. In China, e-commerce platforms are prohibited from paying merchants directly and are required to process payments through third-party payment institutions. Customer funds must be deposited in segregated accounts with the People’s Bank of China or qualified commercial banks to prevent unlicensed fund handling and double settlement. India mandates that non-bank e-commerce platforms obtain licenses from the Reserve Bank of India under the Payment Aggregator (PA) framework, and fully deposit customer funds into escrow accounts. Singapore, under its Payment Services Act, also requires e-commerce platforms to either obtain licenses or use licensed intermediaries for payment disbursement. Given these international practices, the current Korean legislative proposals still fall short in fully addressing settlement risk. First, sales proceeds should be treated as customer funds and be 100% segregated until disbursement. Second, direct payment by platforms should be prohibited in principle, with disbursements routed through external PG service providers. Third, the scope and definition of PG services must be clearly specified to close regulatory loopholes. Lastly, while mandatory settlement deadlines may be necessary in the short term, long-term regulatory approaches should encourage market-based incentives and flexibility. This study aims to bridge existing legal and institutional gaps in the management of settlement funds on e-commerce platforms and propose sustainable regulatory directions tailored to the evolving digital commerce environment.