한국과 일본의 규제특구 제도 비교 -방향성, 운영체계, 제도설계를 중심으로-

Both Korea and Japan actively utilize special regulatory zones. Korea primarily employs a decentralized strategy, excluding the Seoul metropolitan area for balanced regional development. In contrast, Japan adopts a centralized strategy that includes its metropolitan areas to drive national growth around key hubs. In terms of operation, Korea often uses a bottom-up approach led by local governments, whereas Japan's top-down approach, directly led by the Prime Minister, has enabled powerful regulatory reforms to tackle so-called "bedrock regulations." Additionally, while Korea's regulatory design has been limited by a "menu-based" system that only permits pre-defined regulations, Japan has allowed for flexible additions to regulations and introduced regulatory sandboxes, enabling innovative experiments. Based on these findings, Korea's special regulatory zone system should be improved by reconsidering the exclusion of the Seoul metropolitan area, establishing a strong, presidential-level regulatory reform framework, and pursuing flexible and comprehensive regulatory reform. Ultimately, special regulatory zones should serve as a crucial tool for enhancing national competitiveness alongside regional revitalization, requiring a comprehensive approach that combines regulatory relief with financial support.