"100 days of the Yellow Envelope Act: wave of Central Labour Relations Commission rulings on principal employer status", 18 June 2026

As the amended Trade Union Act — known as the "Yellow Envelope Act" — marked 100 days since its entry into force on the 17th, a stream of appeal rulings is emerging on the question of whether principal contractors qualify as the true employers of subcontracted workers.

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As of that date, 27 cases seeking appeal rulings on principal employer status had been filed with the Central Labour Relations Commission (CLRC). (…) If the CLRC upholds principal employer status on appeal, however, the company in question must initiate collective bargaining proceedings. Failure to do so may constitute an unfair labour practice.

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Since the Yellow Envelope Act came into force, bargaining demands from subcontractors' unions directed at principal employers have risen sharply, yet those that have actually proceeded to the bargaining table remain a tiny minority. According to the Ministry of Employment and Labour, between 10 March — the date the amended act took effect — and the 5th of this month, unions at 1,137 subcontracted workplaces had demanded bargaining with 431 principal employers. Of these, only 81 principal employers had publicly posted notice of the bargaining demand, and a mere 8 had actually entered into negotiations.

On that day, the CLRC upheld in their entirety the initial rulings recognising the principal employer status of Posco, Incheon International Airport Corporation, Donghee Auto, and Ewha Hakdang, among others. The decisions represent a succession of findings — across cases spanning different industries — that principal contractors qualify as the true employers of subcontracted workers' unions.