As South Korea prepares for the implementation of the Yellow Envelope Law (revised Labor Union and Labor Relations Adjustment Act), the Korean Airports Corporation has engaged in external consulting with the intention of structuring regulations to prevent recognition of outsourced workers as its 'users'. Critics argue that, despite the emphasis on 'model users' in the public sector, the corporation is attempting to evade collective bargaining by working to eliminate its recognized responsibility for these workers. On October 9, a report reviewed by Democratic Party lawmaker Jeong Jun-ho from the National Assembly’s Land, Infrastructure and Transport Committee revealed that the corporation’s strategy includes proposals about 'user identity management strategies and phased roadmaps' in light of the upcoming law.

The Yellow Envelope Law, which takes effect on October 10, stipulates that primary employers will be deemed 'users' if they substantially control or determine the working conditions of subcontracted laborers, thereby being obligated to engage in collective bargaining with their unions. The internal report asserts that if the Korean Airports Corporation’s subsidiary employees were acknowledged as users, it could lead to significant risks, which the corporation has defined as potential threats to their operational model. Specific risks outlined include involvement in staffing or tasking processes and the existence of verbal-based operational directives that pose risks of illegal contracting.

To address these risks, the report suggests amending relevant regulations to clarify 'supervision and direction' of subsidiaries to terms like 'consultation and requests' and advises shifting the evaluation focus from labor-related measures to performance management systems. Additionally, it emphasizes the need to secure proof to substantiate the denial of user identity and establish management frameworks in anticipation of potential legal disputes. The corporation has historically sought to avoid and evade negotiations with subsidiary unions, raising questions about its commitment to fair labor practices as it navigates this new legal landscape.