Nexon's Risk Pages: Two New Headings and One Changed Word

３【事業等のリスク】, business and other risks, in the annual securities report of NEXON Co., Ltd. for its 24th fiscal year, January 1 to December 31, 2025, filed on EDINET on March 24, 2026, runs from page 26 to page 34 of 204. It has 16 numbered items, (1) to (16), six of which carry numbered sub-headings, 29 in all. The report for the 23rd fiscal year, calendar 2024, filed on March 27, 2025, prints the same 16 items under the same names in the same order on pages 25 to 32 of 200, with 27 sub-headings. Set side by side, the main changes are four: two sub-headings added under (3) 法的規制に関わるリスク, for the United States and the European Union; new paragraphs inside the China item and the personal-data item; three printed figures brought forward a year; and one changed word in the litigation item — alongside a year update in one sentence, a change of tense in the Korea sub-heading and five small wording edits, all described below. The passages that read the same in both years are named as they come.

The 16 items are, in the order both reports print them: (1) 事業環境に関わるリスク, the business environment; (2) 当社グループのサービスに関わるリスク, the group's services; (3) 法的規制に関わるリスク, legal regulation; (4) 事業体制に関わるリスク, the business structure; (5) 知的財産権に関わるリスク, intellectual property; (6) システム等に関わるリスク, systems; (7) ゲームの不正利用に関わるリスク, unauthorised use of games; (8) 訴訟に関わるリスク, litigation; (9) M&Aや業務・資本提携に関わるリスク, M&A and business and capital alliances; (10) 為替変動に関わるリスク, exchange rates; (11) 保有上場株式の株価変動に関わるリスク, price movements in listed shares held; (12) 暗号資産に対する投資に関わるリスク, investment in crypto-assets; (13) 法令・会計基準等の変更, changes in laws and accounting standards; (14) 自然災害や疾病の蔓延に関わるリスク, natural disasters and epidemics; (15) 新株予約権による希薄化に関わるリスク, dilution from share acquisition rights; and (16) NXC Corporationとの関係について, the relationship with NXC Corporation. The numbering style is the one visible difference at this level: the 23rd report numbers the items ① to ⑯ and their sub-headings ⅰ) to ⅸ), while the 24th report uses (1) to (16) and ① to ⑨. Sub-headings sit under (1), four in each year; (2), nine in each year; (3), six in the 23rd report and eight in the 24th; (4), four; (6), two; and (9), two.

The three opening paragraphs are the same in both years. The first begins 本書に記載した事業の状況、経理の状況等に関する事項のうち、投資者の判断に重要な影響を及ぼす可能性のある事項には、以下のようなものがあります — among the matters concerning the state of the business and of accounting described in this document, those that may have a material effect on investors' judgement include the following — and adds that matters not necessarily falling under such risk factors are also disclosed where they are thought important to an investment decision. The third states that the forward-looking matters in the text are the company's judgement as of the filing date and that the list does not cover every risk that may arise in the future. The sub-headings under (1) — market growth, the market environment, new entrants and competitors, technological change — read the same in both years, as do the intellectual-property item (5), both system sub-headings under (6), the unauthorised-use item (7), both alliance sub-headings under (9), and items (10) to (14).

Under (2), one sentence carries a new year and nothing else. ② 主要フランチャイズへの売上集中について, concentration of revenue in major franchises, states in the 24th report that the group's revenue depends heavily on some major franchises and that 2025年12月期では、『アラド戦記』(Dungeon&Fighter)、『メイプルストーリー』(MapleStory)及び『EA SPORTS FC™』が連結売上収益のうち、一定の高い割合を占めております — in the fiscal year ended December 2025, Dungeon&Fighter, MapleStory and EA SPORTS FC accounted for a certain high proportion of consolidated revenue. The 23rd report's ⅱ) names the same three titles for 2024年12月期. The remaining eight sub-headings under (2) — overseas expansion, seasonality, portfolio expansion, updating existing titles, service development, the item-charging model, reputational harm and fraudulent acts, and brand damage — read the same in both years, including the note under ⑧ defining リアル・マネー・トレーディング as trading game characters, items or in-game currency for real currency.

(3) 法的規制に関わるリスク opens with a paragraph, unchanged from the year before, that the group distributes or licenses PC online and mobile games in Japan, Korea, China, the United States, Europe and elsewhere and is subject to the regulation of those countries and regions, and then lists the regulations it regards as particularly important. The 23rd report listed six: ⅰ) 未成年者に関する法的規制について, minors; ⅱ) ゲーム内容の審査について, content review; ⅲ) ランダム型アイテムに関する法的規制について, random items; ⅳ) 中国における法的規制について, China; ⅴ) 日本における法的規制について, Japan; and vi) 韓国における法的規制について, Korea. The 24th report prints those six as ① to ⑥ and adds ⑦ 米国における法的規制について, the United States, and ⑧ EUにおける法的規制について, the European Union. The minors, content-review, random-items and Japan sub-headings read the same in both years apart from three small edits: gaming disorder becomes Gaming disorder in the WHO sentence, and in the Japan text 遵守したうえで becomes 遵守した上で and 遅れた場合、また becomes 遅れた場合や、.

⑦ 米国における法的規制について is new in the 24th report, on page 30. It states that state privacy laws exist, enacted or in the process of enactment, and that legal disputes have arisen under some of them against social-media operators and game operators; that states are considering regulation to curb いわゆる「依存性を高める設計要素」, so-called addictive design elements, in games and social media; and that major litigation is under way concerning the mechanisms by which Instagram and YouTube encourage continued user engagement, with some operators originally included having avoided trial by settlement. It then turns to games: multiple lawsuits have been filed concerning Roblox等のゲーム over the protection of minors and young users, with claims of グルーミング, grooming, exploitation, bullying and threats by adults, and legal action against Roblox by the Florida state authorities has been announced, whose final outcome, civil or criminal, は、現時点で必ずしも明らかではありません, is not necessarily clear at present. The company's own sentences follow: it treats user protection as one of its most important issues, and 今後、連邦又は州レベルにおいて、Roblox型サービス又はこれに類するソーシャルメディア／ゲームを対象とする新たな立法又は規制措置が導入される可能性があります — new legislation or regulatory measures aimed at Roblox-type services or similar social media and games may be introduced at the federal or state level. Such changes, the item closes, may affect service design, operation, monitoring and compliance costs in the group's United States business.

⑧ EUにおける法的規制について, also new and on the same page, states that regulatory demands are strengthening at both the EU and member-state level, centred on consumer and minor protection. It names three things: the European Commission's work towards a Digital Fairness Act (DFA) covering dark patterns, addictive design and unfair personalisation; progress in the operation of Digital Services Act (DSA) 第28条, Article 28 on the protection of minors, with Commission guidelines raising the practical level of compliance; and key principles on in-game virtual currencies published for the online-game industry by the network of member-state authorities the report prints as Consumer Protection Corporation(CPC), clarifying requirements on price display, information, consumer rights and consideration for minors. The consequences are stated as continual review of compliance in the group's global operations and possible additional work on product design, operating structure, monitoring and organisation. The item ends with the penalties the report attributes to the two regimes: for breaches of consumer law, turnover-linked fines under the EU's coordinated enforcement framework, in the report's phrase 少なくとも4%基準, an at-least-4-percent standard, with member-state law able to set a higher cap; for DSA breaches, fines on certain operators of up to 6 percent of worldwide annual turnover; and the possibility of collective redress through representative actions.

④ 中国における法的規制について keeps its first two paragraphs from the year before — the government's promotion of the domestic industry and restriction of foreign-developed games, the law effective May 1, 2017 strengthening supervision of online-game operation, the Online Games Ethics Committee (OGEC) set up in December 2018, and the group's partnerships with local distributors as its way of minimising the effect — and adds two. The first says that laws and administrative rules directly governing online games have recently taken effect or may be newly introduced or strengthened, and singles out 2024年1月1日に施行された未成年者保護に関する規制, the regulation on the protection of minors effective January 1, 2024, which imposes more detailed obligations on operators concerning the prevention of excessive play, the management of play time, and the curbing of unreasonable or excessive in-game spending; stricter interpretation or enforcement, it says, could place major constraints on game design, operation and monetisation and require additional development, operational adjustment or compliance cost. The second concerns the ゲーム版号(出版承認)制度, the game licence or publication-approval system, and the review standards for content and operating models, which can change with regulatory policy and administrative practice. It records that a draft regulation published in the second half of 2023 set out limits on certain reward mechanisms, spending practices and user-engagement features, that moves to revise it in the light of stakeholder opinion followed, and that similar measures may be reintroduced or partly adopted in future — in which case game development plans, launch timing, content updates, marketing and monetisation in the China business could be adversely affected, and games already developed or in distribution could be required to be modified, suspended or otherwise restricted at the regulator's request.

⑥ 韓国における法的規制について changes tense. The 23rd report's vi) stated that the ゲーム産業振興に関する法律 requires operators to disclose clearly the types of probability-based items and the supply probability by type, and that この法律は2025年8月1日に改正される予定で — the law was scheduled to be amended on August 1, 2025 — after which an operator breaching the display obligation would bear the burden of proving the absence of intent or negligence, with punitive damages of up to three times actual loss to be introduced for deliberate breaches. The 24th report's ⑥ prints the same rules as in force: the disclosure obligation 2024年3月22日より, from March 22, 2024, and the reversed burden of proof 2025年8月1日より, from August 1, 2025, with the sentence ending 負うことになりました, and deliberate breach carrying liability for punitive damages of up to three times actual loss. The sentence that follows in both years is the same: the amended 電子商取引等における消費者保護に関する法律 in force from February 14, 2025 prohibits ダークパターン, dark patterns, and requires prior consent for subscription price rises and for making free services paid. ③ ランダム型アイテムに関する法的規制について, which also names the March 22, 2024 amendment alongside Belgium, Slovakia and the Netherlands, is unchanged.

The longest addition is inside (4), under ③ 個人情報の保護について, the protection of personal information, on pages 31 and 32. Its opening — the personal data the group collects, the obligations of a 個人情報取扱事業者 under Japan's law, the Global Security Center and ISMS certification, the privacy policy on the website — reads as before except that its last words, 取組み姿勢を示しております, become 取組みを示しております; the paragraph on GDPR in force since May 25, 2018 is likewise as before, but the 24th report adds the acronym and one sentence: that a review of GDPR aimed at competitiveness and simplification, 特に個人データを用いて学習したAIモデル等に関する規制, particularly of the rules on AI models trained on personal data, has been pointed to as possibly taking place within the next year. Two regimes then appear for the first time. The デジタルサービス法(Digital Services Act: DSA), in force from February 17, 2024, is described as requiring a dedicated DSA page for reports of illegal content, prompt handling not relying solely on automated means, and an annual transparency report on the Commission's standard template, with fines of up to 6 percent of worldwide annual turnover; the report adds 当社グループでは、DSAページ及び透明性報告書の対応を進めております, the group is proceeding with the DSA page and the transparency report. The United Kingdom's オンライン安全法(Online Safety Act), enacted in October 2023, is described as imposing duties such as easy means of reporting problems on services where users post content or interact, with Ofcom's guidance on illegal-content risk assessment published in December 2024 requiring assessments of illegal-content and child risks by March 16, 2025 and July 24, 2025, and non-compliance carrying fines of up to £18 million or 10 percent of worldwide annual turnover, whichever is higher, and criminal liability for senior executives.

The United States passage is updated and the China passage is new. Where the 23rd report said that, after California, 約20州, about 20 states, had privacy laws in force, the 24th says 現在では、カリフォルニア州に続き、約26州が独自のプライバシー関連法を施行しており、その多くには児童のプライバシー保護を強化する特則が含まれています — about 26 states now have their own privacy laws, many with special provisions strengthening children's privacy; the California statutes and their dates are as before, and the sentence on calls for a uniform federal law that has yet to materialise now opens with また、 where the 23rd report had さらに. A new paragraph on China describes the 個人情報保護法（Personal Information Protection Law：PIPL）, in force since 2021, as requiring a clear privacy policy stating the purpose, method and scope of collection and how users exercise rights of copying, inquiry, correction, deletion and account cancellation, with explicit consent, additional consent for sharing with third parties and additional legal procedures for transfer abroad; and the データ安全法（Data Security Law）, also 2021, as requiring data to be classified and graded by importance and risk, with encryption, access control and security audits, and, for operators handling more than 1,000万件, ten million records of personal information, the appointment of a data protection officer, an annual data-security risk assessment and submission of the assessment report to the authorities. It lists the measures that may follow a breach found in the authorities' periodic inspections: publication, removal from app stores, fines, confiscation of illegal gains, suspension orders and revocation of the business licence.

The item's closing paragraph, on past incidents, is the same in substance in both years and differs in two words. The 23rd report said that これまでに, up to now, leaks of personal information such as names through employees' carelessness, and the outflow of many users' names and 暗号化済みの住民登録番号, encrypted resident registration numbers, through external hacking of group servers, had been confirmed; the 24th report says かつて, in the past, and 暗号化済みの識別番号, encrypted identification numbers. The consequence sentence — claims for damages from users, administrative sanctions, criminal penalties and the resulting loss of confidence — is unchanged. So are the other three sub-headings under (4): ① 人的資源について, human resources; ② 内部管理体制について, internal control; and ④ 特定人物への依存について, dependence on particular individuals, whose two paragraphs on officers and key developers leaving, or moving to competitors, read the same in both years.

(8) 訴訟に関わるリスク is one paragraph in both years and differs by one word. It lists the matters over which third parties may sue or the supervisory authorities may investigate: 契約の不履行、知的財産権の侵害、個人情報の漏洩、下請法違反、景品表示法違反及び労務問題等 in the 23rd report — breach of contract, infringement of intellectual property, leakage of personal information, breach of the subcontracting law, breach of the premiums and representations law, and labour matters — and the same list in the 24th report with 取適法違反 in the place of 下請法違反. The rest of the item, on the burden of litigation and investigation and on economic loss and brand damage should an adverse judgment, decision or ruling be made, is the same. (5) 知的財産権に関わるリスク, (7) ゲームの不正利用に関わるリスク and the two sub-headings of (6), システム障害について and プログラムの不具合について, are likewise unchanged.

(15) 新株予約権による希薄化に関わるリスク ends each year with one figure. The 23rd report: なお、2024年12月31日現在、新株予約権(自己新株予約権を除く)は発行済株式総数の1.9％の割合で付与されております — as of December 31, 2024, share acquisition rights, excluding those held by the company itself, had been granted in a proportion of 1.9 percent of the total number of issued shares. The 24th report prints 1.4％ as of December 31, 2025. The share pages give the denominators as printed: ② 発行済株式 on page 44 of the 23rd report shows 842,443,413 shares at December 31, 2024 and 822,664,966 at the filing date, with a note that a cancellation of treasury shares on February 28, 2025, resolved by the board on February 13, reduced issued shares by 19,911,683; page 47 of the 24th report shows 827,160,972 at December 31, 2025 and 792,606,357 at the filing date, with a cancellation on February 27, 2026, resolved on February 12, of 36,487,500 shares. Both notes add that the filing-date column excludes shares issued on exercise of share acquisition rights from March 1 of the filing year.

(16) NXC Corporationとの関係について opens each year with the same share count and a different ratio. The 23rd report: NXC Corporationの保有株式数は、2024年12月31日現在、248,462,800株(議決権比率30.1％)であり — NXC Corporation held 248,462,800 shares, a voting-rights ratio of 30.1 percent — and, the sentence continues, even including indirect holdings the company is not the filer's parent under the Companies Act or the Financial Instruments and Exchange Act. The 24th report prints 248,462,800株(議決権比率31.3％) as of December 31, 2025, with the same conclusion. The rest of the item is the same in both years: NXC Corporation is 主要株主かつ筆頭株主, a major and the largest shareholder, engaged in investment and other businesses unrelated to the group's online-game business; it holds the company-name trademark ＮＥＸＯＮ for Japan, licensed to the filer under a trademark licence agreement for a royalty calculated as a fixed ratio of the filer's 売上高, with the filer holding the right to extend the licence, and with NEXON Korea Corporation, Nexon America Inc. and other subsidiaries under similar agreements; and 上記使用許諾契約を除き、当社グループとNXC Corporationとの間において重要な財務及び事業の方針に関する経常的な取引はありません, apart from that licence there are no regular transactions between the group and NXC Corporation concerning important financial and business policy.

The same 248,462,800 stands in (6) 大株主の状況, the major-shareholder table, on page 67 of each report, at the head of the list with an address in Jeju, Korea, where the ratio column, headed 発行済株式(自己株式を除く。)の総数に対する所有株式数の割合(％), the proportion of the total issued shares excluding treasury shares, prints 30.1 for December 31, 2024 and 31.3 for December 31, 2025. (7) 議決権の状況, the voting-rights table, prints 総株主の議決権, total voting rights, of 8,254,555 at December 31, 2024 on page 68 of the 23rd report and 7,928,858 at December 31, 2025 on page 69 of the 24th, and, in its ② 自己株式等 table, treasury shares held in the company's own name of 16,958,500, or 2.0 percent of issued shares, and 34,253,200, or 4.2 percent. These are the figures as printed on those pages; this piece places them beside the risk item and draws nothing from them.

Method. The desk located the two annual securities reports in the EDINET document-list API for March 24, 2026 and March 27, 2025, retrieved the PDFs through the same API, and read them with pdfplumber: the cover (page 1), ３ 事業等のリスク (pages 26 to 34 of the 24th report, 25 to 32 of the 23rd), ② 発行済株式 (page 47 of the 24th, 44 of the 23rd), (6) 大株主の状況 (page 67 of each) and (7) 議決権の状況 (page 69 of the 24th, 68 of the 23rd). The two risk sections were compared sentence by sentence after removing whitespace and the item numbers, so that the change of numbering style from ① and ⅰ) to (1) and ① does not register as a difference; every difference the comparison produced is described above, including the five one-word or one-spelling changes (Gaming disorder in the minors sub-heading; 遵守した上で and 遅れた場合や、 in the Japan sub-heading; and, in the personal-data sub-heading, 取組みを示しております in place of 取組み姿勢を示しております and また、 in place of さらに before プライバシー関連の法律が各州で異なるため). Heading counts are the desk's counts of the printed headings; page numbers are those printed on the PDF pages. The statements about laws, courts and regulators in the new passages are the company's descriptions, reproduced as such, and the desk did not check them against the statutes or proceedings they describe; nothing here is computed — no ratio, difference or percentage is derived, and no yen amount appears.