A growing number of South Korean clinics are operating without filing any national health insurance benefit claims, potentially making it harder for brokers and underwriters to use claims-based treatment data when assessing professional liability exposure in a rapidly expanding segment of the healthcare market.
The number of medical institutions that filed no health insurance benefit claims rose 25.5% from 1,810 in 2021 to 2,272 in 2025, according to Health Insurance Review and Assessment Service data submitted to Democratic Party Representative Seo Young-seok, a member of the National Assembly's Health and Welfare Committee.
Clinics opened by general practitioners without specialist certification accounted for most of the increase. Their number rose 43% from 1,004 in 2021 to 1,436 in 2025, lifting their share of all non-claiming medical institutions from 55.5% to 63.2%.
The trend is concentrated in areas associated with cosmetic and beauty-related medicine. Of the 1,436 non-claiming general-practitioner clinics in 2025, 951, or 66.2%, were located in Seoul and Gyeonggi Province.
Seoul's Gangnam district accounted for 339 clinics, followed by Seocho with 119. Seoul's Jung district, which includes the tourist-heavy Myeongdong area, had 48, while Busanjin district in Busan had 40.
The concentration comes as South Korea's foreign-patient market expands rapidly, particularly for aesthetic treatment. The Ministry of Health and Welfare said 2.01 million foreign patients received treatment in South Korea in 2025, up from 1.17 million in 2024. The ministry said growth from markets including China and Taiwan reflected, among other factors, increased demand for aesthetic and nonsurgical services, particularly dermatology.
That growth has a direct insurance component. Under South Korean law, medical institutions seeking registration to attract foreign patients must carry medical malpractice liability insurance or participate in an approved medical liability mutual-aid arrangement. Current rules require coverage for medical-accident liability and prescribe minimum annual limits.
As of March 2025, 3,114 medical institutions were registered to attract foreign patients, with Medical Korea reporting malpractice coverage across all registered institutions. The requirement does not apply merely because a clinic provides non-covered services, however, and the data on clinics filing no national health insurance claims does not establish how many are registered to attract foreign patients.
For brokers and underwriters, the key issue is therefore not simply the number of clinics operating outside the national health insurance claims system, but how their exposures can be assessed when a conventional claims-based picture of treatment activity is unavailable. Procedure volumes, treatment mix, patient demographics, practitioner qualifications, foreign-patient exposure and prior incidents may become more important when evaluating professional liability risk in this part of the market. In practice, that means brokers should be requesting procedure volumes, treatment mix and practitioner qualifications directly from clinic clients at submission stage, rather than relying on the claims history underwriters would normally draw on for a conventional medical practice.
The absence of health insurance claims does not mean the clinics operate outside regulatory reporting altogether. HIRA separately publishes price information on non-covered medical services, covering 693 items in its 2025 disclosure program. But those disclosures provide a different type of information from the treatment and utilization data generated through national health insurance claims.
The development also comes amid an increase in medical disputes more broadly. South Korea's Medical Dispute Mediation and Arbitration Agency received 2,605 medical dispute cases in 2025, up 24.7% from the previous year and the highest total in five years. The agency did not attribute that increase specifically to cosmetic clinics or non-covered treatments.
Seo said the rise warrants closer examination of medical institutions focused on non-covered services.
"There are certain limits to grasping the treatment situation at medical institutions that do not file health insurance claims," Seo said, adding, "Given the concerns that beauty medical institutions run by general practitioners, centered on non-covered services, are increasing, there is a need to review accurate assessment and management measures for this field."
