International Comparison of Foster Care Systems from the Perspective of Children's Rights: Focusing on South Korea, the United Kingdom, and Sweden

Background/Purpose

South Korea's child protection policy has historically been facility-centered, rooted in concepts of blood-based family. Although recent policy directions have shifted toward family-based care under the "family care first" principle, institutionalized children still account for 63.5% of all children in protective care as of 2021, while foster care covers only 36.5%. Current foster care policy faces critical challenges: an insufficient number of foster families, inadequate economic and psychological support, and a lack of specialized foster placements. Drawing on UNCRC, this study compares the foster care policies of South Korea, the United Kingdom, and Sweden through the lens of children's rights, in order to derive directions for policy improvement.

Research Questions

1) How are foster care policies operated in South Korea, the United Kingdom, and Sweden? 2) How do the policies of each country reflect the criteria for determining the "best interests of the child"? 3) From the perspective of children's rights, in what direction should South Korea's foster care policies be improved?

Methods

This study employs a descriptive comparative research design, conducting literature and institutional analysis based on official government reports, relevant legislation, UN international documents, and academic papers. The analytical framework applied is the seven-element criteria for determining "the best interests of the child" as presented in UNCRC General Comment No. 14: (1) the child's views, (2) the child's identity, (3) preservation of family environment and relations, (4) care, protection, and safety, (5) situations of vulnerability, (6) the child's right to health, and (7) the child's right to education.

Results

Comparative analysis revealed systematic differences across all seven criteria. The UK and Sweden operate active mechanisms for gathering and incorporating children's views, while South Korea lacks concrete procedural guidelines despite legal provisions. Both the UK and Sweden prioritize cultural, linguistic, and religious matching in foster placements, whereas South Korea has no practical identity-based matching criteria. On family reunification, the UK and Sweden institutionalize regular parental counseling and reintegration programs, while South Korea tends toward long-term placement without systematic support. In terms of post-placement monitoring, both the UK and Sweden maintain robust oversight, whereas South Korea's management remains relatively passive. For vulnerable children, the UK and Sweden offer specialized placements with trauma-informed services, while South Korea lacks the necessary infrastructure. Lastly, South Korea exhibits significant regional disparities in health and education services, whereas the UK and Sweden provide integrated, locally-delivered child welfare services with nationwide reach.

Conclusions and Implications

South Korea's foster care policy remains in a developmental stage, with significant gaps in public case management, institutional support for foster families, and the realization of children's rights. Based on the comparative findings, six policy directions are proposed: (1) establishing procedures to actively reflect children's opinions in placement decisions; (2) developing placement criteria that consider children's cultural and linguistic identities; (3) strengthening biological family reunification support; (4) institutionalizing post-care independence support and expanding case management capacity; (5) expanding specialized foster families for children with disabilities or histories of abuse; and (6) eliminating regional disparities through a nationwide standardized welfare system.