You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

July 2, 2026

Thailand Releases New Draft Artificial Intelligence Act

Subscribe to Updates

Thailand’s Electronic Transactions Development Agency (ETDA) released a new version of the draft Act on Artificial Intelligence on July 2, 2026, for a public hearing period expected to be approximately 30 days. The draft act adopts a risk-based regulatory approach modeled in part on international frameworks—particularly the EU’s AI Act—while incorporating provisions tailored to Thailand’s regulatory landscape and digital economy objectives. If enacted in its current form, the law would introduce extraterritorial obligations, a tiered risk classification system, strict liability for AI-related damages, and new transparency requirements for AI-generated content.

Scope and Extraterritorial Application

The draft act applies to AI development, deployment, or any other action affecting people in Thailand, even if the action occurs outside the country. Of note:

  • This extraterritorial reach creates compliance obligations for global AI companies whose systems impact Thai residents or consumers, even if the provider has no physical presence in Thailand.
  • Foreign AI providers serving Thai deployers or users must appoint a local coordinator or authorized representative. Depending on the type of AI system, the representative may need full authority to act on behalf of the provider without any limitation of liability.
  • Certain activities are exempt from the draft act’s oversight, including AI used by natural persons solely for personal or household activities, AI for educational research conducted by higher education institutions with ethics committee approval, research and development activities conducted prior to distribution or service provision, and other AI systems prescribed by royal decree.

Risk-Based Classification Framework

The draft act establishes a tiered risk classification system with three main categories:

  • Prohibited AI. The act outright prohibits AI systems employing cognitive-behavioral manipulation using subliminal techniques, AI systems causing unfair broad-scale discrimination from processing irrelevant data, and other categories of serious risk as determined by announcement of a forthcoming committee that will be responsible for national AI planning.
  • High-risk AI. High-risk AI systems are those designated by royal decree as affecting national security, health, environment, energy, telecommunications, transport, or public utilities.
  • Designated AI systems. A subsequent royal decree may additionally require regulator notification, registration, or licensing of certain AI systems before deployment.

Obligations for High-Risk AI System Providers and Deployers

Providers of high-risk AI must develop systems that are efficient and fit for purpose, transparent in operation, subject to meaningful human control, fair and nondiscriminatory, and aligned with foreseeable risks. The regulator may announce risk oversight guidelines covering 13 areas, including risk management, bias prevention, cybersecurity, human oversight, transparency, and complaint handling.

Deployers must implement risk management systems, follow provider instructions, assign capable oversight personnel, mitigate damage from AI-related incidents, retain operational logs for a minimum period (six months under the Thai text), and notify authorities of unforeseen risks.

Transparency Obligations for AI-Generated Content

The draft act introduces transparency requirements for content generation by AI systems:

  • Developers of AI systems capable of generating or modifying images, audio, or video must assess risks, implement mitigation measures, and embed machine-readable marks to identify AI-generated content.
  • Persons who introduce AI-generated content relating to national security, election-related content, investment credibility, food or drug properties, impersonation, or illegal acts into public systems must disclose that it is AI-generated or AI-modified content.
  • Platform providers face specific obligations, including risk assessment, providing reporting channels, verifying AI content, displaying labels, and preparing annual operational summaries.

Data Localization and Contract-Controlled AI Businesses

The draft act grants the forthcoming national AI planning committee authority over data and contracting requirements in sensitive sectors:

  • The committee may designate “contract-controlled AI businesses” applicable to services provided to government or critical infrastructure agencies, and may prescribe mandatory contract terms addressing data processing, risk management, security, modification and termination procedures, and post-termination obligations.
  • The committee may also require data processing within Thailand for AI services of national importance. This introduces uncertainty for cloud-based AI services and may require infrastructure investment in Thailand.

Strict Liability Regime

The draft act imposes joint liability for damages regardless of willful act or negligence—a strict liability standard. Defenses are limited to force majeure, the victim’s own act or omission, or compliance with an official order.

Enforcement and Penalties

The draft act establishes an enforcement framework, with escalating consequences for noncompliance:

  • The regulator may order providers and deployers to rectify insufficient measures.
  • With ministerial approval, the regulator may petition the court to order temporary service suspension, product recall, or deployment suspension.
  • If providers fail to comply, the regulator may petition the court to order ISPs to block AI system dissemination in Thailand.

Administrative fines range from THB 1 million to THB 5 million, depending on the nature of the violation.

AI Product Launches, Regulatory Sandbox, and Self-Regulation

The draft act also establishes a regulatory sandbox framework for testing AI systems in regulated sectors, data-sharing infrastructure through Thailand’s Big Data Institute (a national public organization), and frameworks for self-regulation and best practices. Compliance with self-regulatory best practices may also serve as selection criteria for government investment promotion programs.

Implementation Approach and Next Steps

There will be a phased implementation of the draft act’s measures. Core measures related to the launching of AI products take effect immediately upon publication. Risk control, supervision, and serious incident provisions take effect 180 days after publication, providing a compliance preparation window for affected businesses.

Organizations that develop, deploy, or rely on AI systems affecting persons in Thailand should begin assessing their compliance. They are also encouraged to submit comments on the draft act to the Ministry of Digital Economy and Society during the public hearing period.

Related Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

January 5, 2026
On December 31, 2025, the government of Vietnam promulgated Decree No. 356/2025/ND-CP detailing and guiding the implementation of the new Personal Data Protection Law (PDPL) that was issued in June 2025. The new decree, like the PDPL, entered into force on January 1, 2026, with the previous Decree No. 13/2023/ND-CP on personal data protection ceasing effect on the same day. Some key points of the new decree include the following: Comprehensive lists of basic and sensitive personal data are provided, which will require companies to review again their existing documents and data type classification to ensure compliance. New timelines are established for responding to specific data subject requests. These timelines are more reasonable and longer than the previous 72-hour requirements. Additional consent guidelines are provided, prohibiting default consent or ambiguous instructions that confuse data subjects about giving or withholding consent. Mandatory content for data transfer agreements/clauses in particular cases is provided. This covers, among other things, (i) the legal basis for the transfer of personal data; (ii) responsibilities for personal data protection during the transfer and processing of personal data; (iii) responsibilities for ensuring the exercise of the rights of personal data subjects; and (iv) responsibilities for coordination and compliance of the parties in cases where violations of personal data protection regulations are detected. The qualifications and responsibilities of data protection officers (DPOs) and data protection departments include, among others, having been trained and fostered in legal knowledge and professional skills regarding personal data protection. There are no specific provisions governing the qualifications or requirements for organizations that provide data protection training or education. New mandatory templates and requirements are provided in relation to data processing impact assessment and data transfer impact assessment, and for cases in which companies need to re-submit assessments to the regulator. Stricter requirements are
Read More
December 30, 2025
On December 17, 2025, Laos’ Ministry of Industry and Commerce (MOIC) issued a notice introducing a new digital system that allows e-commerce businesses to obtain required certificates and licenses through an online, application-based platform. Notice No. 3988, which will take effect on February 1, 2026, introduces the E-Trust platform, a downloadable application that allows e-commerce businesses to remotely obtain acknowledgement certificates and business operating licenses. New Digital Registration Options Under the previous framework established by the Decree on E-commerce (2021), businesses were required to complete registration exclusively through paper-based submissions. The new system now offers businesses two registration options: Traditional paper-based process at the Division of E-commerce Management within the MOIC; or Electronic registration and renewal through the E-Trust platform. This change is expected to streamline procedures, reduce administrative burdens, and enhance accessibility for businesses operating outside Vientiane. The E-Trust platform facilitates compliance for both individuals and legal entities required to submit applications and renewals for required certificates and licenses. The development is particularly beneficial for businesses located in remote provinces, as it eliminates the need for physical travel and significantly accelerates processing times. Compliance Requirements and Penalties Businesses must obtain or renew the required certificates and licenses to avoid sanctions under the Decision on Fines and Other Measures for Violation of the Decree and Regulations on E-commerce (No. 2828/MOIC, dated November 11, 2025). Penalties for noncompliance may include monetary fines and other enforcement measures.
Read More
December 26, 2025
Thailand has granted ride-sharing platforms additional time to comply with new regulatory requirements, extending the compliance deadline to March 31, 2026 (replacing the previous deadline of October 2, 2025). The postponement was made official on December 18, 2025, when Thailand’s Electronic Transactions Development Agency (ETDA) published the second Notification Regarding Supervision of Ride-Hailing Platforms Classified as High-Impact Digital Platform Services under the Royal Decree on Digital Platform Service Businesses. The notification provides additional time for ride-sharing platforms and drivers to transition to full regulatory compliance. The extension replaces the effective date provision of the earlier notification and applies specifically to ride-hailing activities. Background The postponement responds to feedback from operators and driver groups regarding challenges converting private vehicles into legally registered public vehicles, including complex registration procedures, high compliance costs, and operational delays. The Department of Land Transport (DLT) is concurrently reforming its vehicle registration and driver verification processes to streamline operations. Given these issues, the Electronic Transactions Committee has deferred enforcement to provide an adjustment period for operators and drivers to meet compliance requirements. Ongoing Obligations While the effective date has been deferred, the substantive obligations imposed on ride-sharing platforms remain fully intact. Operators must continue preparing to comply with the additional duties applicable to high-impact digital platform services, beyond the general requirements under the digital platform services framework. Operators are expected to use the extended transition period to finalize operational and compliance readiness ahead of enforcement on March 31, 2026. Key focus areas include: Integration with DLT vehicle-registration systems Deployment of robust driver and passenger identity verification mechanisms Updates to platform terms of service, driver-onboarding standards, and internal operational policies Preparation for ETDA reporting obligations and future audit and review processes Next Steps While the postponement replaces the previous effective date with the new March 31, 2026,
Read More
December 26, 2025
The Bank of Thailand (BOT) has released the Guidelines for Digital Fraud Management, which took effect on December 17, 2025, incorporating certain amendments to the draft guidelines issued in March 2025. These official guidelines aim for end-to-end digital fraud prevention, with a particular focus on mule accounts, to enhance trust and security in Thailand’s financial system. The guidelines apply to “financial service providers,” including: Financial institutions and special financial institutions under the Financial Institution Business Act; and Operators of Inter-institutional Fund Transfer System e-money services and e-fund transfer services under the Payment Systems Act. Besides commercial banks and e-money operators that offer fund-transfer services, other providers may adopt requirements based on risk proportionality and baseline standards set out in the guidelines (for instance, an e-money operator that does not offer e-fund transfer services could consider implementing a fraud monitoring and detection system according to the risk level of its service). The guidelines establish the following key requirements: Policy and oversight. Directors and senior executives of financial service providers must adopt appropriate “end-to-end” fraud management policies and KPIs to manage digital fraud, covering prevention, monitoring, detection, management, resolution, and support for affected customers. The fraud management policy must be regularly reviewed, and whenever there is a situation or change that significantly affects the efficiency of the fraud management. Any significant update to the policy must first be approved by the board of the financial service provider. The BOT also encourages providers to collaborate in establishing industry standards aligned with applicable laws and regulations to ensure consistency and best practices across the sector. Fraud management processes. Financial service providers must establish a clear framework for managing digital fraud throughout the customer lifecycle—from customer onboarding to service termination—covering at least the following processes: Know your customer (KYC) and customer due diligence (CDD):
Read More