Japanese companies in Thailand must follow Thai law first, such as the Personal Data Protection Act (PDPA) and the Cybersecurity Act. Japan's rules arrive as head-office policy. The key document is the AI Guidelines for Business from the Ministry of Internal Affairs and Communications (MIC) and the Ministry of Economy, Trade and Industry (METI), Version 1.2 (31 Mar 2026). The document itself says it is soft law with no legal force. It does not address overseas subsidiaries directly, but it says businesses that operate across borders should comply with local law. Japan's AI law (Act No. 53 of 2025), in full effect since 1 Sep 2025, is a promotion law with no penalties. In practice, a Thai subsidiary works on two layers. It takes the group's AI policy from Japan, then adds the Thai legal duties that head office did not write. Data from the Japan External Trade Organization (JETRO) shows this affects many companies. 6,083 Japanese companies are still operating in Thailand (2024 survey). In the 2025 survey, 46.1% of Japanese companies in Thailand used or invested in digital technology, below the ASEAN average. This article has a table comparing Japan's rules with Thailand's, what the Japanese guidelines expect from AI users with the Thai duties to pair with them, and a template of what a subsidiary must add itself.
Checked against official documents from the Government of Japan, JETRO and Thai law on 24 Oct 2026. This article is not legal advice.
Japan's rules and Thailand's rules
| Japan | Thailand | |
|---|---|---|
| AI-specific law | Act No. 53 of 2025, a promotion law with no penalties, in full effect from 1 Sep 2025 | No AI law in force yet |
| Guidelines for business | AI Guidelines for Business Version 1.2 (31 Mar 2026), voluntary | AI guidance from the Office of the Personal Data Protection Committee (PDPC, สคส.), 7 Oct 2026, and the Generative AI guidance of the Electronic Transactions Development Agency (ETDA). Neither is binding |
| Personal data | Japan's own law | The PDPA is in force and applies to employee and customer data in Thailand |
| National plan | The second AI Basic Plan, approved by the Cabinet on 14 Jul 2026, names cooperation with ASEAN | ETDA's draft Artificial Intelligence Act is still a draft |
The Japanese guidelines split the parties into three roles: AI developers, AI providers and AI business users. One company can hold several roles. A Thai subsidiary that uses Claude, Microsoft Copilot, ChatGPT or Gemini in daily work is mainly an AI business user.
What the Japanese guidelines expect, and the Thai duties to pair with them
| What the AI Guidelines for Business expect from AI users | What a Thai subsidiary must add |
|---|---|
| Use AI within the scope the provider sets, and understand the accuracy and risks of the output before using it | Choose enterprise tools whose contract bars using your data to train models, and run a DPIA for work that uses personal data |
| Do not enter personal or confidential data inappropriately | Check the legal basis for processing under the PDPA and cross-border transfers under sections 28–29, including transfers back to head office |
| When AI is used to assess people, tell the people being assessed, keep a human making the decision with care for automation bias, and be able to explain when asked | HR work in Thailand that uses AI to screen or assess staff must meet both the PDPA and the PDPC guidance |
| Make sure people who work with AI have AI literacy that fits their work | Run training in the language Thai staff actually use, and claim the training-cost deduction under the conditions of the Department of Skill Development (กรมพัฒนาฝีมือแรงงาน) |
For how to run a DPIA, see the DPIA template for AI projects (in Thai). For the conditions of the training-cost deduction, see the guide to the 200% tax deduction. For the full status of Thai law, see Thailand's AI laws and guidelines (in Thai).
An example the guidelines give in an appendix is SoftBank, which applied its AI ethics policy to 89 group companies as of Dec 2025. The example is not a requirement. But it reflects that many Japanese head offices send policy down to the whole group.
Where Japanese companies in Thailand stand
- Number. JETRO Bangkok confirms 6,083 companies that have at least 10% Japanese shareholding and are still operating. About 40% (39.6%) are in manufacturing, and 51.7% have their main office in Bangkok.
- Digital use. JETRO's 2025 survey of Japanese companies overseas found that 46.1% of companies in Thailand used or invested in digital technology, compared with 52.1% across ASEAN.
- Plans and barriers. Across all countries, AI ranks second among the technologies companies plan to expand (49.6%), after cloud. The top barrier is a shortage of digital talent (60.7%).
We have not found an official figure for the share of Japanese companies in Thailand that use generative AI.
Template: what a subsidiary must add itself
- Ask head office for the group AI policy and the list of tools the group has approved, such as Microsoft 365 Copilot if the company uses the same tenant as the group.
- Compare it with Thai law. Add the PDPA, cross-border data transfers and breach notification within 72 hours (PDPA and AI use (in Thai)).
- Write a Thai-language policy that Thai staff can read and understand, not just a translation from Japanese or English (AI policy for Thai organisations (in Thai)).
- Train by role. Japanese executives, Thai managers and frontline staff use AI differently, so the teaching language may need to differ too.
- Report back to head office with the same measures the group uses (measuring the results of AI use (in Thai)).
Training we have delivered at Japanese group companies
| Date | Organisation | Course | Notes from our work log |
|---|---|---|---|
| 19 Oct 2026 | Mitsui & Co. | Microsoft Copilot Premium | Cohort 2 of 4 · learner evaluation 4.94/5.00 |
| 8 Oct 2026 | Mitsui & Co. | Microsoft Copilot Premium | Cohort 1 of 4 |
| 1 Sep 2026 | Siam Kubota Leasing | Consulting on an internal AI project | 3rd engagement · supporting the team that builds internal AI tools |
| 18 Dec 2025 | Thai Toshiba Lighting | Generative AI for Workforce | Cohort 1 |
| 16 Jun 2025 | Daikin | Microsoft Copilot for Workforce | Factory staff |
Every engagement in the table comes from our dated training work log.
Sources
- AI Guidelines for Business and the English translation, Ver1.2, MIC and METI
- AI Act (AI法), English overview and AI Basic Plan, Cabinet Office of Japan
- Survey of Japanese-affiliated companies in Thailand, FY2024 (タイ日系企業進出動向調査 2024年度), JETRO Bangkok
- FY2025 Survey on Business Conditions of Japanese Companies Overseas, Asia and Oceania (2025年度 海外進出日系企業実態調査 アジア・オセアニア編), JETRO (26 Nov 2025)
Read next
If your company uses Microsoft 365 across the group, see planning a Copilot rollout in the organisation (in Thai) and Microsoft Copilot pricing (in Thai), or see our corporate AI training in detail.