AI Governance & EU AI Act Compliance — Risk-Based Classification
AI Governance & EU AI Act Compliance — Risk-Based Classification · § Advisory
What to know before you act
Thai businesses offering AI-enabled products to EU customers may fall under the EU AI Act even without an EU office. The Act tiers systems by risk: some uses are prohibited, high-risk systems need technical documentation, human oversight and logging. In Thailand, the PDPA still applies when personal data trains models. We inventory your AI systems, give an initial risk classification, draft an internal AI-use policy and review model-provider contracts.
Timing and external dependencies: An inventory and initial policy usually take several weeks depending on system count; EU obligations phase in — check current dates.
Official fee: No direct Thai government fee; EU conformity assessment bodies charge separately where required.
Timing is not a promise of an outcome or hearing date. Check the notice, limitation period and current authority rules for your matter.
What to send for the first review
Send every relevant page, a dated sequence of events, any hearing or filing deadline, and the outcome you need. This lets counsel identify urgent steps, missing evidence and a precise scope of work.
- AI system inventory + purpose statement
- Risk classification memo (Annex III mapping)
- Technical documentation (Annex IV)
Legal Basis
EU AI Act (Reg 2024/1689) in force 2 Aug 2026 · Thai AI Ethics Guidelines (ETDA + NXPO 2022) · Thai AI Business Act draft (2026) · PDPA §32 · CoE AI Framework Convention 2024 · OECD AI Principles · NIST AI RMF 1.0 · ISO/IEC 42001:2023 (AIMS).
📚 Official sources — check the current law and procedure before acting
- สำนักงานคณะกรรมการคุ้มครองข้อมูลส่วนบุคคล (สคส.)— PDPC Thailand
- กรมพัฒนาธุรกิจการค้า — จดทะเบียนนิติบุคคล / ธุรกิจคนต่างด้าว— Department of Business Development
- สำนักงานคณะกรรมการกฤษฎีกา — ตัวบทกฎหมายฉบับทางการ— Office of the Council of State
Who Needs This
Companies deploying AI in HR, credit scoring, insurance, medical diagnosis · SaaS with AI features sold to EU · GenAI/foundation model providers · e-commerce with AI recommendations.
Required Documents
- AI system inventory + purpose statement
- Risk classification memo (Annex III mapping)
- Technical documentation (Annex IV)
- Risk management system (Art. 9)
- Data governance (Art. 10) + bias testing report
- Human oversight design (Art. 14) + transparency notice (Art. 13).
Common Pitfalls
- Assuming using another company's model removes all responsibility
- Staff pasting customer data into public AI tools without a policy
- No records of how the system decides and who reviews it
Typical Use-cases
- HR-tech · resume screening AI · high-risk Annex III(4) · FRIA + bias audit + human review
- Healthtech · AI radiology · high-risk + MDR dual compliance
- Fintech · credit scoring · high-risk Annex III(5) · explainability + adverse action notice
- Thai GenAI startup · LLM 7B · GPAI transparency + copyright dataset log.
FAQ
- Does Thailand have a specific AI law yet?
- Guidelines and drafts are being developed — follow the latest government announcements.
- Is a customer-service chatbot high-risk?
- Usually not, but users often must be told they are talking to AI.
- Can we screen job applicants with AI?
- Yes, but the EU treats it as high-risk and discrimination risks apply.
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The information on this page follows the official sources below. Always check the latest version before you file.
- Office of the Judiciary— Office of the Judiciary
- Ministry of Justice— Ministry of Justice
- Lawyers Council of Thailand — Notarial Services Attorneys— Lawyers Council of Thailand
- Office of the Council of State — Thai law database— Office of the Council of State
- Royal Thai Government Gazette— Royal Thai Government Gazette
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Frequently asked questions
- Can a foreigner own 100% of a Thai company?
- Generally no for activities listed in the Foreign Business Act, where majority foreign ownership requires a Foreign Business Licence, a BOI promotion, or treaty rights such as the US–Thailand Treaty of Amity. Manufacturing and certain export activities are largely open, and BOI-promoted activities can permit full foreign ownership together with land-holding and visa privileges, so the right structure depends on the specific activity.
- What is the minimum registered capital for a Thai company?
- There is no general statutory minimum for a Thai-majority company, but practical thresholds apply: a fee quoted after review million of paid-up registered capital per foreign work permit, or a fee quoted after review million if the foreigner is married to a Thai national, and a fee quoted after review million per foreign shareholder for a Foreign Business Licence. Capital should therefore be planned around the visa and work-permit outcome you need, not the incorporation minimum.
- How long does company registration take?
- Registration at the Department of Business Development can be completed within one to three working days once the name reservation, shareholder documents and company objectives are ready, and the VAT registration and social security registration follow afterwards. The realistic end-to-end timeline including bank account opening is two to six weeks, with the bank account usually being the slowest step for foreign directors.
- What ongoing accounting obligations does a Thai company have?
- Every Thai company must keep statutory accounts, file monthly withholding tax (PND 1, 3, 53) and VAT (PP 30) returns by the middle of the following month, file the half-year corporate income tax return (PND 51) and the annual return (PND 50), and have its financial statements audited by a Thai CPA and filed with the DBD each year. Dormant companies are not exempt — nil returns and an audited statement are still required.