Global Expansion Global

US and Southeast Asia AI Regulation

There is no single US AI statute and no single ASEAN one. Obligations arrive state by state and country by country, so the work is sequencing — what actually binds you now, and what to build ahead of.

No federal statute, no ASEAN harmonisation — so compliance is a sequencing problem

An AI company entering the US meets a patchwork: state AI statutes, employment-discrimination rules applied to automated decision tools, and sector regulators each asserting jurisdiction over the same product. Entering Southeast Asia meets a different patchwork: six data protection regimes at different maturity levels, with AI-specific guidance layered on top in some markets and absent in others.

The practical error is treating this as a coverage problem — five markets, five compliance projects. It is a sequencing problem: a common baseline covers most of what every regime requires, and a thin local layer covers the rest. Companies that build five separate programmes pay five times and still miss obligations; companies that build one baseline and four adaptations move faster.

What we do


The landscape, by shape rather than headline

United States. No comprehensive federal AI statute. Obligations come from three directions: state AI statutes (Colorado’s AI Act on high-risk systems and consumer protection; Texas’s TRAIGA; California’s frontier-model transparency and training-data disclosure requirements), employment law applied to automated decision tools (New York City’s Local Law 144 requiring bias audits of automated employment decision tools; Illinois rules on AI in hiring), and sector regulators applying existing consumer-protection and anti-discrimination authority. Status changes every legislative session, so any list is a snapshot, and the audit has to be run against the current text.

Southeast Asia. Data protection is the mature layer: Singapore’s PDPA, Thailand’s PDPA, Indonesia’s Law 27/2022, Vietnam’s Decree 13/2023, Malaysia’s amended PDPA and the Philippines’ Data Privacy Act. Most are GDPR-shaped but differ on registration, breach notification timing, cross-border transfer conditions and local representative requirements. AI-specific rules are thinner and mostly soft law — Singapore’s Model AI Governance Framework and its guidance on generative AI are the most developed, and while they are not statutes, they inform supervisory expectations and procurement.


What is different for an AI company

Typical situations

Situation 1: Extraterritorial effect overlooked at state level

The company has no US entity and no US office. Its product is used by residents of states whose AI statutes attach on the basis of serving those residents. Jurisdiction follows use, not incorporation, and the assumption that “we are not in the US” fails the same way it fails under the AI Act.

Our approach: measure where users actually are, then map that distribution against enacted statutes rather than against the states the company thinks it operates in.

Situation 2: An automated hiring tool treated as an ordinary product feature

A screening feature ranks candidates. In several US jurisdictions that is an automated employment decision tool, subject to independent bias audit, published results and candidate notice. The feature ships as a product update, and the audit obligation is never identified.

Our approach: review every feature that makes or informs a decision about a person — hiring, evaluation, credit, pricing — against the jurisdiction-specific tool rules, and schedule the audits as recurring obligations rather than launch tasks.

Situation 3: Southeast Asia deprioritised as “lower risk”

A market entry is deferred on the assumption that enforcement is light. In practice, breach notification deadlines are strict, transfer conditions are formal, and a regulator’s inquiry arrives with a short response window. The cost of the assumption is highest in the market where nothing was prepared.

Our approach: build the baseline before entry, localise at entry, and where local counsel is required, engage before the first incident rather than after it.


Process and deliverables

StageWorkDeliverables
1Jurisdictional mapping against actual user distributionMarket obligation matrix
2Gap analysis against enacted requirementsPriority register + remediation sequence
3Baseline build (data protection and AI governance)Policy set + records + assessment templates
4Local adaptation and local counsel coordinationMarket-specific addenda + local opinions
OngoingLegislative tracking and refreshQuarterly update note + revised baseline

AI-specific deliverables

Frequently asked

Do we need a US entity to be caught by state AI laws? No. Several state statutes attach on the basis of conducting business in the state or serving its residents, which is a factual test rather than a corporate one. The analysis starts with the user distribution, not the org chart.

Are Singapore’s AI governance frameworks legally binding? Not as such — they are frameworks rather than statutes. They nonetheless shape supervisory expectations, and they are frequently written into procurement and investor diligence requirements, which makes them commercially binding even where they are not legally binding.

Can one privacy policy cover all these markets? A single policy can cover the common core, but several jurisdictions require specific disclosures, named representatives, or language that a global policy will not contain. The workable structure is one baseline with a jurisdiction-specific annex, not one document stretched to fit.

How often does this need to be revisited? At least annually, and on any market entry. US state legislation moves every session and several of the enacted statutes have been amended before their effective dates, so a position paper older than a year should be treated as a draft.


Related Case Studies

All cases →

Each case states the obligation triggered, the judgment we made, and what was delivered.

Further Reading

Rule changes, enforcement cases and practical judgments around this service, listed in publication order.

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