Basiran
In a comprehensive assessment of Taiwan’s evolving technological landscape, the American Chamber of Commerce in Taiwan (AmCham) has issued a series of strategic recommendations aimed at bolstering the island’s digital infrastructure, privacy frameworks, and emerging technology ecosystems. As Taiwan moves into a critical phase of its digital transformation, the AmCham Technology Committee has commended the government’s recent proactive measures, including the 2025 announcement of the “Ten Major AI Infrastructure Projects” and the introduction of the AI Basic Act. However, the Committee emphasizes that for Taiwan to maintain its competitive edge and ensure national security, the government must transition from reactive policy-making to a "resilience-by-design" philosophy rooted in international collaboration and risk-based regulatory frameworks.
The push for these reforms comes at a time when Taiwan’s role in the global technology supply chain is more pivotal than ever. With the world increasingly reliant on Taiwan’s semiconductor prowess, the island’s internal digital stability has become a matter of global economic consequence. The Committee’s report underscores that the resilience of Taiwan’s digital foundations is no longer just a technical requirement but a core national imperative central to security, economic stability, and public trust.
Strengthening National Digital Resilience Through Systematic Design
A primary focus of the Committee’s recommendations is the modernization of Taiwan’s digital infrastructure. While the government has made significant strides in digitalization over the past decade, the Committee argues that the current approach relies too heavily on incremental upgrades and simple data backup. In an era defined by sophisticated cyber threats and geopolitical volatility, "backup" is insufficient to ensure the continuity of essential services.
The Committee advocates for a "resilience-by-design" approach, particularly for critical sectors such as government administration, financial services, and healthcare. This framework requires that continuity, recoverability, and adaptability be embedded into the architecture of IT systems from the very beginning. Digital technologies now underpin almost every facet of public life, from interbank settlements to national security operations. Any significant disruption, whether caused by a cyber incident, a natural disaster, or a geopolitical shock, could lead to cascading failures across the economy.
To achieve this, the Committee recommends a coordinated public-private partnership model. This would involve cross-ministerial collaboration to prevent fragmented security protocols and ensure that resilience planning is synchronized across different authorities. Furthermore, the Committee suggests that the government engage with trusted international technology partners to translate these design principles into operational realities. This includes conducting large-scale stress scenarios, joint drills, and tabletop exercises to identify hidden dependencies and refine decision-making protocols before a crisis occurs.
Modernizing Privacy Frameworks and the Personal Data Protection Act
As data becomes the lifeblood of the modern economy, Taiwan is also moving to update its privacy regulations. The Preparatory Office of the Personal Data Protection Commission (PDPC) has introduced draft amendments for 2026 regarding the Personal Data Protection Act (PDPA). While the Committee welcomes these updates, it warns that rigid mandates and quantitative thresholds could inadvertently stifle innovation and increase compliance burdens without offering meaningful protection.
The Committee’s critique focuses on moving Taiwan toward a more risk-based approach that aligns with international standards like the European Union’s General Data Protection Regulation (GDPR). Key suggestions include:
- Defining Business Contact Information (BCI): The Committee calls for a formal definition of BCI—information used solely for professional contact—to be excluded from the more stringent requirements of personal data protection. This alignment with global trends would facilitate more efficient commercial operations.
- Refining Breach Notifications: Rather than a blanket 72-hour notification window triggered by "initial awareness," the Committee suggests that the clock should start once a breach is reasonably confirmed with enough detail to be actionable. This ensures that notifications are accurate and do not lead to "notification fatigue."
- Risk-Based High-Risk Definitions: Instead of defining "high-risk" entities based on the volume of data they hold (e.g., 10,000 entries), the PDPC should focus on the nature of the data processing, such as large-scale profiling or the use of automated decision-making.
- Technology Neutrality: Regulations should avoid prescribing specific technical solutions, such as mandatory password complexity rules, which can quickly become obsolete. Instead, they should focus on outcomes, allowing companies to adopt modern security measures like multi-factor authentication and encryption.
By adopting these risk-based refinements, Taiwan can create a regulatory environment that protects individual privacy while remaining flexible enough to accommodate rapid technological shifts.
Harmonizing ICT Procurement with Global Cybersecurity Standards
Cybersecurity in public procurement remains a contentious and complex issue. The Committee highlighted concerns regarding the current application of country-of-origin (COO) restrictions in government tenders. While the 2025 amendments to the Cybersecurity Management Act (CSMA) and the Ministry of Digital Affairs (MODA) regulations aim to strengthen security, inconsistencies persist between these laws and the bidding templates used by the Public Construction Commission (PCC).
Currently, many government agencies apply broad exclusions based on where a product is manufactured. The Committee argues that in an era of globally distributed production and software-defined hardware, the location of a factory is an unreliable indicator of risk. A product manufactured in one country may be controlled by code developed in another, and its data flows may be managed by an entity in a third jurisdiction.
The Committee recommends that the PCC harmonize its procurement guidance with MODA’s entity-based framework. This would shift the focus from "Made in China" to "Chinese-branded" or "Chinese-controlled" entities, which more accurately reflects the source of potential cyber risk. Adopting clearer, technical risk profiles rather than broad geographic bans would reduce uncertainty for agencies and ensure that Taiwan’s critical infrastructure is protected by the most secure and advanced technology available, regardless of assembly location.
Preparing for the Quantum Era: Strategy and Security
Quantum computing represents the next frontier of global technological competition. With the launch of Taiwan’s Phase II Five-Year National Quantum Strategy (2027-2031), the government has signaled its commitment to hardware development and national research infrastructure. However, the Committee suggests that hardware alone will not be enough to secure Taiwan’s position in the quantum landscape.
The Committee recommends that international collaboration be a core pillar of the Phase II strategy, with a specific focus on software, algorithms, and application development. As quantum systems approach the point of "quantum advantage"—where they outperform classical computers—the ability to apply these systems to real-world problems in finance, logistics, and medicine will become a key differentiator.
Equally important is the threat quantum computing poses to current encryption standards. The Committee urges the creation of a unified, cross-agency task force to oversee a national "quantum-safe" migration. This would involve a transition to post-quantum cryptography (PQC) to protect sensitive government and financial data from future quantum attacks. The Committee advocates for a "no-regret" phasing model, starting with the discovery of existing cryptographic assets and moving toward controlled pilot programs for critical systems.
Advancing AI Policy Through Public-Private Collaboration
The rapid deployment of Artificial Intelligence (AI) has prompted the Taiwan government to draft the AI Basic Act and establish risk classification frameworks. AmCham has expressed appreciation for the opportunities provided by MODA and the National Development Council (NDC) for industry input. However, the Committee notes that many supporting measures, including sector-specific guidelines and risk assessment tools, are still under deliberation.
Continued collaboration between the public and private sectors is essential to ensure that AI governance remains agile. By sharing industry insights and international best practices, technology providers can help the government develop frameworks that promote responsible AI use without creating barriers to innovation. This collaborative approach is seen as vital for Taiwan to maintain its status as a global AI hub and ensure that its domestic industries can compete on the world stage.
Implications for Taiwan’s Future
The recommendations provided by AmCham reflect a broader shift in how modern states must approach technology policy. In a world where digital infrastructure is as critical as physical infrastructure, the traditional methods of regulation and procurement are often found wanting. By moving toward risk-based, resilient, and internationally aligned policies, Taiwan can safeguard its democracy and its economy against the evolving threats of the 21st century.
The Committee concludes that these ambitions can only be realized through sustained partnership. Whether it is building "resilience-by-design" or preparing for the quantum inflection point, the path forward requires a deep integration of expertise from both the government and the private sector. If Taiwan can successfully implement these structural reforms, it will not only secure its own digital future but also continue to serve as a beacon of technological excellence and a trusted partner in the global digital economy.
Laily UPN
Pevita Pearce
