Lina Irawan
The American Chamber of Commerce in Taiwan (AmCham Taiwan) has issued a comprehensive set of recommendations aimed at fortifying the island’s technological landscape, urging the government to transition toward a "resilience-by-design" digital architecture and a risk-based regulatory environment. In a detailed policy assessment, the AmCham Technology Committee commended the recent announcement of the 2025 “Ten Major AI Infrastructure Projects” and the introduction of the AI Basic Act. However, the Committee emphasized that as Taiwan navigates an increasingly complex geopolitical and technological era, its long-term competitiveness will depend on deep international collaboration and the modernization of its digital foundations.
According to the Committee, Taiwan’s digital resilience is no longer merely a technical requirement but a core national imperative central to security, economic stability, and public trust. As the global semiconductor hub and a critical node in the world’s technology supply chain, Taiwan faces unique pressures to ensure its systems are not only robust but capable of rapid recovery in the face of cyber incidents or infrastructure failures.
A New Era of Digital Resilience: Beyond Data Backups
The primary thrust of the Committee’s recommendations focuses on the modernization of national digital infrastructure. While the Taiwan government has made significant strides in establishing data backup mechanisms for essential public services, the Committee argues that backup alone is insufficient for true resilience.
In a "resilience-by-design" framework, continuity, recoverability, and adaptability are embedded as core design principles from the outset. This approach is particularly critical for systems supporting government administration, financial services, and healthcare delivery. As digital technologies now underpin nearly all essential services—from interbank settlements to national security operations—any disruption could result in far-reaching economic and social consequences.
To achieve this, the Committee suggests a coordinated public-private partnership model supported by cross-ministerial collaboration. The objective is to move beyond incremental upgrades toward a systematic national resilience architecture. This would involve translating resilience objectives into deployable architectures and operational models through structured dialogue with trusted international technology partners. Furthermore, the Committee recommends the implementation of joint drills, tabletop exercises, and cross-sector simulations to identify hidden dependencies and clarify decision-making authorities before a crisis occurs.
Modernizing Privacy and Data Protection
As the Preparatory Office of the Personal Data Protection Commission (PDPC) prepares for the 2026 draft amendments to the Personal Data Protection Act (PDPA), AmCham Taiwan has voiced concerns regarding potential "rigid mandates" that could hinder innovation. The Committee is advocating for a framework that aligns more closely with international standards, such as the European Union’s General Data Protection Regulation (GDPR).
Key suggestions for the PDPA update include:
- Defining Business Contact Information (BCI): Establishing a formal definition for BCI (names, titles, business addresses) and excluding it from the stricter tiers of personal data protection to facilitate efficient commercial operations.
- Risk-Based Breach Notifications: Implementing a "harm threshold" where notification obligations are triggered only when an incident poses a real risk to individuals’ rights. The Committee also suggests that the 72-hour reporting window should begin only after a breach is reasonably confirmed with sufficient detail.
- Qualitative High-Risk Definitions: Shifting away from simple quantitative metrics, such as the number of data entries (e.g., 10,000), and instead defining "high-risk" based on the nature of the processing, such as large-scale profiling or automated decision-making.
- Technology Neutrality: Avoiding prescriptive rules like specific password complexity or retention periods, which can quickly become obsolete. Instead, regulations should focus on outcomes, allowing for modern controls like multi-factor authentication and encryption.
The Committee emphasized that a minimum 12-month transition period following the promulgation of new regulations is essential for organizations to adjust internal policies and update technical systems.
Reforming ICT Procurement and Cybersecurity
A significant point of friction identified by the Committee involves the current state of Information and Communications Technology (ICT) procurement. While the 2025 amendment to the Cybersecurity Management Act (CSMA) was welcomed, inconsistencies remain between the legal framework and the actual tendering processes managed by the Public Construction Commission (PCC).
Currently, many government agencies apply broad country-of-origin (COO) restrictions in public procurements. The Committee argues that in an era of software-defined hardware and globally distributed production, manufacturing location alone is an unreliable indicator of cybersecurity risk. A product’s security is more accurately determined by who controls its code, updates, and data flows.
The Committee encourages the Ministry of Digital Affairs (MODA) and the PCC to harmonize their approaches. Specifically, they recommend moving toward an entity-based framework—which might ban specific high-risk brands—rather than blanket exclusions based on the country of manufacture. This shift would reduce uncertainty for procuring agencies and better reflect the intent of modern cybersecurity laws.
The Quantum Leap: Strategy for 2027–2031
Looking toward the future, the Committee highlighted the critical nature of quantum computing. With "quantum advantage"—the point where quantum systems outperform classical computers—potentially emerging as early as this year, Taiwan’s Phase II Five-Year National Quantum Strategy (2027-2031) is viewed as a vital foundation.
However, the Committee notes that hardware investment alone is not enough. To build a robust quantum ecosystem, Taiwan must:
- Accelerate Software and Algorithm Research: Focus on practical, real-world applications across priority domains.
- Incentivize International Partnerships: Deepen engagement with global partners to foster talent development and skill transfer.
- Prepare for Quantum-Safe Cryptography: Establish a unified, cross-agency task force to oversee the migration to "quantum-safe" standards. This is a strategic transformation to protect Taiwan’s digital ecosystem against the systemic risk of quantum computers eventually breaking current encryption standards.
The migration to quantum-safe systems should follow a "no-regret" model, starting with cryptographic asset discovery and moving to controlled pilot programs for the most critical information assets.
Timeline of Key Policy Milestones
The current technological roadmap for Taiwan is marked by several significant regulatory and strategic dates:
- 2024: Initiation of industry consultations for the AI Basic Act and risk classification frameworks.
- 2025: Implementation of the "Ten Major AI Infrastructure Projects" and the coming into force of the amended Cybersecurity Management Act.
- 2026: Expected implementation of the updated "Regulations Regarding the Security Maintenance and Administration of Personal Information Files" under the PDPA.
- 2027: Launch of the Phase II Five-Year National Quantum Strategy, running through 2031.
Broader Implications and Economic Impact
The recommendations from AmCham Taiwan come at a time when the global "Silicon Shield"—the idea that Taiwan’s dominance in semiconductors protects it from conflict—is being augmented by a "Digital Shield." By adopting these recommendations, Taiwan stands to strengthen its position as a trusted digital partner for Western economies.
Industry analysts suggest that a shift toward risk-based regulation could significantly lower compliance costs for multinational corporations operating in Taiwan, thereby attracting more foreign direct investment (FDI) in the tech sector. Conversely, maintaining rigid, localized mandates could isolate Taiwan’s digital economy from global trends, potentially leading to a "technology island" effect where local systems are incompatible with international standards.
The Committee’s call for public-private collaboration is particularly relevant for AI governance. As MODA and the National Development Council continue to refine the AI Basic Act, the input of technology providers is seen as essential to ensure that the risk framework does not stifle the very innovation it seeks to manage.
Official Responses and Industry Outlook
While government officials from the Ministry of Digital Affairs have expressed a commitment to "sustained, structured dialogue" with industry associations, the implementation of a 60-day public consultation period for all major law amendments remains a key demand from the business community. This period is viewed as vital for ensuring that regulatory revisions are practical and do not result in unintended negative consequences for the tech ecosystem.
In conclusion, AmCham Taiwan’s Technology Committee underscores that Taiwan’s path to maintaining technological leadership requires a pivot from defensive, reactive policies to a proactive, resilience-oriented strategy. By aligning with global standards in privacy, procurement, and quantum readiness, Taiwan can ensure that its digital infrastructure is as robust and world-leading as its semiconductor manufacturing capabilities. The coming five years will be a decisive period in determining whether Taiwan can successfully translate its current hardware dominance into a sustainable, secure, and innovative digital future.
Azzam Bilal Chamdy
Muslim
