Asro
The American Chamber of Commerce in Taiwan (AmCham) Technology Committee has issued a comprehensive set of recommendations aimed at fortifying Taiwan’s digital landscape, praising the government’s proactive stance while calling for more nuanced, risk-based regulatory frameworks. As Taiwan navigates a pivotal era defined by artificial intelligence (AI), quantum computing, and escalating cybersecurity threats, the Committee’s latest position paper underscores that the island’s long-term economic stability and national security are inextricably linked to the resilience of its digital foundations.
The Committee’s assessment comes at a time when Taiwan is aggressively positioning itself as a global "AI Island." In 2025, the government launched the "Ten Major AI Infrastructure Projects," an ambitious initiative designed to enhance domestic computational power and foster a robust local AI ecosystem. This was followed by the introduction of the AI Basic Act, which serves as a legal cornerstone for responsible development. While these steps are seen as significant milestones, industry experts and international partners emphasize that the transition from policy ambition to durable outcomes will require deeper international collaboration and a fundamental shift in how digital risks are managed.
A Chronology of Taiwan’s Recent Technology Policy Evolution
To understand the current recommendations, it is essential to trace the trajectory of Taiwan’s digital policy over the last three years. In 2023 and 2024, the Ministry of Digital Affairs (MODA) and the National Development Council (NDC) focused heavily on digitalization and the establishment of basic data backup protocols for government agencies. This period saw a surge in IT modernization across the public sector, driven by the realization that physical infrastructure and digital assets were increasingly vulnerable to both natural disasters and geopolitical tensions.
By early 2025, the focus shifted toward high-performance computing and AI integration. The "Ten Major AI Infrastructure Projects" marked a transition toward national-level investment in emerging technologies. Simultaneously, the Preparatory Office of the Personal Data Protection Commission (PDPC) began drafting amendments to the Personal Data Protection Act (PDPA), aiming to modernize Taiwan’s privacy regime for the digital economy era.
Looking forward, the government has already laid the groundwork for the next decade. The Phase II Five-Year National Quantum Strategy (2027–2031) has been unveiled, reflecting a strategic pivot toward quantum-safe cryptography and the development of a domestic quantum ecosystem. The Committee’s suggestions are intended to refine these ongoing efforts, ensuring that Taiwan’s regulatory environment remains conducive to innovation while maintaining world-class security standards.
Moving Toward Resilience-by-Design in Critical Infrastructure
One of the Committee’s primary recommendations involves a paradigm shift in how Taiwan protects its most vital digital systems. While the government has made commendable progress in data backup—ensuring that information can be recovered after a loss—the Committee argues that backup alone is insufficient for true national resilience.
In the event of a large-scale cyber incident or a prolonged infrastructure failure, the ability of core systems to remain operational is paramount. The Committee advocates for a "resilience-by-design" approach. This philosophy requires that continuity, recoverability, and adaptability be embedded into the architecture of IT systems from the very beginning of their development. This is particularly critical for sectors that underpin societal stability, such as financial services, healthcare, and national security operations.
Supporting data highlights the urgency of this shift. According to recent cybersecurity reports, Taiwan remains one of the most targeted regions globally for sophisticated cyberattacks, with the frequency of incidents involving critical infrastructure increasing annually. To mitigate these risks, the Committee suggests a coordinated public-private partnership model. This would involve structured dialogues with trusted global technology partners who have experience implementing large-scale continuity planning in other jurisdictions.
Furthermore, the Committee recommends that Taiwan move beyond theoretical preparedness. By incorporating joint drills, tabletop simulations, and cross-sector stress tests, the government can identify hidden dependencies and clarify decision-making authorities before a crisis occurs. This proactive rehearsal ensures that operational playbooks are not just documents on a shelf but are actionable strategies ready for mobilization.
Modernizing Privacy Frameworks and the PDPA
As the PDPC prepares for the 2026 implementation of new privacy regulations, the Committee has raised concerns regarding the potential for "rigid mandates" that could inadvertently stifle innovation. The goal, according to the Committee, should be to align Taiwan’s privacy framework with international benchmarks like the European Union’s General Data Protection Regulation (GDPR) while maintaining a risk-based perspective.
Key suggestions for the PDPC include:
- Defining Business Contact Information (BCI): Establishing a clear distinction for information used solely for professional purposes (names, business emails) to streamline commercial operations.
- Risk-Based Breach Notifications: Moving away from mandatory reporting for every minor incident and instead focusing on breaches that pose a real risk of harm to individuals. The Committee also suggests that the 72-hour notification window should begin only after a breach is reasonably confirmed, ensuring that reports are accurate and actionable.
- Outcome-Based Security: Avoiding prescriptive technical requirements, such as specific password rules that may become obsolete. Instead, the focus should be on security outcomes, allowing firms to adopt modern controls like multi-factor authentication and encryption.
The Committee emphasizes that a minimum 12-month transition period is necessary for organizations to update their technical systems and train personnel, ensuring that the new regulations do not cause undue economic disruption.
Aligning ICT Procurement with Global Cybersecurity Standards
A significant point of friction identified by the Committee is the current state of public information and communications technology (ICT) procurement. While MODA has introduced a risk-based approach to reviewing products harmful to national security, the Public Construction Commission (PCC) continues to use tendering templates that rely on broad "country-of-origin" (COO) restrictions.
The Committee argues that in an era of globally distributed production and software-defined hardware, where a product is manufactured is often an unreliable indicator of its security risk. A more effective approach would be to focus on who controls the product’s code, updates, and data flows.
The recommendation is to harmonize PCC model contracts with MODA’s entity-based framework—specifically banning certain brands known to pose risks rather than applying blanket exclusions based on manufacturing location. This alignment would reduce uncertainty for government agencies and ensure that Taiwan has access to the most advanced and secure global technologies.
Preparing for the Quantum Inflection Point
The emergence of "quantum advantage"—the point where quantum computers outperform classical ones—is no longer a distant prospect. Some experts suggest this could occur as early as the current year. Taiwan’s Phase II Five-Year National Quantum Strategy (2027–2031) is a welcome development, but the Committee believes more focus is needed on the "software and application" side of the equation.
While Taiwan’s strengths in hardware and semiconductors are a massive advantage, the utility of a quantum program depends on algorithms and talent. The Committee urges the government to incentivize international partners to link their quantum ecosystems with Taiwan. This includes fostering a domestic startup scene focused on quantum software.
Perhaps most critically, the Committee highlights the need for "quantum-safe" preparedness. Quantum computers will eventually have the power to break current encryption standards, posing a systemic risk to digital trust. The recommendation is to establish a unified, cross-agency task force to drive a "crypto-agility" strategy. This would involve a structured migration of critical business functions to quantum-resistant cryptography, beginning with "no-regret" actions such as cryptographic asset discovery.
Conclusion: A Collaborative Path Forward
The overarching message from the AmCham Technology Committee is one of partnership. The rapid development of AI and other emerging technologies requires a regulatory environment that is flexible, evidence-based, and globally aligned. By continuing to engage in structured dialogue with the private sector, the Taiwan government can ensure that its technology policies not only protect national interests but also drive the innovation that will define the island’s economic future.
As the AI Basic Act and other regulatory frameworks move toward finalization, the Committee remains optimistic. "Taiwan has the unique opportunity to lead by example," the report concludes. "By adopting risk-based approaches and fostering trusted international collaborations, Taiwan can secure its position as a resilient and indispensable hub in the global digital economy."
Asep Darmawan
Nana Muazin
