Why March 11, 2026 Matters
March 11, 2026 is a deadline for two U.S. federal agencies working on AI policy. The outcome matters to companies operating across states, including Thai organisations serving U.S. customers.
Deadlines for Two Agencies
Commerce Department Assessment of State AI Laws
The U.S. Department of Commerce must submit an assessment of state-level AI laws and how they align with or conflict with national policy. The report will indicate the federal position on federal preemption and the extent to which individual states may continue setting their own rules.
FTC AI Policy Statement
The Federal Trade Commission must issue a policy statement on unfair or deceptive AI practices. It is intended to explain which uses of AI may be considered unfair or deceptive under the FTC Act.
Overview of the AI Laws on the Horizon
The legal picture is complicated because more than 20 states are preparing to enforce new AI and privacy laws in 2026.
- The Colorado AI Act takes effect on June 30, 2026 and sets duties related to algorithmic discrimination
- More than 15 states are considering privacy bills that cover AI use in automated decision-making
- The DOJ AI Litigation Task Force has been established to challenge state laws that may be considered "overly restrictive"
Requirements differ by state. Companies operating across several states therefore need to identify which rules apply to their customers, data and automated decisions.
Impact on Thai Organizations
Thai organisations with U.S. customers or business partners can start with the scope of their own work.
Identify the applicable laws. If you serve customers in several states, requirements may differ. Work involving consumers in Colorado may, for example, require an Impact Assessment review.
Document AI governance. Record each system’s purpose, data, accountable roles, approval points and monitoring process so the team can assess scope as rules change.
Use existing PDPA records as inputs. Data inventories, impact assessments and consent records may help the team identify relevant systems and data. They should not be treated as proof of compliance with U.S. AI laws.
Before relying on this article for a legal decision, check the current status of the rules in the relevant state with an adviser familiar with your business.
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