The Framework

Thailand’s draft Digital Platform Economy Act (DPEA) includes interoperability requirements that apply to platforms designated as “gatekeepers,” defined as providers with more than ฿7 billion in domestic revenue, over 15 million monthly end users, and at least 10,000 annual business users over a three-year period.[1] These provisions prohibit covered platforms from preventing business users from offering their goods or services on other platforms or through direct channels, even if at different prices or under different conditions.^[2] The draft also prohibits contractual or technical restrictions that block or interfere with business users’ ability to interoperate with third-party services.^[3] These obligations would require platforms to support cross-platform access and multi-homing for commercial users.^[4] The Electronic Transactions Development Agency (ETDA) is responsible for enforcement and may impose penalties based on a percentage of global turnover, with no requirement for prior findings of anticompetitive harm.^[5]

Implications for U.S. Technology Leadership

Thailand’s proposed interoperability mandates impose direct structural burdens on U.S. technology companies by requiring them to redesign core platform functions to accommodate local multihoming and access requirements. Obligations such as allowing business users to offer different terms across channels or requiring compatibility with third-party services force changes to system design, user interface logic, and data handling infrastructure. These demands undermine the integrated architecture that many U.S. firms rely on to deliver consistent services across markets. By mandating these changes in advance, without a market failure or anticompetitive finding, the regulation compels U.S. platforms to expose and adapt proprietary interfaces, increasing risk and compliance complexity. The cost of aligning with divergent national interoperability standards is particularly high for firms offering cloud, app store, and financial services, where security, consistency, and data integration are central to product value.

The strategic implications extend beyond operational friction. Thailand’s interoperability rules serve as a mechanism for gaining access to systems and capabilities developed through U.S. R&D investment, subject to the threat of revenue-based penalties. While domestic and regional firms operate under less scrutiny or are excluded due to size thresholds, U.S. companies must absorb the cost of alignment, technical adaptation, and compliance reporting. This undermines comparative advantage and diminishes U.S. firms’ ability to maintain coherent product offerings across ASEAN markets. If adopted regionally, such interoperability mandates would force U.S. platforms into a fragmented compliance environment where architectural decisions are dictated by regulatory criteria rather than global product standards, eroding both competitiveness and leadership in Southeast Asia’s digital economy.[6]

Endnotes