1. Introduction

Autonomous Shipping Governance in Thailand concerns the legal regulation of ships that use artificial intelligence (AI), machine learning, sensors, satellite navigation, robotics, automated propulsion and remote-control technologies to perform maritime operations with reduced or no direct human intervention.

Autonomous shipping is an emerging area of Thai civil and maritime law. It creates new legal questions concerning:

Liability for collisions involving autonomous vessels.

Responsibility of shipowners and remote operators.

AI navigation errors and software malfunctions.

Cargo loss and damage during autonomous transportation.

Seaworthiness and vessel safety certification.

Marine insurance and compensation for maritime accidents.

Cyberattacks against autonomous vessels.

Environmental damage caused by autonomous ships.

Electronic contracts, digital bills of lading and maritime evidence.

Jurisdiction and enforcement in international shipping disputes.

Important legal distinction: Thailand does not yet have a comprehensive, autonomous-shipping-specific civil liability code. Autonomous vessels must therefore be examined primarily under existing maritime legislation, general civil liability principles, shipping contracts and applicable international maritime rules.

There is also an important distinction between actual Thai judicial precedents involving autonomous vessels and conventional maritime decisions that can be applied by analogy. The six-plus decisions discussed below belong to the latter category; they should not be misrepresented as autonomous-ship judgments.

2. Legal framework governing autonomous shipping in Thailand

A. Navigation in Thai Waters Act B.E. 2456 (1913)

The Navigation in Thai Waters Act is one of the principal foundations of maritime regulation in Thailand.

It regulates matters including:

Navigation within Thai territorial and inland waters.

Vessel licensing and registration requirements.

Navigation safety.

Responsibilities of vessel owners and operators.

Inspection and supervision of vessels.

Compliance with applicable maritime regulations.

Application to autonomous vessels

An autonomous vessel cannot avoid ordinary navigation requirements merely because its navigation is performed by software.

For example, if an AI-controlled cargo vessel enters Thai waters, its owner and operator must consider applicable licensing, safety, inspection and operational requirements.

The central question is whether existing requirements concerning masters, crews and vessel operation can accommodate a ship operated entirely through remote or autonomous systems.

B. Thai Vessels Act B.E. 2481 (1938)

The Thai Vessels Act provides the legal framework for Thai vessel registration and related matters.

Its importance includes:

Registration and legal identity of vessels.

Nationality of vessels.

Ownership and transfer.

Vessel documentation.

Registration-related responsibilities.

For autonomous shipping, registration must be connected with clear identification of the legal owner, operator and other responsible parties.

An autonomous vessel should not become legally ownerless merely because it has no crew physically present.

C. Carriage of Goods by Sea Act B.E. 2534 (1991)

This legislation is particularly important for autonomous cargo vessels.

It regulates the responsibilities of maritime carriers concerning:

Loss of goods.

Damage to goods.

Delayed delivery.

Seaworthiness.

Cargo handling.

Bills of lading.

Carrier liability and statutory defences.

Sections 39–40 are particularly relevant to carrier responsibility and the period during which goods remain in the carrier's custody.

Sections 46–47 concern limitation periods, while sections 58–61 address limitations and calculation of carrier liability.

Autonomous shipping application:

Suppose an autonomous vessel transports electronic equipment from Thailand to Singapore. An AI navigation malfunction causes the vessel to collide with another ship, resulting in cargo damage.

The carrier cannot automatically avoid liability by arguing that the accident was caused by an autonomous system.

The court would examine the applicable statutory provisions, the carrier's custody of the goods, the cause of the damage and any available statutory defence.

D. Civil and Commercial Code of Thailand

The Civil and Commercial Code (CCC) provides the general principles governing contractual and non-contractual civil liability.

Important provisions include:

Section 420: General liability for wrongful acts.

Section 425: Employer's liability for wrongful acts committed by an employee in the course of employment.

Section 437: Special liability concerning damage caused by dangerous things or objects under a person's control.

Sections 587 onwards: Hire-of-work contractual principles, where applicable.

General contractual principles concerning performance, breach and damages.

Application:

If an autonomous ship collides with a passenger vessel because its collision-avoidance software malfunctions, the injured party may consider a civil claim against the legally responsible owner, operator or other liable party.

The absence of a human captain does not eliminate the possibility of civil liability.

E. Product Liability Act B.E. 2551 (2008)

The Product Liability Act is important where damage results from defective autonomous navigation technology.

Potentially responsible parties may include:

Manufacturers.

Importers.

Sellers.

Other statutory business operators falling within the Act.

For example, if a defective radar sensor repeatedly misidentifies nearby vessels, resulting in a collision, the injured party may examine whether the product liability legislation applies.

F. Electronic Transactions Act B.E. 2544 (2001)

Autonomous shipping depends heavily on electronic communications and digital documentation.

The Electronic Transactions Act supports the legal recognition of electronic information and transactions.

It is relevant to:

Electronic bills of lading.

Electronic shipping contracts.

Remote navigation instructions.

Automated commercial transactions.

Electronic communications between ports and vessels.

Digital maritime records.

The Act does not, by itself, establish that every autonomous decision is legally valid or that every AI-generated instruction is attributable to a particular person.

G. Preventing Ship Collision Act and maritime collision liability

Thailand's collision-prevention legislation is essential to autonomous navigation.

Autonomous vessels must be capable of observing applicable navigation rules, including requirements concerning:

Safe speed.

Lookout.

Collision-risk assessment.

Navigation lights and signals.

Giving way and maintaining course.

Emergency manoeuvres.

If an autonomous vessel fails to recognize another ship or incorrectly calculates collision risk, the resulting damage may create civil liability.

The Civil Liability Arising from Collision Act B.E. 2548 (2005) is also relevant to determining responsibility and compensation arising from maritime collisions.

H. Personal Data Protection Act B.E. 2562 (2019)

Autonomous vessels collect and process substantial quantities of information, including:

Crew identification information.

Passenger information.

Vessel tracking information linked to identifiable individuals.

Remote-control operator information.

Port access and security records.

Where personal data is processed, the PDPA may impose obligations concerning lawful processing, security and data-subject rights.

I. International maritime law and the IMO MASS Code

The International Maritime Organization (IMO) adopted the non-mandatory International Code of Safety for Maritime Autonomous Surface Ships (MASS Code) in May 2026. It came into effect on 1 July 2026.

The Code establishes a goal-based safety framework for autonomous commercial ships, including operational risk assessment, safety certification, operational limitations and human oversight.

Importantly, the master retains overall responsibility even when operating from shore through a Remote Operations Centre.

The Code is presently non-mandatory, with development of a mandatory version expected to progress towards 2030–2032. Its adoption does not automatically amend Thai domestic legislation.

Autonomous shipping

For Thailand, the MASS Code provides an important framework for modernizing vessel licensing, remote operations, safety management and technical certification.

3. Civil liability in autonomous shipping

A. Liability of shipowners

The shipowner is one of the most important parties in autonomous shipping disputes.

An owner may face liability where damage is connected with:

Defective vessel maintenance.

Inadequate safety equipment.

Improper installation of autonomous navigation systems.

Failure to maintain cybersecurity.

Failure to arrange appropriate operational supervision.

Negligent selection of the vessel operator.

For example, if an autonomous vessel collides with a fishing boat because its sensors were not properly maintained, the shipowner may face a civil claim depending on the applicable statutory and contractual rules.

B. Liability of remote operators

Remote operators may be responsible for failures involving:

Incorrect navigation instructions.

Failure to monitor vessel movement.

Delayed emergency intervention.

Incorrect interpretation of sensor information.

Failure to respond to collision warnings.

The legal assessment should examine whether the operator had the authority, training, information and practical ability to intervene.

C. Liability of AI developers and software manufacturers

AI developers may face liability when defects in autonomous navigation software cause foreseeable damage.

Examples include:

Incorrect obstacle detection.

GPS manipulation vulnerabilities.

Faulty route-planning algorithms.

Failure of emergency stopping systems.

Incorrect interpretation of maritime signals.

The Product Liability Act and general tort principles may become relevant, depending on the nature of the defect and the parties involved.

D. Joint and multiple-party liability

An autonomous shipping accident may involve several parties simultaneously:

A court must establish the applicable legal basis and causal connection before imposing liability. All parties are not automatically jointly liable merely because they participated in the shipping operation.

4. Important Supreme Court case laws relevant to autonomous shipping in Thailand

The following Thai Supreme Court judgments provide useful legal principles for autonomous shipping disputes. They are conventional maritime and cargo decisions, not direct rulings on AI-operated ships.

Case 1: Supreme Court Judgment No. 15502/2556

Subject: Carrier liability for missing cargo

The shipper handed goods to the carrier, but the entire consignment was missing when the vessel arrived.

The Supreme Court held that the loss occurred while the goods were in the carrier's custody. The carrier could not establish an applicable statutory exception and was liable under sections 39 and 43 of the Carriage of Goods by Sea Act.

The Court also recognized the rights of a lawful bill-of-lading holder to claim compensation.

Relevance to autonomous shipping:

If cargo disappears during an autonomous vessel's voyage because of a navigation-system failure, unauthorized access or operational malfunction, the carrier's statutory obligations remain important.

The carrier cannot automatically escape liability by attributing the loss to autonomous technology.

Case 2: Supreme Court Judgment No. 69/2556

Subject: Cargo theft and carrier responsibility

Copper tubes weighing more than 3,000 kilograms disappeared from a container and were replaced by sandbags. Although the container seal remained intact, other evidence established that the cargo had disappeared while in the carrier's custody.

The Supreme Court held the carrier liable because it failed to establish an applicable statutory defence.

Relevance to autonomous shipping:

This decision is useful when examining digital cargo-security systems.

For example, an autonomous vessel may use electronic seals, automated cargo monitoring and remote surveillance. However, electronic records cannot automatically establish that cargo was properly protected.

The reliability of monitoring systems and the surrounding evidence must be examined.

Case 3: Supreme Court Judgment No. 8973/2553

Subject: Liability of an actual carrier

A company entrusted with transporting goods from Singapore to Laem Chabang and subsequently moving containers to an inland container depot was treated as an actual carrier.

The container had holes and was stored in an unsafe location, allowing water to enter and damage the cargo.

The Court recognized the liability of the actual carrier together with the contractual carrier.

Relevance to autonomous shipping:

Autonomous shipping frequently involves multiple service providers, including:

Vessel owners.

Shipping companies.

Remote-control centres.

Logistics operators.

Container-terminal operators.

The judgment supports examining the actual functions performed by each participant rather than relying solely on contractual labels.

Case 4: Supreme Court Judgment No. 12708/2555

Subject: End of the carrier's custody

The container had been unloaded from the vessel and placed in the Hong Kong port authority's container yard. A fire was discovered after the container was subsequently moved to a warehouse.

The Supreme Court held that the container was no longer in the actual carrier's custody when the relevant damage occurred.

Relevance to autonomous shipping:

The case is important for identifying the boundaries of responsibility in automated maritime logistics.

An autonomous vessel operator may be responsible during one stage of transportation, while a terminal operator or another logistics provider may have responsibility during a subsequent stage.

The precise contractual and statutory custody period must be established.

Case 5: Supreme Court Judgment No. 2586/2543

Subject: Container delivery and limitation of liability

In a CY/CY carriage arrangement, the Court considered when the carrier's responsibility ended after the container was delivered to the destination port under the applicable port regulations.

The claim was held to be time-barred because it was brought after the one-year period under section 46 of the Carriage of Goods by Sea Act.

Relevance to autonomous shipping:

Autonomous shipping creates complicated digital delivery records.

This judgment highlights the importance of determining:

The actual delivery date.

The legally recognized delivery event.

The beginning of the limitation period.

The party responsible for maintaining delivery records.

An electronic notification that a ship has reached its destination is not necessarily equivalent to legal delivery of cargo.

Case 6: Supreme Court Judgment No. 15080/2556

Subject: Delivery to port authority and limitation period

The destination port required the carrier to hand cargo over to its port authority.

The Supreme Court held that this handover constituted delivery under section 40(3). Consequently, the one-year limitation period began from that event, rather than from the later date when the consignee physically collected the cargo.

Relevance to autonomous shipping:

Autonomous vessels may complete automated discharge operations and transfer cargo through digital port systems.

The legal distinction between unloading, transfer of custody and final collection remains important when determining the commencement of limitation periods.

Case 7: Supreme Court Judgment No. 4581/2552

Subject: Storms, foreseeable maritime risks and force majeure

The case concerned cargo loss during a storm. The Court examined the foreseeability of the weather conditions and whether the master could reasonably have avoided the danger.

The Court held that the relevant storm did not qualify as force majeure or a peril of the sea under section 52 in the circumstances.

Relevance to autonomous shipping:

This judgment has significant implications for AI-based weather forecasting and route-planning systems.

If an autonomous vessel enters a dangerous weather area despite available forecasts and safer alternative routes, the carrier may have difficulty establishing a statutory defence.

The use of AI does not automatically convert a foreseeable navigational risk into force majeure.

Case 8: Supreme Court Judgment No. 1273/2554

Subject: Unseaworthiness, cargo packing and limitation of liability

The carrier packed goods into a container with a leaking roof despite knowing that damage could result.

The Court treated the conduct as falling within section 60(1), preventing reliance on the ordinary statutory limitation of liability.

Relevance to autonomous shipping:

The same reasoning may be important where an autonomous shipping company knowingly operates a vessel with defective sensors, unsafe software or compromised navigation equipment.

Where the statutory requirements concerning intentional conduct or knowledge of the risk are satisfied, ordinary liability limitations may not be available.

Case 9: Supreme Court Judgment No. 22318/2555

Subject: Statutory limitation of carrier liability

A subrogated insurer brought a claim against carriers for damage to imported equipment. The Supreme Court considered the statutory limitation of liability and the failure to plead the necessary grounds for avoiding that limitation.

The Court maintained the applicability of section 58.

Relevance to autonomous shipping:

The judgment demonstrates the importance of properly pleading and proving the facts necessary to establish liability beyond statutory limits.

In autonomous shipping disputes, claimants should specifically identify relevant software defects, operational negligence and the carrier's knowledge of the risk where those matters are legally material.

Case-law references and factual summaries: Thai Supreme Court maritime decisions discussed in the Thai cargo-claims legal analysis. The application to autonomous vessels is analytical, not a finding made by those courts. 

Eksiam & Partners+1

5. Major legal issues in autonomous shipping governance

A. Autonomous vessel collision disputes

Collision is one of the most important areas of autonomous maritime liability.

Consider a situation in which an autonomous cargo vessel approaches Laem Chabang Port and its AI navigation system fails to recognize an approaching passenger vessel.

Potential legal issues include:

Whether the vessel maintained a proper lookout.

Whether its navigation system complied with collision-prevention requirements.

Whether the remote operator monitored the vessel adequately.

Whether the shipowner maintained the navigation equipment.

Whether defective software contributed to the accident.

Whether another vessel contributed to the collision.

Thai civil liability principles and collision legislation must be considered alongside applicable international navigation rules.

B. Autonomous shipping and seaworthiness

Seaworthiness traditionally involves the vessel's physical condition, equipment, crew and ability to undertake its intended voyage safely.

For autonomous vessels, seaworthiness must also include technological reliability.

Important considerations include:

Sensor accuracy.

Radar functionality.

Navigation software reliability.

Satellite connectivity.

Emergency control systems.

Cybersecurity protection.

Remote-control availability.

Backup power systems.

A vessel may be physically sound but technologically unsafe.

Accordingly, the concept of seaworthiness should evolve to include the reliability of autonomous operating systems.

C. AI navigation errors and negligence

AI systems may produce incorrect decisions because of:

Incomplete training data.

Incorrect sensor information.

Algorithmic bias.

Software defects.

Environmental uncertainty.

Failure to identify unexpected maritime obstacles.

The central civil-law issue is whether the resulting damage can be attributed to a legally responsible person or organization.

For example, if an AI system repeatedly misidentifies small fishing vessels, the court may need to examine the manufacturer's design, the operator's monitoring practices and the owner's maintenance obligations.

D. Cybersecurity and maritime liability

Autonomous ships rely on interconnected digital systems.

A cyberattack could affect:

Vessel navigation.

Engine control.

Cargo security.

Satellite communications.

Port management systems.

Remote-control operations.

Suppose a hacker takes control of an autonomous vessel and changes its destination, causing a collision in Thai waters.

Potential legal questions include:

Whether the shipowner implemented reasonable cybersecurity measures.

Whether the software manufacturer supplied adequate security.

Whether the remote operator detected the intrusion.

Whether the attack constitutes an intervening cause.

Whether the relevant insurance policy covers cyber-related losses.

The existence of a cyberattack does not automatically eliminate the liability of the shipowner or carrier.

E. Autonomous shipping and marine insurance

Marine insurance is essential for the commercial operation of autonomous vessels.

Insurance arrangements may need to address:

Hull and machinery damage.

Cargo damage.

Collision liability.

Third-party bodily injury.

Environmental pollution.

Cybersecurity incidents.

Software malfunction.

Remote-operation failures.

Traditional marine insurance policies may contain assumptions about human crews and conventional navigation.

Insurers should therefore clarify whether autonomous operations are covered and whether particular autonomy levels, software systems or remote-control arrangements require additional disclosure.

F. Environmental liability

Autonomous vessels can contribute to environmentally sustainable transportation through efficient navigation and optimized fuel consumption.

However, accidents may cause:

Oil spills.

Chemical leakage.

Marine pollution.

Damage to coral reefs.

Harm to fisheries.

Destruction of coastal ecosystems.

Thai environmental legislation, maritime pollution requirements and applicable international conventions must be considered.

A shipowner or operator may face civil or statutory consequences when an autonomous vessel causes environmental damage.

G. Electronic evidence and digital maritime records

Autonomous shipping produces large amounts of digital evidence.

Examples include:

AI decision logs.

GPS tracking records.

Radar recordings.

Sensor data.

Remote-control communications.

Software update histories.

Electronic bills of lading.

Cybersecurity incident reports.

Under the Electronic Transactions Act, electronic information may receive legal recognition, subject to the applicable requirements.

In litigation, the court must examine authenticity, integrity, reliability and the circumstances in which electronic records were generated and preserved.

A particularly important issue is whether a shipping company can produce complete and unaltered records of an autonomous vessel's decisions immediately before an accident.

6. Autonomous shipping and contractual governance

Autonomous shipping requires more sophisticated maritime contracts than conventional transportation arrangements.

A. Autonomous vessel operating agreements

These agreements should identify:

The shipowner.

The vessel operator.

The remote-control service provider.

The software developer.

The maintenance provider.

The party responsible for emergency intervention.

The allocation of insurance responsibilities.

B. Autonomous cargo transportation contracts

Contracts should address:

Cargo custody.

Delivery obligations.

Electronic bills of lading.

Delayed delivery.

Autonomous navigation failures.

Cybersecurity incidents.

Liability limitations.

Dispute resolution.

The Carriage of Goods by Sea Act remains important even where the transportation service is performed by autonomous technology.

C. Smart contracts in maritime transportation

Blockchain and smart contracts may automate:

Freight payments.

Cargo release.

Port entry arrangements.

Insurance notifications.

Delivery confirmation.

Supply-chain documentation.

However, an automated payment or cargo-release instruction does not automatically resolve the underlying question of contractual liability.

Thai electronic transaction rules, ordinary contract principles and applicable maritime legislation must be considered together.

7. Regulatory challenges for Thailand

Thailand faces several important challenges in establishing a comprehensive autonomous shipping governance system.

A Thailand-focused UNESCAP study identifies a particularly important regulatory gap: existing navigation legislation assumes that several responsibilities are performed by a ship's master, including collision response, accident reporting, restricted-area navigation and handling dangerous cargo.

The study recommends regulatory modernization, training, safety management and controlled experimental environments for autonomous vessels.

unescap.org

8. Recommendations for strengthening autonomous shipping governance in Thailand

The following reforms could create a more effective legal framework.

1. Autonomous Shipping Act

Thailand should consider developing dedicated legislation defining autonomous vessels, remote operators, autonomous shipping companies and their civil responsibilities.

2. Remote Master Recognition

The law should clarify the legal status, authority and responsibilities of a master operating a vessel remotely.

3. Mandatory Safety Certification

Autonomous vessels should undergo technical and operational safety assessments before commercial deployment.

4. AI Accountability Framework

Legislation should establish clear responsibilities for shipowners, operators, software developers and manufacturers.

5. Autonomous Vessel Insurance

Thailand should encourage specialized marine insurance products covering software malfunction, cyberattacks and remote-operation risks.

6. Maritime Cybersecurity Regulation

Autonomous shipping companies should implement cybersecurity standards, incident-reporting systems and emergency recovery procedures.

7. Controlled Testing Areas

The Marine Department should develop regulatory sandboxes for testing autonomous vessels in controlled waterways before authorizing wider commercial operations.

8. International Harmonization

Thai maritime regulation should progressively align with IMO standards, particularly the MASS Code and relevant SOLAS requirements.

9. Digital Evidence Standards

Regulations should establish minimum requirements for recording, retaining and producing autonomous navigation data.

10. Environmental Accountability

Autonomous vessels should comply with marine environmental protection requirements and maintain effective pollution-response systems.

9. Hypothetical legal case study

Facts:

A Thai shipping company operates an autonomous cargo vessel between Bangkok Port and Singapore. During its voyage, the vessel's AI navigation system incorrectly identifies another vessel's location.

The autonomous ship changes direction suddenly and collides with a fishing vessel. The collision causes:

Damage to the fishing vessel.

Injuries to fishermen.

Loss of commercial cargo.

Marine pollution.

Financial losses to the cargo owner.

Legal analysis:

Possible judicial approach:

A Thai court would likely examine:

Whether the vessel was legally authorized to operate.

Whether the shipowner complied with safety requirements.

Whether the AI system was defective.

Whether the remote operator failed to intervene.

Whether the collision resulted from negligence or another legally relevant cause.

Whether multiple parties contributed to the damage.

Whether statutory limitations or defences apply.

The court would need to distinguish contractual carrier liability from tort liability and product liability. The same accident may generate several different claims.

10. Conclusion

Civil Law and Autonomous Shipping Governance in Thailand represents an emerging intersection of maritime law, civil liability, artificial intelligence, commercial contracts, cybersecurity and environmental protection.

Thailand's existing legal framework provides important foundations through the Navigation in Thai Waters Act, Thai Vessels Act, Carriage of Goods by Sea Act, Civil and Commercial Code, Product Liability Act and Electronic Transactions Act.

The Thai Supreme Court decisions discussed above provide useful principles concerning carrier responsibility, cargo custody, seaworthiness, force majeure, limitation of liability and maritime evidence. However, they do not directly resolve the distinctive legal problems of fully autonomous vessels.

The IMO MASS Code, effective from 1 July 2026 as a non-mandatory instrument, provides an important international starting point.

Ultimately, Thailand should develop a comprehensive autonomous shipping governance framework that combines technological innovation with clear ownership responsibilities, human oversight, safety certification, insurance protection, environmental accountability and effective civil remedies.

The central legal principle should be that automation must not create a gap in legal accountability.