Regulatory  ·  2026-05-28

Singapore IMDA Publishes Discussion Paper on Legal Responsibility for AI Agents — Liability Framework for Agentic AI Value Chain

RegulatoryHigh impactSingapore
Singapore's Infocomm Media Development Authority (IMDA), convening a 20+-member working group from government, academia, and industry, published a discussion paper examining how legal responsibility should be allocated when AI agents act autonomously, use tools, interact with third parties, and cause harm. The paper was launched publicly at Asia Tech x Singapore in May 2026 and analyzes civil liability mechanisms, explores fault-based vs strict liability regimes in a computer-use agent hypothetical, and identifies three priority areas for further study: responsibility allocation along the agentic AI value chain, protections for actors with limited bargaining power, and liability for unforeseeable agent actions.
Although non-binding, this is the first Singapore working-group paper to systematically examine agent liability in private law, and it will directly shape forthcoming sector-specific frameworks. The paper identifies that demonstrable safeguards — logging, capability limits, human approval gates, and provenance records — will be legally relevant in allocating fault, which means security teams building agentic systems now need to instrument them as evidence-producing systems, not just functional pipelines.
Review all production agentic deployments against the paper's three liability dimensions: document capability scope and tool authorizations, implement human-in-the-loop approval gates for high-stakes actions, and ensure agent session logging is sufficient to reconstruct decision chains for legal review. Use the paper's hypothetical 'computer-use agent deviation' scenario as a tabletop exercise to identify gaps.
Sources
IMDA — Legal Responsibility for AI Agents (PDF)
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