BOT Framework for Safeguarding the Financial Sector from Illicit Activities: New Supervisory Expectations for Financial Institutions and Payment Providers

The Bank of Thailand (BOT), together with financial institutions and regulated financial service providers, has formally launched the Framework for Safeguarding the Financial Sector from Illicit Activities, a sector-wide initiative intended to prevent the financial system from being used to facilitate technology-enabled crime, corruption, money laundering, fraud, and other illicit activities. The Framework represents a significant supervisory development for banks, payment service providers, e-money operators, foreign exchange businesses, and non-bank lenders. While the Framework itself is principally a cooperation and policy framework rather than a standalone regulation imposing penalties, the BOT has expressly indicated that it will strengthen regulations, minimum standards, and supervisory oversight to promote consistent implementation across the financial sector. Accordingly, regulated entities should view the Framework not merely as a statement of policy, but as an indication of the direction in which future supervisory expectations and regulatory requirements are likely to develop.

Five Core Principles:

The Framework is built around five principles that participating institutions are expected to apply in a manner appropriate to their business models and risk profiles. First, preventing misuse of the financial sector should form part of leadership and corporate governance, with boards and senior management responsible for establishing policies, strategic direction, oversight arrangements, and adequate resources. Second, institutions should translate those commitments into effective standards and execution, including appropriate minimum standards for monitoring, detection, and risk response, with periodic review as risks evolve. Third, institutions are expected to develop expertise and data-driven capabilities, using data, technology, and specialized knowledge to improve monitoring and detection. Fourth, the Framework emphasizes collaboration and collective intelligence, including exchanges of information, intelligence, fraud typologies, risk indicators, and best practices among financial institutions, government authorities, private-sector organizations, and other relevant stakeholders, subject to applicable legal frameworks. Finally, preventive measures should pursue balanced objectives, taking into account financial inclusion, fair competition, innovation, customer convenience, and the need to avoid unnecessary burdens on legitimate users.

From Policy Framework to Operational Controls:

The significance of the Framework becomes clearer when the commitments of the BOT and participating industry groups are considered. The BOT intends to strengthen KYC, Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) standards, including end-to-end controls against mule accounts. It also plans to strengthen Know Your Merchant (KYM) requirements and oversight of high-risk merchants, particularly in payment acceptance services. Other areas identified for enhanced controls include high-value cash transactions, conversion of illicit proceeds into assets that are more difficult to trace, digital financial service security, and standards applicable to non-bank operators.

Financial institutions and industry associations have correspondingly committed to stronger customer identification and due diligence, greater scrutiny of high-risk accounts and cash transactions, and increased use of data and technology to identify unusual transactions and behavioral patterns. Banks are expected to integrate internal information with trusted external sources and use customer profiles, behavioral information, and transaction inflow/outflow patterns to identify links among accounts and suspicious activity. Payment service providers are expected to strengthen KYM throughout the merchant lifecycle, including enhanced merchant screening and behavioral monitoring, while non-bank lenders are expected to strengthen their assessment of customers, related parties, transactions, and sources of funds. The Framework also contemplates databases of high-risk persons and merchants, links with the Central Fraud Registry, and development of industry-wide AML/CFT operational guidelines.

Data Sharing Becomes a Central Compliance Issue:

One of the most consequential elements of the Framework is its emphasis on information sharing. The BOT intends to analyze linkages and share risk patterns, behavioral indicators, and information concerning individuals, legal entities, and merchants identified as high risk. It also envisages greater data exchange and collaborative analytics involving regulatory authorities, law enforcement agencies, and other government bodies. Financial institutions and payment providers will likewise be expected to contribute relevant information, including unusual transaction patterns, merchant information, fraud intelligence, and other indicators that may assist in identifying misuse of the financial system.

This creates an important intersection between financial-crime prevention and personal data protection. The Framework expressly recognizes that information exchange must occur within applicable legal frameworks. Consequently, an expectation or request to share information for fraud prevention purposes should not automatically be treated as removing the need for analysis under the Personal Data Protection Act (PDPA). Institutions should identify an appropriate lawful basis for each relevant processing and disclosure activity, determine whether the data collected and shared are necessary and proportionate to the stated purpose, establish appropriate retention periods, and implement access controls and security safeguards. Data accuracy will be particularly important where information is used to classify a person or merchant as high risk or to restrict access to financial services.

High-Risk and Blacklist Databases Require Particular Attention:

The contemplated development and sharing of high-risk-person and merchant information raises additional governance considerations. A risk indicator used merely to trigger additional review is materially different from a blacklist that automatically results in account restrictions, rejection of onboarding, termination of services, or other adverse consequences. Institutions should therefore consider establishing clear criteria for inclusion and removal, defining the evidentiary threshold required for a high-risk designation, controlling who may submit or amend records, periodically reviewing whether information remains accurate and relevant, and establishing escalation or review procedures where a designation may materially affect a customer.

These issues become more significant as databases are interconnected across institutions or with centralized fraud information systems. Incorrect, outdated, or insufficiently verified information could potentially propagate across the financial sector and affect an individual or business beyond the institution that originally generated the risk indicator. Governance of shared databases should therefore address not only cybersecurity and access management but also data provenance, accuracy, correction procedures, retention, accountability, and the distinction between intelligence suggesting risk and verified findings of unlawful conduct.

What Financial Institutions and Payment Providers Should Do Now

Although detailed minimum standards will continue to develop, regulated entities should consider conducting a readiness assessment against the Framework now rather than waiting for individual implementing measures. This should include reviewing whether board and senior-management oversight adequately covers financial-crime and fraud risks; mapping existing KYC/CDD/EDD and KYM controls against the emerging supervisory direction; assessing high-value cash and unusual-transaction monitoring; reviewing the use of AI, behavioral analytics, and external data sources; and identifying existing or planned information-sharing arrangements with other institutions, industry bodies, regulators, and law-enforcement agencies. Particular attention should be given to the interface between financial-crime controls and the institution’s PDPA, cybersecurity, data governance, outsourcing, and third-party risk frameworks.

Institutions should also document the legal and governance architecture supporting fraud-related data processing before broader industry sharing becomes operational. This may include reviewing privacy notices, records of processing activities, data-sharing agreements or protocols, retention schedules, access matrices, security controls, procedures for correcting inaccurate risk information, and the allocation of responsibilities among compliance, AML, fraud, privacy, cybersecurity, legal, and business teams. Where automated tools or risk-scoring systems are used to identify high-risk customers or transactions, institutions should also consider whether their governance arrangements provide sufficient human oversight and mechanisms to manage false positives and unintended customer impacts.

Key Takeaways:

The Framework marks a shift toward a more coordinated, intelligence-led approach to protecting the financial sector from illicit activities. Although it is not, by itself, a standalone penal regulation, the BOT has expressly signaled further development of regulations, minimum standards, and supervisory oversight, making the Framework an important indicator of future compliance expectations.

For financial institutions, payment providers, and other regulated non-banks, the immediate priorities are to assess existing KYC/CDD/EDD and KYM controls, strengthen technology-based detection and high-risk transaction monitoring, and prepare for substantially greater information sharing across the financial ecosystem. At the same time, fraud prevention and financial-crime objectives must be reconciled with PDPA requirements, cybersecurity controls, proportionality, data accuracy, retention, and appropriate governance of high-risk and blacklist databases.

The next major development to monitor will be the BOT’s issuance or enhancement of minimum standards, regulations, supervisory guidelines, or operational requirements implementing the Framework. Those measures are likely to determine when the Framework moves from a high-level sector commitment to more concrete and enforceable compliance expectations.

Author: Panisa Suwanmatajarn, Managing Partner.

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Bangkok Blueprint: A New Framework for Protecting the Financial Sector from Illicit Activities

The Bank of Thailand (BOT) is moving toward a broader and more coordinated approach to preventing the financial system from being used for fraud and other illicit activities. As part of this initiative, the BOT, together with relevant financial-sector stakeholders, is preparing the Framework on Safeguarding the Financial Sector from Illicit Activities, while the BOT, the International Monetary Fund (IMF), and the World Bank Group are also advancing the Bangkok Blueprint for Fraud-Resilient Financial Services.

Although the final text of the Framework has not yet been separately published in the official materials reviewed for this article, the initiatives signal an important development in financial-sector supervision: fraud prevention and the prevention of illicit financial flows are increasingly being treated as responsibilities extending across the financial ecosystem rather than as matters confined to individual institutions or conventional anti-money laundering controls.

The Bangkok Blueprint:

The Bangkok Blueprint is intended to strengthen the resilience of financial services against fraud and scams in the digital age. The BOT has described the initiative as being developed with the IMF and World Bank Group and as providing a practical reference for strengthening coordinated responses to digital financial fraud.

This direction reflects the changing nature of financial crime. Digitalization has made payments faster and financial services more accessible, but it has also allowed fraud proceeds to move rapidly between accounts, institutions, payment channels, and potentially other asset classes. An effective response therefore increasingly depends on coordination among financial institutions and other participants in the financial ecosystem.

The BOT has already taken measures addressing unauthorized payment fraud and, more recently, authorized push payment fraud. These measures have included controls relating to mule accounts, tracing of fund flows, use of customer behavioral information, risk-based transaction limits, and shared-responsibility principles. The Bangkok Blueprint appears to place these developments within a broader policy framework focused on making financial services more resilient against fraud.

Safeguarding the Financial Sector from Illicit Activities

Alongside the Bangkok Blueprint, the BOT is coordinating the Framework on Safeguarding the Financial Sector from Illicit Activities. According to the BOT’s official announcement, this is intended to be a sector-wide initiative aimed at preventing the financial system from being misused for illegal and fraudulent activities.

The significance of the Framework is its potentially broad institutional reach. The policy direction described publicly extends beyond commercial banks and reflects the need for controls across different points through which illicit funds may enter, move through, or leave the financial system.

Public statements surrounding the initiative indicate an emphasis on strengthening customer due diligence, identifying higher-risk transactions, improving information sharing, and reinforcing anti-money laundering controls. However, until the final Framework is officially published, these matters should not be treated as new binding regulatory requirements merely by reason of the Framework itself.

From Individual Compliance to Ecosystem Responsibility:

The more important development may be the shift in regulatory philosophy. Traditional compliance programs tend to focus on whether an individual institution has properly identified its customer, monitored transactions, reported suspicious activity, and complied with applicable restrictions. Digital fraud demonstrates the limitations of an institution-by-institution approach because funds can move through several accounts and service providers within a very short period.

The emerging approach therefore places greater importance on the ability of institutions to identify suspicious behavior rapidly, connect information from different sources, exchange relevant fraud intelligence, and intervene before illicit funds disappear from the regulated financial system.

For banks and other regulated financial businesses, this could eventually affect the design of onboarding controls, customer risk classification, transaction-monitoring systems, mule-account detection, escalation procedures, information-sharing arrangements, and internal governance. It may also increase expectations that management can demonstrate not merely formal compliance with existing rules, but the effectiveness of controls in preventing the institution’s products and infrastructure from facilitating illicit activity.

What Financial Institutions Should Watch:

The practical significance of the Framework will depend on the final text and any subsequent BOT rules, guidelines, supervisory expectations, or industry commitments implementing it. In particular, financial institutions should monitor whether the initiative results in more specific expectations concerning mule-account identification and management, customer and merchant onboarding, enhanced due diligence for higher-risk customers, transaction monitoring, cross-institution information sharing, rapid restriction or suspension of suspicious transactions, and governance responsibility for financial-crime controls.

Institutions should also consider the interaction between these measures and their existing obligations concerning anti-money laundering, cybersecurity, fraud prevention, consumer protection, and personal data protection. Greater information sharing can improve fraud detection, but institutions will need appropriate legal bases, governance, security measures, access controls, retention policies, and safeguards governing the use and disclosure of customer information.

Key Takeaways:

The Bangkok Blueprint and the Framework on Safeguarding the Financial Sector from Illicit Activities indicate a move toward a more integrated approach to financial crime, linking fraud prevention, illicit-fund detection, customer due diligence, transaction monitoring, and cooperation across the financial ecosystem.

For regulated financial businesses, the key issue will be whether the final Framework remains principally a statement of collective commitment or develops into concrete supervisory expectations. If detailed obligations or commitments are introduced, institutions may need to reassess their customer onboarding, mule-account controls, transaction-monitoring capabilities, information-sharing arrangements, escalation procedures, and governance structures.

Until the final Framework is officially available, however, institutions should distinguish between the BOT’s announced policy direction and legally or regulatory binding requirements. The publication of the final Framework—and any subsequent implementing measures—will therefore be important in determining the immediate compliance impact on banks, payment service providers, non-bank lenders, foreign exchange businesses, and other regulated financial-sector participants.

Author: Panisa Suwanmatajarn, Managing Partner.

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Digital Platform Fees: New Guidance on Transparency and Fairness

Thailand’s regulation of digital platform services is continuing to develop beyond basic registration and disclosure obligations. The Electronic Transactions Development Agency (ETDA) has issued a new guideline addressing transparency and fairness in the fees charged by digital platform service providers. The guideline is intended to address growing concerns surrounding unpredictable fee structures, hidden costs, frequent changes to charges, and contractual arrangements that make it difficult for businesses using platforms to determine their actual cost of doing business.

The guideline does not impose a statutory cap on platform fees or prescribe particular prices. Instead, it establishes a best-practice framework under which platform operators are encouraged to make their fee structures transparent, understandable, predictable, and fair. Although the guideline is voluntary in nature, it provides an important indication of the regulatory standards that ETDA considers appropriate for the digital platform sector and should therefore be considered when platform operators design or review their terms and conditions and commercial arrangements.

Transparency of Platform Fees:

A central principle of the guideline is that users should be able to understand the total financial burden associated with using a platform.

Platform operators are encouraged to present fee information in a centralized and readily accessible location rather than requiring users to search through multiple pages, policies, or contractual documents. Information should clearly identify the different categories of fees, explain what each fee represents and what service or benefit the user receives in return, and provide sufficient information regarding the basis for calculating the fee.

Where a fee is calculated according to a formula or percentage, practical examples should be provided where appropriate so that users can reasonably estimate the amount they will be required to pay.

This approach is particularly relevant to platforms where the overall cost imposed on merchants or service providers consists of several components. Depending on the business model, these may include commissions, transaction charges, payment-processing fees, advertising expenses, promotional program charges, affiliate fees, logistics charges, or charges for additional platform services.

The regulatory concern is therefore not limited to the headline commission rate. A fee structure may create transparency concerns where individual charges appear understandable in isolation but users cannot readily determine their aggregate cost.

Changes to Fees Should Be Predictable:

The guideline also addresses changes to platform fees. ETDA recommends that platform operators provide users with advance notice of changes, with the guideline contemplating at least 15 days’ prior notice.

This principle is significant for merchants and other business users because frequent or unexpected changes to fees may affect their ability to calculate margins, determine prices, or decide whether continued participation on a platform remains commercially viable.

From a compliance perspective, platform operators should therefore consider establishing an internal change-management process for fee adjustments. Before introducing or increasing a fee, operators should identify the affected users, prepare an understandable explanation of the change, determine how and when notice will be delivered, and maintain appropriate records showing that the required communication has taken place.

The issue should also be considered together with the existing regulatory framework governing changes to the terms and conditions of digital platform services. Fee changes should not be treated merely as an accounting matter where they effectively alter the commercial terms governing the relationship between the platform and its users.

Fairness Is More Than Disclosure:

Transparency alone does not necessarily make a fee fair. The guideline therefore establishes a separate fairness principle.

Among other things, platform operators are encouraged to avoid duplicative charges and to ensure that fees have a reasonable relationship with the relevant costs or value provided. Users should generally not be compelled to purchase ancillary services merely as a practical condition of obtaining the core platform service.

Additional fees should similarly correspond to genuine additional value or services received by users rather than operating as unavoidable charges presented as optional services.

These principles are particularly relevant to platform ecosystems in which merchants may technically be free not to purchase advertising, participate in promotions, use affiliate programs, or acquire other supplementary services, but where the commercial architecture of the platform could make participation practically necessary to remain visible or competitive.

Accordingly, platform operators reviewing compliance should consider the economic substance of their fee arrangements rather than relying exclusively on how a charge is described in the contract.

Relationship With Competition Law:

The guideline also has an important competition-law dimension. In ETDA’s discussion of the new framework, the Trade Competition Commission of Thailand emphasized that regulatory scrutiny is not simply concerned with whether a fee is “high” or “low.” Relevant concerns can include whether the pricing structure is reasonable and transparent and whether the operator can explain the basis on which particular fees are determined.

Competition concerns may potentially arise in circumstances involving excessive charges, predatory pricing, or coordinated or parallel pricing behavior unsupported by legitimate cost considerations.

The regulatory approach therefore appears to favor transparency and market discipline rather than direct government determination of platform prices. This distinction is important: the objective of the guideline is not to establish a uniform fee structure across platforms, whose business models and cost structures may differ substantially, but to encourage operators to be able to explain and justify how their charges operate.

What Platform Operators Should Review:

The guideline provides a useful opportunity for platform operators to conduct a broader review of their commercial arrangements with users. In particular, operators should consider whether users can easily identify every material fee applicable to them; whether the purpose and calculation method of each fee are adequately explained; whether optional services are genuinely optional in practice; whether fees for similar services overlap; and whether procedures exist for providing adequate advance notice of fee changes.

Operators should also consider whether their internal records provide a reasonable explanation for the commercial basis of material fees. This may become increasingly important where complaints regarding platform charges raise issues not only under the digital platform regulatory framework but also under consumer-protection or competition laws.

For businesses operating multiple digital services, fee governance may therefore merit treatment as a compliance function rather than simply a commercial pricing decision.

A Broader Direction in Platform Regulation:

The new guideline should also be viewed in the broader context of Thailand’s regulatory framework for digital platform services. The Royal Decree on the Operation of Digital Platform Service Businesses Subject to Prior Notification already establishes obligations intended to improve transparency and fairness in platform operations.

ETDA’s increasing use of detailed guidelines and sector-specific measures indicates a movement toward more substantive expectations concerning how platforms interact with users, rather than regulation being confined to notification requirements.

The fee guideline is formally framed as best practice. Nevertheless, voluntary regulatory guidance can influence market expectations, contractual practices, complaint handling, and the way regulators assess whether platform conduct is transparent and fair. Platform operators should therefore consider the guideline when drafting new fee structures and when reviewing existing terms and conditions.

Key Takeaways:

• ETDA has introduced a best-practice framework for transparency and fairness in digital platform fees rather than imposing price controls or statutory fee caps.
• Platform operators are encouraged to consolidate fee information, explain the purpose and calculation of charges, and enable users to understand their overall cost of using the platform.
• Changes to fees should be communicated in advance, with the guideline recommending at least 15 days’ notice.
• Fairness requires more than disclosure: duplicative charges, compulsory ancillary services, and fees that do not reasonably correspond to costs or value may raise concerns.
• Platform fee structures may also have implications under competition and consumer-protection laws.
• Even though the guideline operates as voluntary guidance, platform operators should consider incorporating its principles into their terms and conditions, pricing governance, and compliance procedures.

Author: Panisa Suwanmatajarn, Managing Partner.

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Cabinet Approves Four Draft Bills Modernizing Thailand’s Capital Market Legislation

Introduction

The Cabinet has approved four draft bills proposed by the Ministry of Finance (“MOF”) and reviewed by the Office of the Council of State (“OCS”), pursuant to the Cabinet resolution of 14 February 2023 (B.E. 2566). The bills amend:

• the Securities and Exchange Act B.E. 2535 (1992) (“SEA”);
• the Derivatives Act B.E. 2546 (2003) (“DA”);
• the Trust for Transactions in Capital Market Act B.E. 2550 (2007) (“TTA”); and
• the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018) (“DAB”).

The case for reform is that provisions across all four instruments have fallen out of step with current market conditions, do not adequately accommodate rapid technological change, are inconsistent with one another on matters of shared subject matter, and in places lack the clarity needed for consistent interpretation.

Together, the draft bills address six areas:

• Promotion of the digital capital market;
• Supervision of business operators;
• Supervision of the secondary market and related organizations;
• Fundraising and the supervision of audit firms and capital market service providers;
• Enforcement and penalties; and
• The supervisory structure.

Two bodies are principally involved in the reforms: the Securities and Exchange Commission (“SEC”), which has the power and duty to set policy for the promotion and development of the Thai capital market, and the Office of the Securities and Exchange Commission (“SEC Office”), which implements that policy on the SEC’s behalf. The amendments under each of the four draft bills are summarized below.

1. The Draft Securities and Exchange Act (No. ..) B.E. .… (“Draft SEA”)

1.1 Capital market promotion

a. Preparing, sending, receiving, and storing information and documents, and advertising, disclosing, or distributing them, by electronic means will be expressly lawful. The SEA currently contains no such provision, although the practice is already well established.

b. A prospectus may be published through means other than printing, which is currently the only channel the SEA recognizes.

c. Where certificated securities are pledged as collateral, enforcement will be available through means outside the Thai Civil and Commercial Code. Where the instrument has a stated maturity and the debt has fallen due, the pledgee may collect on the due date without prior notice.

1.2 Supervision of securities companies

a. Major shareholder approval requirements move into the Draft SEA. A person holding, or benefiting from, shares carrying more than 10 percent of total voting rights must obtain SEC Office approval. This requirement currently sits in subordinate legislation.

b. The Minister of Finance may impose conditions requiring a securities company whose license has been revoked to take steps to protect investors’ interests.

c. Securities companies must prepare financial statements for both six-month and twelve-month periods, audited and opined on by an auditor, in the form the SEC Office prescribes. Under the current SEA, only six-month statements are required.

d. Supervision of auditors and audit firms, financial advisers, property valuers, credit rating agencies, offshore service providers, securities business personnel, and other service providers will be set out in the Draft SEA itself rather than in subordinate instruments, raising the standard applied to capital market personnel.

1.3 Trading venues and the secondary market

a. Securities trading centers are classified into two categories: licensed centers, open to general investors, and registered centers, open only to institutional investors, with the level of supervision depending on the degree of investor protection required.

b. Ownership of deposited securities is clarified. A depositor must maintain a list of the owners of securities deposited with the Stock Exchange of Thailand (SET), and a person named on that list is deemed the owner entitled to the securities of the class, type, and quantity recorded. The current SEA leaves the position of depositors’ clients unclear.

c. Associations connected with the securities business may invest their funds or income in debt instruments or other securities prescribed by the SEC, subject to SEC Office supervision, giving them an additional income channel.

1.4 Auditors, service providers, and critical systems

a. Financial reports must be audited by auditors and audit firms approved by the SEC Office, and capital market service providers must obtain SEC Office approval.

b. Significant system providers to the capital market become subject to supervision, including a requirement to hold sufficient funding to support their operations and associated risks.

c. Control over management and continuity is strengthened. Such a provider may appoint a director or manager, or contract out all or part of its management authority, only with SEC Office approval. The SEC may restrain conduct capable of causing serious damage to the public interest and may address the cessation of the provider’s business.

1.5 Enforcement and penalties

a. SEC Office officials will be able to conduct investigations alongside inquiry officials and special case inquiry officials in categories of offence that may seriously damage confidence in the capital market or affect the national economy.

b. Criminal penalties and administrative fines will be revised, with criminal liability retained only for serious offences or those contrary to good morals.

1.6 The supervisory structure

a. The Secretary-General of the Office of Insurance Commission joins the SEC as an ex officio member.

b. The Minister of Finance, the SEC, and the SEC Office each gain the power to reduce or waive fees for registration and capital market services.

c. The affairs of the SEC Office are placed outside social security legislation, aligning its position with that of other regulators such as the Bank of Thailand (BOT).

2. The Draft Derivatives Act (No. ..) B.E. .… (“Draft DA”)

2.1 Capital market promotion

a. See Section 1.1(a) above.

2.2 Supervision of securities companies

a. See Section 1.2(a) above.

b. The scope and characteristics of persons acting as investment consultants, investment analysts, investment planners, derivatives investment managers, or other functions notified by the Capital Market Supervisory Board (“CMSB”) will be prescribed. Such matters were previously prescribed in subordinate legislation.

c. Provisions will be introduced on the supervision of major shareholders, directors, and persons with management authority of a derivatives exchange. A person may hold shares in, or benefit from shares of, a derivatives exchange in excess of the threshold notified by the SEC only upon obtaining SEC Office approval, in accordance with criteria, conditions, and procedures notified by the SEC. Under the current DA, shareholding is capped at 5 percent.

2.3 Auditors, service providers, and critical systems

a. Derivatives business operators — other than derivatives advisors who are natural persons (a category not previously specified) — will be required to prepare accounts showing the results of their operations and their financial position as these actually stand, in accordance with professional accounting standards under the law on accounting professions and any additional requirements notified by the SEC.

b. Derivatives business operators will be required to prepare financial statements and submit them to the SEC Office, audited and opined on by a certified public accountant in accordance with criteria notified by the SEC and approved by the SEC Office.

2.4 Enforcement and penalties

a. See Section 1.5(a) above.

b. Administrative penalties will be prescribed for a derivatives exchange that contravenes or fails to comply with criteria, orders, or conditions prescribed by law.

2.5 The supervisory structure

a. Additional powers and duties are conferred on the SEC and the SEC Office to reduce or waive fees for applications for a license, registration, or approval; for the issuance of a license, acceptance of a registration, or grant of an approval; or for carrying on a licensed, registered, or approved business, in accordance with notified criteria and conditions.

3. The Draft Trust for Transactions in Capital Market Act (No. ..) B.E. .… (“Draft TTA”)

3.1 Capital market promotion

a. See Section 1.1(a) above.

3.2 Supervision of securities companies

a. Additional powers and duties are conferred on the SEC to reduce or waive fees for applications for permission, the granting of permission, or the carrying on of business under the Draft TTA, in accordance with notified criteria and conditions.

b. Regulations, rules, notifications, orders, or requirements issued under the Draft TTA by the CMSB and having general application will take effect upon publication in the Government Gazette, whereas the current TTA applies this requirement only to instruments issued by the SEC Board and the SEC Office.

4. The Draft Emergency Decree on Digital Asset Businesses (No. ..) B.E. …. (“Draft DAB”)

4.1 Capital market promotion

a. See Section 1.1(a) above.

4.2 Enforcement and penalties

a. See Section 1.5(a) above.

4.3 The supervisory structure

a. See Section 1.6(b) above.

Legal Basis and Objectives

The four draft bills are brought forward under Section 77 of the Constitution of the Kingdom of Thailand, which provides that the State should, without delay, revise laws that are no longer suited to prevailing circumstances or that obstruct the pursuit of an occupation, so that they do not burden the people.

Beyond this constitutional duty, the stated objectives are to accommodate the use of appropriate technology in capital market transactions, to create clarity in supervision, to improve enforcement in line with international regulatory standards, to remove duplicative processes, to advance State policy and capital market plans, and to raise the level of investor protection.

Consultation and Impact Assessment

The OCS and the SEC Office consulted state agencies, the private sector, and the public on all four draft bills, through both online submissions and focus group sessions. An impact analysis was prepared in accordance with the Cabinet resolution of 19 November 2019 (B.E. 2562), and both the consultation results and the analysis have been published online.

The MOF has also submitted a plan for the subordinate legislation to be issued under the four draft bills, including the intended timeframe and a framework of key content. That subordinate legislation comprises 183 instruments.

Key Takeaways

• The Draft SEA, DA, TTA, and DAB have cleared Cabinet and Council of State review and now proceed through the parliamentary process.
• The most immediate practical change is the statutory recognition of electronic documents and non-print advertising, which brings the SEA into line with existing market practice.
• Several matters move from subordinate legislation into the acts themselves, notably approval of major shareholders in securities companies and supervision of capital market service providers.
• Two newly regulated categories of person are introduced: capital market service providers (including auditors, financial advisers, and valuers) and significant system providers to the capital market.
• Enforcement is strengthened through joint investigation powers, while criminal liability is narrowed to serious offences, with other conduct shifting to civil administrative fines.
• The MOF has flagged 183 subordinate instruments to be issued under the four draft bills, meaning enactment will mark the start rather than the end of the reform process.
• Affected businesses should assess now whether they fall within the newly regulated categories, since approval requirements, funding thresholds, and management appointment controls will apply once the draft bills are enacted.

Author: Panisa Suwanmatajarn, Managing Partner.

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Legal Update: Thailand Named in the White House Transshipment Report — Legal Exposure and the Government’s Response

Introduction

On 13 August 2026, the White House Office of Trade and Manufacturing Policy published a report entitled The Great Transshipment Scam (the “Report”). The Report identifies more than 40 jurisdictions said to present elevated risk of illegal transshipment of Chinese-origin goods into the United States and places Thailand in the second of three risk tiers.

The Thai Government responded within days, on 15 August 2026, confirmed that technical tariff negotiations with the United States would proceed at the end of August, and on 17 August 2026, the Department of Foreign Trade (“DFT”), Ministry of Commerce (“MOC”), set out the measures Thailand has taken on origin verification and its position on the underlying analysis.

The Report is not a legal instrument: it imposes no duty and creates no liability. Nonetheless, it consolidates a documented U.S. Government position that will inform enforcement targeting, trade remedy proceedings, and the negotiation of an Agreement on Reciprocal Trade (“ART”).

Thailand’s Classification under the Report

The Report groups the identified jurisdictions into three tiers. The first comprises diversified economies with large volumes of China-linked goods and comparatively strong customs systems, including Canada, the European Union, India, Israel, Japan, Mexico, South Korea, and Taiwan. The third comprises smaller economies said to offer specific weak-link advantages, such as low-cost labor, permissive free zones, or limited customs capacity.

Thailand is placed in the second tier, described as economies combining significant transshipment volumes with deep integration into China-linked supply chains, alongside Brazil, Indonesia, Malaysia, Turkey, and Vietnam. The Report characterizes Thailand, Vietnam, Malaysia, and Indonesia as major platforms for electronics, machinery, plastics, footwear, apparel, and components incorporating Chinese-origin inputs.

Thailand is named specifically in two contexts, and the two carry different legal weight.

The first is the Report’s “ugly sister city” analysis, which pairs foreign industrial corridors with U.S. regions producing the same goods, on the premise that work gained in one is work lost in the other. Thailand’s entry pairs the Ayutthaya–Samut Prakan corridor — linked to thermostats under HS 903210 — with the Minneapolis–St. Paul instruments sector. This is an inference drawn from trade statistics rather than a finding against any specific company, and the Report itself describes the pairings as illustrative. It nonetheless signals to U.S. Customs and Border Protection (“CBP”) which product code and geographic area warrant closer scrutiny.

The second reference concerns a decided case. The Report cites circumvention findings on solar cells and modules, in which the U.S. Department of Commerce determined that duties on Chinese goods were being evaded through final processing in Cambodia, Malaysia, Thailand, and Vietnam. Thailand therefore already has an enforcement record on this issue.

Thailand’s Response

According to MOC figures cited on 15 August 2026, approximately 72 percent of Thai product lines under Section 301 and Section 232 measures are already exempt, leaving roughly 28 percent still subject to the additional tariff. The exemptions span eight industry groups:

• Electronic equipment and electrical machinery;
• Machinery and components;
• Iron and steel;
• Articles of iron or steel;
• Plastics and plastic products;
• Vehicles and components;
• Copper and copper products; and
• Measuring, medical, and optical instruments.

Four of these groups fall under Section 232. As explained below, their inclusion reflects a distinction: goods in those categories are excluded from Section 301 to prevent double charging, rather than relieved of duty altogether.

Thailand is responding on three fronts.

Origin verification: The DFT has reported that the watch list operated jointly with CBP has been expanded from 49 items covering 194 tariff lines to 67 items covering 274 tariff lines, effective 1 June 2026. The DFT is developing an AI-assisted origin risk assessment system, has trained more than 2,000 operators on rules of origin and local content requirements, and has increased factory inspections, retrospective origin audits, and data linkage with the Customs Department, the Department of Industrial Works, and provincial commercial offices. The DFT and the Customs Department were scheduled to meet the Office of the United States Trade Representative (“USTR”) between 28 and 31 August 2026.

Negotiation: The Government confirmed on 15 August 2026 that technical tariff discussions would take place at the end of August, led by the Deputy Prime Minister and Minister of Commerce. It cited Thai private-sector investment in the United States of close to USD 20 billion as evidence of mutual economic interest, and denied reports that the negotiations were linked to any security or military arrangement.

The trade surplus: Thailand exports more to the United States than it imports, but at least 30 percent of those exports are produced by U.S. companies operating manufacturing bases in Thailand. On Thailand’s analysis, the bilateral surplus therefore measures the depth of a shared supply chain rather than a one-sided advantage, and cannot be read from the headline figure alone. It must instead be assessed together with investment flows, the location of production, and the broader scope of economic activity between the two countries.

Key Takeaways

• The Report places Thailand in Tier 2 of a three-tier transshipment risk classification, alongside Brazil, Indonesia, Malaysia, Turkey, and Vietnam.
• The Report is analytical rather than legal. It imposes no measure and expressly acknowledges that the trade patterns it identifies do not, by themselves, establish illegal transshipment.
• Thailand has expanded its CBP watch list to 67 items and 274 tariff lines effective 1 June 2026, is deploying AI-assisted origin risk assessment, and met with the USTR between 28 and 31 August 2026.
• Approximately 72 percent of Thai product lines under Section 301 and Section 232 are already exempt, with roughly 28 percent remaining exposed.

Author: Panisa Suwanmatajarn, Managing Partner.

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DBD Opens Consultation on Exempting Five Business Categories from Foreign Business Licensing

Introduction

The Department of Business Development (the “DBD”) has published an announcement inviting public comments on the principles of a draft Ministerial Regulation Prescribing Businesses Not Requiring a License for the Operation of Business by Foreigners, B.E. …. (the “Draft Regulation”).

The Draft Regulation would allow foreign nationals to operate five categories of business without obtaining a license under the Foreign Business Act B.E. 2542 (1999) (the “FBA”). All five categories are already supervised by a sector regulator under specific legislation, reflecting the removal of duplicate licensing rather than the liberalization of previously unregulated activity.

Background

Section 9 of the FBA requires the Foreign Business Committee (the “Committee”) to review the restricted business categories under the lists annexed to the FBA at least once a year. Following its reviews for 2024 (B.E. 2567) and 2025 (B.E. 2568), the Committee resolved to propose removing five business activities from the restricted categories. The Committee reasoned that the businesses concerned are already supervised by specific agencies under specific laws, so removing them would reduce duplication in state oversight. It also considered that the exemptions are consistent with economic development and with the readiness of Thai operators to compete; further, because certain of the activities are provided only to affiliated companies, exempting them would reduce costs and facilitate business operations without exposing Thai operators to new competition.

Consultation

The consultation itself reflects a recent procedural change. Section 5 of the Act on Legislative Drafting and Evaluation of Law B.E. 2562 (2019) requires state agencies to conduct consultation and impact analysis before enacting any law, to disclose the results, and to take them into account at every stage of the process; this requirement applies to ministerial regulations by analogy.

On 10 March 2026 (B.E. 2569), the Cabinet approved recommendations of the Law Development Commission extending the minimum consultation period from not less than 15 days to not less than 30 days, and requiring agencies to consult on the principles of a law before it is drafted, in addition to consulting on the drafted text.

The present exercise is therefore a first-stage consultation on principles. The text of the Draft Regulation has not yet been produced, and a further consultation on the drafted provisions is expected to follow.

The consultation period runs from 10 August 2026 to 30 September 2026 (B.E. 2569). Comments may be submitted through the Central Legal System website and the DBD website.

The Five Proposed Categories

1. Businesses related to, supporting, or necessary for securities or derivatives business

A foreign national conducting any of these activities must already be licensed by the Office of the Securities and Exchange Commission (the “SEC Office”) to operate a securities business under the securities and exchange law, or a derivatives business under the derivatives law, and must obtain the SEC Office’s approval before commencing the additional activity.

2. Aircraft maintenance services

This covers the maintenance of aircraft, aircraft major components, appliances, and aircraft parts under the air navigation law. The Air Navigation Act B.E. 2497 (1954) (the “ANA”) requires a repair station certificate, issued in three types corresponding respectively to aircraft, aircraft major components, and appliances and parts. The ANA prohibits operating a repair station without such a certificate and requires applicants to meet prescribed qualifications. The certificate is issued by the Director of the Civil Aviation Authority of Thailand (“CAAT”), which would become the single licensing authority for the activity.

3. Procuring customers to offer financial products of companies within a financial business group

Please see details of explanation in Item 4.

4. Debt collection services provided to companies within a financial business group

For categories 3 and 4, the foreign operator must itself be a company within a financial business group and may provide the relevant services only to other companies within that group. The term “financial business group” follows the Bank of Thailand (“BOT”) notification, which covers a commercial bank together with its parent company, subsidiaries at every tier, and joint ventures, whether domestic or foreign. Both activities constitute a supporting business, and where the group company is itself a commercial bank, they fall within the “other services” framework.

One qualification applies to debt collection: where collection is made from a debtor who is a natural person, the activity constitutes a debt collection business under the Debt Collection Act B.E. 2558 (2015) and must be registered in accordance with the criteria, methods, and conditions prescribed under that Act and its associated Ministerial Regulation.

5. Service business where a state enterprise is the counterparty

This category differs in nature from the others: it is not a new exemption but a correction to an existing one.

The business already appears in the Ministerial Regulation Prescribing Service Businesses Not Requiring a License for Foreigners (No. 3), B.E. 2560 (2017), which was issued when the applicable budget legislation was the Budget Procedure Act B.E. 2502 (1959) (the “2502 BPA”). The Budget Procedure Act B.E. 2561 (2018) (the “2561 BPA”) subsequently narrowed the definition of “state enterprise” by excluding limited companies and public limited companies in which state enterprises hold more than 50 percent of the capital. The transitional provision of the 2561 BPA, however, provides that references to “state enterprise” in pre-existing legislation continue to carry the meaning under the 2502 BPA.

As a result, the term used in the 2017 Ministerial Regulation still bears the older, wider meaning, which is inconsistent with the definition now in force. The DBD proposes to align the reference with the 2561 BPA, together with a transitional provision preserving the rights of foreign nationals already providing services to state enterprises under the former definition before the Draft Regulation takes effect.

Legal Significance

The exemption removes the requirement to obtain the FBL. However, a foreign national or entity relying on it must still obtain the licenses and approvals from the other agencies regulating such activities as follows:

• SEC Office licensing and approval for the securities-related activities;
• A CAAT repair station certificate for aircraft maintenance;
• The BOT financial business group framework for the two financial support services; and
• Registration under the Debt Collection Act where collection is made from natural persons.

The scope conditions are also narrow and should be read closely. Categories 3 and 4 are available only to a company within a financial business group serving other companies within the same group — a limitation expressly intended to confine the commercial reach of the exemption so that Thai operators are not affected. Category 1 is confined to management, marketing, human resources, and information technology services, and to a defined class of recipients.

For category 5, the practical question runs the other way. Because the definition of “state enterprise” has narrowed, some foreign operators currently serving state-enterprise subsidiaries may fall outside the exemption once the reference is updated. The proposed transitional provision is intended to address this, and its drafting will matter to those affected.

Key Takeaways

• The DBD is consulting on the principles of a Draft Regulation that would exempt five business categories from FBA licensing. The proposal remains subject to the legislative process and does not yet have legal effect.
• The proposal aims to reduce regulatory duplication in areas where specific sectoral laws and regulators already apply.
• Comments are open until 30 September 2026. This is a principles-stage consultation, and a second consultation on the drafted text is expected before the Draft Regulation is finalized.

Author: Panisa Suwanmatajarn, Managing Partner.

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Government Support for Small and Medium Enterprises (SMEs): Four New Economic Working Groups

Introduction

On 10 August 2026, Ms. Suphajee Suthumpun, Deputy Prime Minister and Minister of Commerce (“MOC”), chaired the first 2026 meeting of the Sub-Committee on the Development of Trade, Tourism and the Community Economy (the “Sub-Committee”). The Sub-Committee resolved to establish four specialized working groups tasked with restructuring the Thai economy across four dimensions:

• the creative and visitor economy;
• high-value agriculture and food security;
• the community economy and SMEs; and
• international trade.

The initiative is built on a two-tier delivery model:

• Quick Big Win (short-term): targets measurable results within 6 to 12 months, principally by reviewing and removing regulatory requirements that obstruct business. This tier is deliberately confined to measures achievable without amending primary legislation and without requiring substantial budget allocation.
• Big Win (long-term): targets structural reform over a two-to-four-year horizon to strengthen Thailand’s international competitiveness.

For businesses — particularly SMEs — the initiative carries particular significance. The MOC has identified small operators as accounting for approximately 35 percent of total national income, and the working group dedicated to the community economy and SMEs has been given an express mandate covering the entire entrepreneurial lifecycle, from business formation through to scale-up.

The initiative also places strong emphasis on regulatory and administrative reform. In particular, the Quick Big Win framework is intended to deliver practical improvements through measures that can generally be implemented without amendments to primary legislation.

The Four Working Groups

1. Creative Economy and Visitor Economy
   This group aims to extend the policy frame beyond conventional tourism to a broader visitor economy that includes those travelling to Thailand for education, business, and wellness purposes. Its work draws on Thailand’s cultural capital, identity, and visitor experience, and seeks to connect secondary cities and local communities to visitor spending.
2. Agricultural Products, Food Security, and High-Value Agriculture
   This group addresses the agricultural sector across the full value chain — upstream production, midstream processing, and downstream marketing — with the goal of moving Thai agriculture toward higher-value output, linking the sector more closely to industry and investment, and reinforcing food security.
3. Community Economy and Small and Medium Enterprises (SMEs)
   This group covers the entrepreneurial ecosystem as a whole: reducing licensing burdens, streamlining permit processes, building operator knowledge, upgrading goods and services, and promoting both scale-up and fair competition. Wholesale and retail trade is treated as a connected dimension of the same mandate. The group’s focus reflects the Government’s broader objective of improving the business environment for SMEs through practical regulatory and administrative reform.
4. International Trade
   This group focuses on promoting a more balanced import-export position, opening new markets, increasing utilization of existing free trade agreements, and responding to geopolitical pressure and non-tariff measures. It also carries the specific objectives of increasing SMEs’ share of the export structure and reducing dependency on any single market, thereby strengthening the resilience and international competitiveness of Thai businesses.

Legal and Regulatory Context

The Quick Big Win initiative is expected to be implemented through existing legal and administrative mechanisms, including:

• Facilitation of Licensing and Public Services Consideration Act B.E. 2569 (2026): streamlines licensing procedures and public service delivery through new administrative mechanisms, replacing and expanding the earlier framework under the Facilitation of Official Licensing Consideration Act B.E. 2558 (2015).
• Act on Legislative Drafting and Evaluation of Law B.E. 2562 (2019): facilitates stakeholder participation in the law-making and regulatory reform process.
• SME Promotion Act B.E. 2543 (2000): provides the institutional framework for SME development and policy coordination.

These instruments provide the legal and administrative foundation for implementing the Quick Big Win agenda, particularly in relation to licensing simplification, regulatory reform, public service efficiency, and SME development.

Key Takeaways

• The initiative underscores the strategic importance of SMEs in driving inclusive and sustainable economic growth.
• The Quick Big Win framework aims to deliver measurable regulatory and administrative improvements within 6 to 12 months, primarily through reforms that do not require legislative amendment.
• The Community Economy and SMEs Working Group has been tasked with supporting businesses throughout the entrepreneurial lifecycle — from establishment and compliance to expansion and competitiveness.
• Businesses should closely monitor developments over the next 6 to 12 months and take advantage of opportunities to raise regulatory concerns as reforms are implemented.
• Although the initiative does not create binding legal obligations, it offers an early indication of the Government’s priorities for future economic and regulatory reform.

Author: Panisa Suwanmatajarn, Managing Partner.

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Cabinet Approves Draft Ministerial Regulation Introducing Per-Item Fees for DBD Data Linkage Services

On August 7, 2026, The Deputy Government Spokesperson announced that the Cabinet of Thailand (“Cabinet”) has approved in principle a draft Ministerial Regulation Prescribing Fee Rates and Fee Exemptions for Registration, Requests for Document Inspection, Requests for Certified Copies, and Other Fees Relating to Partnerships and Limited Companies B.E. …. (“Draft Regulation”), as proposed by the Ministry of Commerce (“MOC”). The Draft Regulation has been referred to and is currently under the Office of the Council of State’s review. The Cabinet also instructed the MOC to take into account comments from the Office of the National Economic and Social Development Council regarding this Draft Regulation.

Background

Members of the public and businesses can currently verify juristic person information through a data linkage between the Department of Business Development (“DBD”) computer network and the user’s own system. Under the Ministerial Regulation Prescribing Fee Rates, Fee Reductions and Fee Exemptions Relating to Partnerships and Limited Companies B.E. 2563 (2020) (the “2563 Regulation”), a fee of THB 30 is charged per data set, with each set comprising six items:

• name of the partnership or limited company
• director information
• number and names of authorized directors
• registered capital
• head office and branch locations
• corporate objectives

The current system does not permit partial data requests: a user seeking only a single item — for example, registered capital — must nevertheless pay THB 30 for the full data set. The MOC considers this structure an unnecessary cost burden on both the public and private sectors, an obstacle to digital government development, and inconsistent with modern business practices that call for selective data access.

The Draft Regulation therefore aims to lower data-linkage service costs for juristic person verification by the public and private sectors. It also seeks to encourage corporate transactions through reliable electronic platforms, accelerate digital transformation in government, facilitate inter-agency data integration, and enable the DBD to expand its service coverage.

Key Changes

• Introduction of a per-item fee. A new fee of THB 5 per individual item will apply to company certificate data. Users may still request the complete data set at the existing rate of THB 30, while the installation fee for the data linkage program remains THB 3,000 per instance. This allows users to select and pay only for the items they require.
• Removal of the expired e-Registration discount. Clause 4 of the 2563 Regulation — which granted a 50 percent reduction on certain registration fees for partnerships and limited companies filing through the electronic juristic person registration system between 1 January 2021 and 31 December 2023 — will be deleted, as the discount period has already lapsed.

Key Takeaways

• Users of the DBD data linkage service will be able to obtain individual certificate items at THB 5 each, rather than paying THB 30 for the full six-item data set.
• For a typical two-item request, cost will fall from THB 30 to THB 10.
• The THB 3,000 installation fee and the THB 30 full-set option are retained; all other registration and document fees are unaffected.
• The Draft Regulation remains subject to review by the Office of the Council of State and is not yet in force. Businesses relying on the data linkage service should monitor the Royal Gazette for the effective date.

Author: Panisa Suwanmatajarn, Managing Partner.

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Big Data: Thailand Approves National Strategy to Accelerate AI and Data-Driven Economy

Thailand’s Cabinet has acknowledged the draft National Big Data Strategy, establishing the country’s first comprehensive policy framework for the development and use of big data as a foundation for digital government, artificial intelligence (AI), and a data-driven economy.

The strategy is intended to provide a unified direction for government agencies to improve data management, strengthen digital infrastructure, and promote the practical use of data in both the public and private sectors.

Why the strategy matters:

Although the strategy is not legislation and does not itself impose new legal obligations, it signals the Government’s long-term policy direction. Businesses operating in Thailand—particularly technology companies, cloud service providers, AI developers, healthcare providers, financial institutions, and organizations handling government-related data—should expect increased public investment and regulatory attention in data governance and AI.

The strategy also reinforces the Government’s objective of using data as a strategic national asset to improve public administration, support economic growth, and enhance Thailand’s digital competitiveness.

Key objectives:

According to the announcement, the strategy seeks to:

• establish an integrated national big data ecosystem;
• improve evidence-based policy making through better use of government data;
• support AI adoption across government and industry;
• enhance Thailand’s digital competitiveness; and
• promote responsible and systematic use of data.

The Government has also set measurable goals, including increasing the economic value generated from big data and positioning Thailand among the world’s leading countries in big data capability.

Four strategic pillars:

The strategy consists of four principal initiatives.

1. Building national data infrastructure

The Government plans to strengthen core digital infrastructure through initiatives such as:

• Government Cloud;
• Government Data Catalog; and
• National Big Data Platform.

These projects are intended to improve interoperability and enable more effective data sharing among government agencies.

2. Expanding practical use of data

The strategy encourages wider use of data analytics to address national priorities, including:

• healthcare;
• tourism;
• environmental management;
• agriculture; and
• trade and economic development.

This reflects the Government’s intention to move beyond data collection toward data-driven decision-making.

3. Accelerating AI adoption

A significant component of the strategy is the promotion of AI across the public and private sectors.

The Government intends to:

• expand AI applications in government services and industry;
• support development of Thai-language AI models; and
• establish datasets suitable for AI development.

These initiatives may create opportunities for AI developers, cloud providers, data platform operators, and businesses offering AI-enabled solutions.

4. Developing human capital

Recognizing that technology alone is insufficient, the strategy also emphasizes workforce development by increasing the number of professionals with expertise in big data and AI.

The Government aims to significantly expand the pool of skilled personnel capable of supporting Thailand’s digital transformation.

Legal and regulatory implications:

The strategy itself does not amend Thailand’s existing legal framework, including laws governing personal data protection, cybersecurity, or digital government.

Nevertheless, it indicates that future regulatory and policy initiatives are likely to focus on:

• enhanced government data governance;
• improved standards for data interoperability;
• greater integration of public-sector datasets;
• expanded use of AI in government services; and
• stronger digital infrastructure supporting government cloud and data-sharing initiatives.

Organizations participating in government projects or processing government-related data should therefore continue monitoring future implementing measures, technical standards, procurement requirements, and sector-specific regulations that may follow.

Looking ahead:

The National Big Data Strategy represents an important policy milestone in Thailand’s digital transformation agenda. While much of its implementation will depend on future projects, funding, and regulatory measures, the strategy demonstrates the Government’s commitment to treating data and AI as key drivers of economic development and public-sector modernization.

For businesses, the announcement suggests increasing opportunities in AI, cloud computing, digital infrastructure, and government technology, while reinforcing the importance of robust data governance and regulatory compliance.

Key takeaways:

• Businesses involved in AI, cloud services, digital infrastructure, and government technology should monitor future implementing regulations, technical standards, and procurement initiatives arising from the strategy.
• Thailand has adopted its first comprehensive national strategy for big data development.
• The strategy serves as a policy framework rather than creating immediate legal obligations.
• Four priorities include national data infrastructure, wider use of data analytics, AI adoption, and workforce development.
• Government investment is expected to accelerate in cloud infrastructure, data platforms, and AI ecosystems.

Author: Panisa Suwanmatajarn, Managing Partner.

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