Thai Cabinet Acknowledges Delay in Issuing Integrated Ticketing Regulations

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skytrain on railway tracks

Thai Cabinet Acknowledges Delay in Issuing Integrated Ticketing Regulations

On 20 October 2026, the Thai Cabinet acknowledged the explanation of the Ministry of Transport (the “MOT”) for its delay in issuing subordinate legislation under the Integrated Ticketing System Management Act B.E. 2568 (2025) (the “Act”). The MOT attributed the delay to extended public consultation requirements and additional discussions with transport operators, which prevented it from meeting the statutory deadline of 25 June 2026. Although the subordinate legislation has not yet been issued, the MOT has completed drafting all 20 instruments of subordinate legislation and expects to issue them by the end of 2026.

Background

The Act came into force on 28 December 2025. It establishes a legal framework for an integrated ticketing system that allows passengers to use a single ticket or payment method across different modes of public transportation, including electric trains, buses, conventional trains and boats. By simplifying travel and supporting more affordable fares, the Act aims to encourage greater use of public transportation, reduce traffic congestion and lessen environmental impact.

The Act establishes a regulatory framework covering the following key matters:

  • Integrated ticketing and fares: The Act provides for an integrated ticketing system and authorizes the MOT to prescribe integrated fare rates, which government agencies must use as the basis for future public transport concession agreements.
  • Regulatory oversight: The Act creates the Integrated Ticketing System Policy Committee, which determines policies, technological standards and principles for calculating integrated fares.
  • Licensing requirements: Operators of central revenue management centers, fare card issuance services and integrated ticketing services must obtain licenses from the Minister of Transport.
  • Financial support: The Act creates the Integrated Ticketing System Promotion Fund to support the development and operation of the system, including through loans to eligible private operators. Operators seeking financial support must hold the licenses required under the Act.
  • Mandatory participation: Certain public transport services may be designated by Royal Decree as required to participate in the integrated ticketing system and to comply with the applicable licensing requirements.
  • Enforcement and penalties: The Act imposes monetary penalties for certain violations by licensed operators and criminal penalties for unauthorized operations and other offenses.

While the Act sets out the overall regulatory framework, detailed requirements on fare structures, licensing procedures and operational standards must be prescribed through subordinate legislations. To ensure timely implementation, Section 53 of the Act requires that such legislation be issued within 180 days from the effective date of the Act, or by 25 June 2026. If the MOT cannot meet this deadline, it must report the reasons for the delay to the Cabinet for acknowledgment.

Reasons for the Delay

As the statutory deadline was not met, the MOT reported the following two reasons for the delay to the Cabinet in accordance with Section 53 of the Act.

1. Extended public consultation requirements

Under the revised public consultation guidelines issued in 2026 pursuant to the Act on Legislative Drafting and Evaluation of Law B.E. 2562 (2019), the minimum online public consultation period was extended from 15 to 30 days. The guidelines also require consultation at two stages: (i) when the key principles of the legislation are proposed and (ii) after the draft legislation has been prepared. These additional requirements extended the drafting process beyond the original schedule.

2. Additional consultations with transport operators

The proposed subordinate legislation directly affects fare collection and revenue allocation among different public transport operators. The MOT therefore needed additional time to consult relevant operators and stakeholders on technical and operational matters, to ensure that the proposed requirements are practical and can be implemented effectively.

Current Status and Next Steps

The MOT also reported that it has completed drafting all 20 instruments of subordinate legislation, although none have yet been issued. The drafts cover licensing, operational and technological standards, integrated fares, revenue management, fund administration, reporting obligations, license transfers, service suspension or termination, and enforcement measures. The MOT expects to issue all 20 instruments by the end of 2026.

Key Takeaways

  • Although the Act is already in force, its full implementation depends on the issuance of subordinate legislation governing integrated fares, licensing and system operations.
  • The missed statutory deadline does not affect the legal validity of the Act, and the MOT remains responsible for issuing the required subordinate legislation.
  • With all 20 drafts completed and issuance expected by the end of 2026, public transport operators and related businesses should monitor regulatory developments and prepare for potential operational and compliance requirements.

Author: Panisa Suwanmatajarn, Managing Partner.

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