Criteria and Conditions for Allowing Foreign Nationals to Use Automated Passport Control Channels

Background

The Immigration Bureau introduced Automated Passport Control Channels under the Order No. 322/2566 (the “Previous Order”), effective 15 December 2023, to support tourism and improve immigration processing efficiency.

However, the original framework was relatively narrow in scope, covering only a limited group of foreign nationals and restricting outbound automated processing to Suvarnabhumi Airport. To enhance accessibility and accommodate a wider range of travelers, the Immigration Bureau subsequently issued the Order No. 196/2569 (the “Current Order”), which substantially expands the scope of the Automated Passport Control System.

Immigration Bureau Order No. 196/2569

To further facilitate immigration clearance for foreign travelers, the Immigration Bureau issued the Current Order, effective on 24 August 2026. The Current Order significantly expands access to Automated Passport Control Channels by broadening eligible nationalities, visa categories, and airport checkpoints. Here is what has been changed compared to the previous order.

  1. Expanded Eligible Nationalities

The most significant change is the expansion of eligible nationalities from only Singapore and Hong Kong under the Previous Order to 33 countries and territories under the Current Order.

The expanded list now includes major business and tourism markets such as the United Kingdom, Japan, South Korea, Australia, New Zealand, Germany, France, Switzerland, Italy, the Netherlands, Sweden, Norway, Denmark, Finland, Belgium, Austria, Canada, and Singapore.

As a result, a substantially larger number of foreign travelers are now eligible to use Automated Passport Control Channels when entering and departing Thailand.

  • Expanded Visa Eligibility

The Previous Order primarily limited access to permanent residents, diplomats, government representatives, and certain designated individuals.

Under the Current Order, eligibility has been extended to holders of specified Non-Immigrant Visas as listed in its Appendix, covering a wider range of foreign nationals residing, working, studying, investing, or living with family members in Thailand.

  • Expanded Airport Access

Under the Previous Order:

  • Inbound automated channels were available only to a limited group of foreign nationals and specific type of passport holders.
  • Outbound automated channels were available only at Suvarnabhumi Airport.

Under the Current Order:

  • Eligible foreign nationals as listed in its Appendix can use automated channels for both inbound and outbound travel.
  • Access is available at any international airport equipped with the Automated Passport Control System.
  • Operational Improvements

The Current Order also introduces procedures enabling immigration officers to promptly correct minor system errors, including issues related to visa classification, period-of-stay records, and automated overstay alerts, thereby helping to reduce delays and unnecessary processing.

  • Broader Coverage of Eligible Travelers

The Current Order also broadens eligibility to include:

  • Business: employees, executives, assignees, and investors;
  • Education: teachers, researchers, and students;
  • Family: spouses, parents, children, and other qualifying family members of Thai nationals, permanent residents, and eligible foreign residents.  

It is crucial to note that each criterion is evaluated independently. Therefore, if a foreigner fits into one of the eligible groups (such as holding a qualifying visa or belonging to an eligible nationality), they will be allowed to use the automated channels

Practical Examples

  1. Long-Term Business Professionals and Expatriates Holding Non-Immigrant “B” Visas

Under the Previous Order:

  • Inbound: No access to the Automated Passport Control System was allowed; even senior executives of multinational companies and citizens of major economies such as the United States, the United Kingdom, Japan, and China. They  were required to use manual immigration counters.
  • Outbound: The Automated Passport Control System is available only at Suvarnabhumi Airport.

Under the Current Order:

  • Inbound and Outbound: It is accessible at any international airport equipped with the Automated Passport Control Channels, provided the traveler qualifies under the Appendix of the Current Order and holds a valid re-entry permit where required.
  • Short-Term Business Travelers and Tourists

Under the Previous Order:

  • Inbound: No access to the Automated Passport Control System was allowed, except for Singaporean and Hong Kong passport holders.
  • Outbound: The Automated Passport Control System is available only at Suvarnabhumi Airport.

Under the Current Order:

  • Inbound and Outbound: Eligible travelers from countries listed in the Appendix to the Current Order, including the United States, Japan, China, and the United Kingdom, can use Automated Passport Control Channels at any international airport equipped with the Automated Passport Control System.

Key Takeaways

  • Significant Expansion: Eligibility has increased from only two nationalities to 33 countries and territories under the Current Order.
  • Broader Access: Business travelers, expatriates, investors, academics, students, and family-based visa holders can now benefit from automated immigration processing.
  • Nationwide Availability: Automated outbound processing is no longer limited to Suvarnabhumi Airport, and it is now being used at any international airport equipped with the system.
  • Improved Efficiency: Immigration officers are now authorized to resolve minor system errors immediately, helping to reduce delays and unnecessary procedures.

Author: Panisa Suwanmatajarn, Managing Partner.

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Thailand Revises Visa Exemption Scheme: 30-Day Stay and Revised List of Eligible Countries

1. Introduction

The Ministry of Interior has issued notification revising Thailand’s visa exemption arrangements for foreign nationals. The revised measures repeal the special 60-day visa exemption scheme introduced in July 2024 and establish an updated list of countries and territories whose passport or travel-document holders may enter the Kingdom without a visa for tourism purposes, for a period not exceeding 30 days.

The notifications were signed on 26 August 2026 and published in the Royal Gazette on 31 August 2026, and will take effect on 15 September 2026, being 15 days after publication.

2. Background: The Previous 60-Day Visa Exemption Scheme

Under the Ministry of Interior notification dated 15 July 2024, nationals of 93 countries and territories entering Thailand for tourism, work, or short-term business purposes were exempt from visa requirements and permitted to stay for up to 60 days.

3. The Revised 30-Day Visa Exemption Scheme

3.1 Scope

  • The revised notification sets out an updated list of countries and territories eligible for visa-free entry for tourism purposes with the permitted period of stay reduced from 60 days to 30 days.
  • The revised scheme covers 60 countries and territories in total: 59 retained from the previous list, plus the Kyrgyz Republic, which has been newly added.

3.2 Retained Countries and Territories (59)

  • Asia: Bahrain, Bhutan, Brunei Darussalam, Georgia, India, Indonesia, Israel, Japan, Jordan, Kuwait, Malaysia, Maldives, Oman, Philippines, Qatar, Saudi Arabia, Singapore, Taiwan, Türkiye, and the United Arab Emirates.
  • Europe: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Ukraine, and the United Kingdom.
  • Africa: South Africa.
  • North America: Canada and the United States.
  • Oceania: Australia, Fiji, and New Zealand.

3.3 Amended Countries and Territories Covered by the Revised 15-Day Scheme (2)

  • Africa: Seychelles and Mauritius 

Seychelles is not counted as retained Country and Territory as it never been in the Scheme while the Mauritius was in 30 – Day Scheme.

In addition, the Kyrgyz Republic has been newly added to the revised list as well as Seychelles on the Revised 15 – Day Scheme. 

3.4 Countries and Territories No Longer Covered by the Revised 30-Day Scheme (34)

  • Asia: Cambodia, China, Hong Kong, Kazakhstan, Korea (ROK), Laos, Macao, Mongolia, Sri Lanka, Uzbekistan, and Vietnam.
  • Europe: Albania, Andorra, Kosovo, Monaco, Russia, and San Marino.
  • Africa:  Mauritius and Morocco.
  • North, Central America and the Caribbean: Cuba, Dominica, the Dominican Republic, Guatemala, Jamaica, Mexico, Panama,Trinidad and Tobago.
  • South America: Brazil, Colombia, Ecuador, Peru, and Uruguay.
  • Oceania: Papua New Guinea and Tonga.

These countries and territories are no longer covered by the revised 30-day visa exemption scheme. Certain nationals among them are eligible for visa-free entry under separate arrangements.

4. Key Operational Requirements Under the Revised Scheme

4.1 Purpose of Entry

Whereas the previous notification permitted eligible nationals from a broader list of countries to enter Thailand for tourism purposes for up to 60 days, the revised notification limits the privilege to a reduced number of eligible countries and shortens the permitted stay to 30 days.

4.2 Land-Border Entry Limitations

  • Visa-exempt entry through land-border immigration checkpoints for the nationals listed in Item 3.2 is limited to no more than two entries per calendar year, except for nationals of Malaysia, Brunei Darussalam, Indonesia, and Singapore, and any other countries as may be further designated by the Ministry of Interior.

5. Effect on Nationals Removed From the Previous Scheme

Once the revised measures take effect, nationals of countries and territories removed from the previous list will no longer be entitled to the former 60-day exemption and also this 30-day exemption. However, some may nonetheless remain eligible for visa-free entry under separate bilateral arrangements. The applicable entry requirements and permitted period of stay therefore depend on the specific legal basis applicable to each foreign national.

  • Required to obtain a visa prior to entry (21 from 34 countries): Albania, Andorra, Colombia, Cuba, Dominica, the Dominican Republic, Ecuador, Guatemala, Jamaica, Kosovo, Mexico, Monaco, Morocco, Panama, Papua New Guinea, San Marino, Sri Lanka, Tonga, Trinidad and Tobago, Uruguay, and Uzbekistan.
  • Covered under separate bilateral arrangements (11 countries and territories): Cambodia, China, Hong Kong, Kazakhstan, Korea (ROK), Laos, Macao, Mongolia, Russia, Vietnam, and Mauritius continue to be governed by their respective bilateral frameworks. For example, Chinese nationals continue to be eligible for visa-exempt entry under the agreement between Thailand and the People’s Republic of China on mutual visa exemption, allowing a stay of up to 30 days per entry, subject to the terms and conditions of the agreement.

6. Key Takeaways

  • The permitted period of visa-exempt stay under the general scheme has been reduced from 60 days to 30 days.
  • The number of countries and territories eligible under the general visa exemption has decreased from 93 to 60.
  • Nationals of countries removed from the list will no longer benefit from the former 60-day exemption, however, subject to any separate bilateral or country-specific arrangements.
  • The revised measures take effect on 15 September 2026. Travellers admitted before that date retain the period of stay granted under the rules in force on their date of arrival.

Author: Panisa Suwanmatajarn, Managing Partner.

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Consumer Protection: Proposed Labeling Rules for Solar Panels, Inverters and Energy-Storage Batteries

The Office of the Consumer Protection Board (OCPB) has opened a public consultation on three draft notifications of the Committee on Labels covering solar panels, inverters used with solar panels, and batteries for storing energy generated from solar panels. The consultation runs from 13–27 August 2026. Although, the notifications remain in draft form, they are an important development for manufacturers, importers, distributors, dealers, installers, and businesses supplying rooftop-solar and energy-storage systems.

The Proposed Labeling Rules:

The three draft notifications would regulate labeling requirements for the principal components of a solar-energy system: solar panels, inverters, and energy-storage batteries. The initiative follows increased regulatory attention to consumer protection in the solar sector, including concerns regarding the quality and safety of solar equipment and installations.

Designation of these products as label-controlled products is significant because labeling under the Consumer Protection Act is more than a product-branding requirement. The regulatory framework is intended to ensure that consumers receive sufficient and accurate information about the products they purchase, including information prescribed by the Committee on Labels. The precise disclosures, language requirements, and presentation requirements will ultimately depend on the final wording of each notification.

For solar products, compliance can be particularly complex because consumers frequently purchase an entire rooftop-solar or solar-plus-storage system rather than individual components. The panels, inverter, and battery may be manufactured by different companies, imported by different entities, and supplied to the consumer through a distributor or installer. As a result, businesses should consider labeling compliance across the entire supply chain rather than treating it solely as a manufacturer’s responsibility.

Key Compliance Issues for Businesses:

Manufacturers and importers should be particularly attentive to the proposals because they generally control product specifications, labels, packaging, and accompanying documentation. Imported equipment may present additional challenges where the original labels and manuals are prepared for international markets. Importers should therefore assess whether Thai-language supplementary labels will be required and whether information on those labels is consistent with the manufacturer’s original product information.

This review should extend beyond literal translation. Product names, model numbers, technical specifications, manufacturer and importer details, instructions, warnings, and other required disclosures should be consistent across the product label, packaging, manuals, technical specifications, warranties, and other customer-facing materials. Inconsistencies between these materials can create both regulatory and consumer-dispute risks.

Distributors, dealers, and installers should also monitor the proposals closely. A rooftop-solar provider may purchase panels, an inverter, and a battery from different suppliers and then offer them to the consumer as a single installed system. Businesses operating this model should consider incorporating label verification into their procurement and installation procedures, including checking that required labels are present, correspond to the correct product model, and are not removed or obscured during installation.

The proposals may therefore have consequences beyond the physical product label. Depending on the final requirements, businesses may need to review packaging, Thai-language disclosures, product specification sheets, user instructions, warranties, quotations, sales proposals, online product descriptions, and information provided by dealers and installers. Not all of these materials will necessarily constitute regulated labels, but consistency between mandatory product information and commercial representations should form part of the compliance review.

Supply-Chain Contracts and Existing Inventory:

Businesses should also review how responsibility for labeling compliance is allocated contractually. Supply, import, distribution, dealer, and installation agreements often contain general obligations to comply with applicable law but may not specifically address responsibility for preparing Thai-language labels, verifying technical information, implementing regulatory changes, or bearing the cost of relabeling noncompliant products.

For importers dealing with overseas manufacturers, this can be commercially important. Changes to factory-applied labels or packaging may require manufacturing lead times and additional costs. Agreements should therefore be reviewed to determine who must implement regulatory changes, who bears the associated costs, and what remedies apply where products supplied into the market do not satisfy mandatory labeling requirements.

Existing inventory will be another important issue when the final notifications are issued. Businesses may already hold substantial stocks of solar panels, inverters, and batteries bearing existing labels, while additional products may be in transit or subject to outstanding purchase orders. Companies should monitor the final rules for their effective dates and any transitional provisions, including whether existing inventory can continue to be sold or whether supplementary labeling will be permitted. Businesses should not assume that existing products will automatically be grandfathered.

Labeling, Product Safety, and Enforcement:

The proposed rules should also be considered alongside broader product-safety regulation. The OCPB has previously highlighted consumer concerns relating to allegedly substandard solar installations and has emphasized the importance of consumers being able to identify relevant product, manufacturer, importer, origin, and standards information.

Labeling compliance and technical compliance should therefore be managed as related but distinct requirements. A product’s compliance with an applicable industrial or technical standard does not necessarily establish compliance with consumer-labeling requirements, while a correctly labeled product may still fail to satisfy separate product-safety requirements.

Noncompliance with labeling requirements can carry criminal consequences under the Consumer Protection Act. The OCPB has stated that a seller of a label-controlled product without the required label, or with an incorrect label where the seller knows or ought to know of the noncompliance, may face imprisonment for up to six months, a fine of up to THB 100,000, or both. For manufacturers producing goods for sale and persons ordering or importing goods for sale, the potential penalty may increase to imprisonment for up to one year, a fine of up to THB 200,000, or both.

What Businesses Should Do Now:

As the notifications remain in draft form, immediate changes to product labels may be premature. However, businesses can begin preparing by identifying affected product models and collecting their current labels, packaging, manuals, and Thai-language product information. Importers should determine which labeling changes can be made locally and which would require cooperation from overseas manufacturers.

Businesses should also map responsibility throughout their distribution networks, review supply and dealer agreements, and identify existing inventory that could be affected by the new requirements. Once the final notifications are issued, particular attention should be given to the exact product scope, mandatory disclosures, Thai-language requirements, effective dates, and transitional arrangements.

Key Takeaways:

  • The OCPB is consulting on three draft labeling notifications covering solar panels, solar inverters, and batteries used for solar-energy storage.
  • The proposals are relevant to manufacturers, importers, distributors, dealers, installers, and integrated rooftop-solar and energy-storage providers.
  • Businesses should review not only physical labels but also packaging, Thai-language product information, technical documentation, sales materials, and downstream dealer practices.
  • Importers should assess whether existing global labels and packaging can satisfy the proposed requirements or whether local supplementary labeling or factory changes may be necessary.
  • Supply-chain agreements should clearly allocate responsibility and costs for labeling compliance and regulatory changes.
  • Businesses holding substantial inventory should monitor effective dates and transitional provisions carefully.
  • Companies can use the consultation period to conduct a preliminary product and labeling audit so they are prepared to implement the final requirements efficiently.

Author: Panisa Suwanmatajarn, Managing Partner.

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Integrating Cybersecurity, Fraud Response, and PDPA Compliance: Practical Implications of the Proposed Digital Channel Security Framework

The Bank of Thailand (BOT) has released a proposed Digital Channel Security framework that would strengthen expectations for authentication, fraud prevention, incident response, and the governance of digital financial services. While the proposal focuses primarily on enhancing the security and resilience of digital channels, financial institutions should not view these requirements in isolation.

In practice, a single cybersecurity incident frequently triggers multiple legal and regulatory obligations simultaneously. For example, an account takeover resulting from a phishing attack may require an institution to activate its cybersecurity incident response procedures, implement fraud mitigation measures, assess whether a personal data breach has occurred under the Personal Data Protection Act (PDPA), evaluate outsourcing or third-party service provider involvement, and make appropriate internal and regulatory notifications.

Although these obligations arise from different legal and regulatory sources, organizations may benefit from managing them through a coordinated incident response framework. This article examines the practical implications of the proposed BOT framework alongside existing obligations under the PDPA and broader operational governance practices.

From cybersecurity to operational resilience:

The proposed framework reflects an increasing regulatory emphasis on operational resilience rather than viewing cybersecurity solely as an information technology function. It places greater focus on preventing, detecting, responding to, and recovering from threats affecting digital financial services while maintaining the continuity and integrity of critical operations.

At the same time, financial institutions should recognize that cybersecurity incidents rarely occur in isolation. A single event may involve operational disruption, attempted fraud, compromise of customer credentials, unauthorized disclosure of personal data, and third-party service providers. As a practical matter, organizations may therefore benefit from adopting governance arrangements capable of addressing these interconnected risks through a unified response process.

Governance beyond information technology:

The proposed framework emphasizes that responsibility for digital channel security extends beyond information security teams.

Boards of directors and senior management are expected to establish appropriate governance, oversee digital risks, allocate adequate resources, monitor security performance, and ensure that significant incidents are escalated appropriately.

From a broader governance perspective, institutions should also consider ensuring that legal, compliance, privacy, operational risk, business continuity, and customer service functions are integrated into incident management processes. This cross-functional approach can help organizations address multiple regulatory obligations efficiently when significant incidents occur.

Fraud prevention as part of digital channel security:

The BOT proposal places significant emphasis on fraud prevention through enhanced digital channel security. Proposed measures include stronger customer authentication, monitoring of suspicious activities, behavioral analysis, device identification, protection against phishing and social engineering attacks, and mechanisms for responding to suspicious transactions.

These expectations primarily seek to reduce fraud risks affecting digital financial services. However, successful fraud attacks frequently have wider legal implications. Unauthorized access to customer accounts may also involve compromised personal data, contractual issues with service providers, customer remediation, and regulatory reporting obligations. Institutions should therefore consider integrating fraud response procedures into broader cybersecurity governance rather than treating fraud management as a separate operational function.

Incident response across multiple regulatory frameworks:

The proposed framework expects institutions to establish formal incident response procedures covering detection, escalation, containment, investigation, recovery, and post-incident review.

In practice, these procedures should also enable organizations to identify other legal and regulatory obligations that may arise from the same incident. Depending on the circumstances, an incident may require parallel consideration of fraud management, operational resilience measures, contractual obligations, outsourcing arrangements, and personal data protection requirements.

Developing coordinated response procedures may help reduce duplication of effort, improve decision-making, and ensure that regulatory obligations are addressed consistently across different functions.

Interaction with the Personal Data Protection Act:

The proposed BOT framework does not replace or modify existing obligations under the PDPA. Rather, the two regimes operate alongside one another.

Where a cybersecurity incident involves unauthorized access to, disclosure of, alteration of, or loss of personal data, organizations should assess their obligations under the PDPA independently of the BOT framework. This may include determining whether a personal data breach has occurred, evaluating notification obligations, preserving relevant evidence, documenting response measures, and implementing appropriate remediation.

Accordingly, organizations may wish to ensure that privacy officers, legal counsel, and cybersecurity teams participate jointly in incident response planning and tabletop exercises so that both operational and data protection considerations are addressed from the outset.

Third-party risk management:

Digital financial services increasingly depend on cloud service providers, payment processors, managed service providers, software vendors, and other external partners.

The proposed framework reinforces expectations regarding oversight of third-party service providers throughout the outsourcing lifecycle. Institutions should conduct appropriate due diligence, establish contractual security requirements, monitor vendor performance, and ensure that incident reporting and business continuity arrangements are clearly defined.

Because cybersecurity incidents involving third parties may also raise fraud and personal data protection issues, organizations should consider aligning vendor management processes with their broader incident response and compliance frameworks.

Documentation and evidence of compliance:

The proposed framework places considerable emphasis on governance, accountability, and demonstrating that appropriate controls are in place.

Organizations should maintain comprehensive records of cybersecurity governance, risk assessments, incident response activities, testing, training, vendor oversight, and business continuity exercises. From a broader compliance perspective, documentation should also support obligations arising under other applicable legal frameworks, including the PDPA and contractual commitments relating to outsourced services.

Maintaining complete records may facilitate regulatory engagement, internal investigations, and post-incident reviews while demonstrating that reasonable organizational and technical measures have been implemented.

Practical considerations:

As organizations prepare for the proposed framework, they may wish to assess not only technical cybersecurity controls but also how different compliance functions interact during a significant incident.

Areas for review may include:

  • governance and board oversight;
  • coordination among cybersecurity, legal, compliance, privacy, and operational teams;
  • fraud detection and response procedures;
  • customer authentication controls;
  • third-party risk management;
  • incident reporting and escalation processes;
  • documentation and recordkeeping; and
  • operational resilience testing and tabletop exercises.

An integrated approach may improve organizational readiness while reducing the risk that separate regulatory obligations are managed through disconnected processes.

Key takeaways:

  • The proposed BOT Digital Channel Security framework primarily addresses digital channel security, fraud prevention, governance, and operational resilience.
  • Existing obligations under the PDPA continue to apply independently where cybersecurity incidents involve personal data.
  • A single cyber incident may simultaneously trigger cybersecurity, fraud management, personal data protection, outsourcing, and operational governance obligations.
  • Although these obligations arise under different legal and regulatory frameworks, organizations may benefit from managing them through an integrated incident response framework.
  • Financial institutions should consider reviewing governance structures, cross-functional coordination, and documentation practices to improve operational resilience and regulatory compliance.

Author: Panisa Suwanmatajarn, Managing Partner

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Consumer Enforcement Intensifies for EV Businesses as Complaint Cases Rise and Labeling Expectations Increase

Thailand’s consumer protection regulator has signaled a more assertive enforcement approach toward the electric vehicle (EV) sector through two related developments. First, it has indicated its readiness to initiate legal proceedings on behalf of consumers in appropriate EV dispute cases. Second, it has issued new guidance consolidating labeling requirements for automobiles, electric vehicles, and used cars.

Although neither development introduces new legislation, together they demonstrate heightened regulatory scrutiny of the automotive industry and provide valuable insight into the regulator’s current enforcement priorities. Manufacturers, importers, distributors, dealers, service centers, and online vehicle marketplaces should treat these developments as an opportunity to reassess their compliance and dispute management frameworks.

Increased Enforcement Risk from EV Consumer Complaints:

The Office of the Consumer Protection Board (OCPB) has reported a significant number of consumer complaints relating to electric vehicles, with a substantial portion already progressing through legal procedures. The agency has confirmed that it has begun issuing formal demand letters in cases supported by sufficient documentation and has reiterated its statutory authority to commence legal proceedings on behalf of consumers where the legal requirements are satisfied.

This represents an important enforcement signal. Rather than merely facilitating mediation between consumers and businesses, the regulator has indicated its willingness to escalate suitable cases into formal litigation.

The risk is particularly significant where multiple complaints arise from the same product model, manufacturing issue, software defect, battery performance concern, warranty practice, or recurring after-sales service problem. A pattern of similar complaints may increase regulatory attention and expose businesses to coordinated enforcement actions, representative litigation, or broader product liability claims.

Businesses operating within the EV supply chain should therefore review whether existing complaint-handling mechanisms are capable of identifying systemic issues before they evolve into regulatory investigations or court proceedings.

Strengthened Expectations for Vehicle Label Compliance:

Separately, the OCPB has published an electronic handbook consolidating labeling requirements applicable to automobiles, electric vehicles, and used vehicles.

The publication emphasizes information that consumers commonly rely upon when making purchasing decisions, including battery specifications, driving range, testing standards, pricing information, warranty coverage, and the disclosure of material vehicle history for used vehicles.

Although the handbook itself is not legally binding, it provides a clear indication of the regulator’s compliance expectations. It reinforces that automobiles and electric vehicles remain controlled labeling products under consumer protection law and that incomplete, inaccurate, or misleading information may expose businesses to regulatory enforcement.

The guidance also illustrates that compliance extends beyond physical labels. Regulators are increasingly likely to examine whether information presented across all customer-facing channels remains accurate and consistent.

Businesses should therefore review:

  • labels displayed at dealerships and points of sale;
  • information published on corporate websites and online marketplaces;
  • brochures and sales presentations used by sales personnel;
  • representations concerning driving range and the testing methodology used, such as WLTP or NEDC;
  • battery capacity, expected degradation, warranty scope, and warranty exclusions;
  • disclosures relating to collision history, flood damage, major repairs, and battery replacement for used vehicles; and
  • consistency between information published by manufacturers, importers, dealers, and affiliated sales channels.

Claims relating to vehicle performance, battery longevity, operating costs, sustainability, resale value, or environmental benefits should be supported by appropriate technical evidence and internal documentation before publication.

Litigation Readiness and Document Preservation:

These developments also highlight the importance of litigation preparedness.

Businesses should consider establishing a centralized process for collecting and analyzing customer complaints to determine whether recurring issues indicate broader product or service risks.

At the same time, organizations should preserve relevant evidence, including:

  • sales documentation;
  • warranty records;
  • repair histories;
  • technical diagnostic reports;
  • replacement part records;
  • communications with customers;
  • call center recordings;
  • email correspondence;
  • mobile application records; and
  • connected vehicle diagnostic data.

Where disputes may reasonably be anticipated, organizations should consider implementing litigation hold procedures to reduce the risk of inadvertent deletion of potentially relevant evidence.

Companies should also review contractual risk allocation among overseas manufacturers, importers, dealers, distributors, and service centers, including indemnity provisions and responsibilities for handling product defects, recalls, warranty claims, and consumer litigation.

Data Protection Considerations:

Responding to consumer complaints frequently requires the collection and sharing of customer information, vehicle service histories, location information, and connected vehicle diagnostic data. Much of this information may constitute personal data under the Personal Data Protection Act.

Organizations should ensure that internal investigations and litigation response procedures incorporate appropriate data governance measures, including clearly defined access controls, documented processing purposes, retention periods, and secure mechanisms for sharing information with external counsel, technical experts, and other authorized parties.

Integrating consumer protection compliance with data governance can reduce both regulatory and litigation risks while supporting more effective dispute management.

Key Takeaways:

  • Organizations should strengthen complaint management, evidence preservation, document retention, contractual risk allocation, and data governance processes to prepare for increased regulatory scrutiny and potential consumer litigation.
  • The OCPB’s indication that it is prepared to commence litigation on behalf of consumers represents a significant escalation in consumer protection enforcement affecting the EV industry.
  • Businesses should not view repeated consumer complaints as isolated customer service matters but as potential regulatory and litigation risks requiring centralized oversight.
  • The newly published vehicle labeling handbook, although not legally binding, demonstrates higher regulatory expectations regarding the accuracy, completeness, and consistency of vehicle-related information across all sales channels.
  • Automotive businesses should review advertising claims, warranty disclosures, battery-related representations, and used vehicle disclosures to ensure they are fully substantiated.

Author: Panisa Suwanmatajarn, Managing Partner.

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Thailand Revises Visa Exemption Scheme: Shorter Stay Periods and a New Country-Based Category System

Introduction

On 14 July 2026, the Thai Cabinet approved a revision of Thailand’s visa exemption scheme. Under the revised framework, the current uniform 60-day visa exemption will be abolished and replaced with a country-based system that classifies eligible countries according to Thailand’s diplomatic relations and immigration risk assessment. Depending on the category assigned, eligible foreign nationals will be permitted to enter Thailand visa-free for stays of up to 30 or 15 days, or will remain eligible for a Visa on Arrival.

Background

In 2024, Thailand introduced a 60-day visa exemption for nationals of 93 countries and territories to stimulate tourism and support the country’s economic recovery following the COVID-19 pandemic. Since implementation, however, the government has identified several concerns associated with the scheme, including visa runs, illegal employment, nominee business arrangements, transnational crime, and visa overstays. In response, the government resolved to review and revise the existing visa exemption policy.

Key Changes

1. Introduction of a Tiered Visa Exemption Framework

30-Day Visa Exemption (59 Countries and Territories)

Nationals of 59 countries and territories will be eligible for visa-free entry for tourism purposes for stays of up to 30 days. The revised scheme extends this 30-day entitlement to six countries that were not previously covered:

  • India
  • Croatia
  • Bulgaria
  • Cyprus
  • Malta
  • Maldives

With these additions, all 27 European Union Member States will receive the same 30-day visa exemption entitlement, promoting greater consistency across Thailand’s visa policy. The government expects this measure to strengthen diplomatic relations, support future discussions on Schengen visa exemptions for Thai nationals, and facilitate continued economic and trade cooperation with partner countries.

15-Day Visa Exemption (2 Countries)                                                                                                                                                                            

Nationals of Mauritius and Seychelles will be eligible for visa-free entry for stays of up to 15 days. The government intends to periodically review this entitlement based on tourism statistics and visitor spending patterns.

Visa on Arrival (3 Countries)

Nationals of the following three countries will remain eligible to obtain a Visa on Arrival at Thailand’s immigration checkpoints:

  • Azerbaijan
  • Belarus
  • Serbia

2. Implementation of the “One Country, One Entitlement” Policy

Under the revised framework, each country will be eligible for only one immigration privilege, and overlapping schemes will be eliminated. For example, India will no longer be eligible for a Visa on Arrival, as it has instead been granted 30-day visa exemption status.

3. Enhanced Border Screening

The government will strengthen the Thailand Digital Arrival Card (TDAC) system by integrating it with relevant government databases, improving immigration risk assessment, border screening, and monitoring of visa exemption usage.

The Cabinet resolution provides for a revised visa framework covering a reported total of 65 countries and territories across the categories described above. The complete list of eligible countries and territories in each category has not yet been officially published; further detail is expected in forthcoming Ministry of Interior notifications and related subordinate legislation.

Effective Date

The revised measures have not yet entered into force. They will take effect 15 days after the relevant Ministry of Interior notifications are published in the Royal Gazette. Until that time, the existing immigration rules remain in effect, and foreign nationals who enter Thailand before the change takes effect will be permitted to remain for the duration of their existing permitted stay.

Key Takeaways

  • The revised measures are pending implementation and will take effect 15 days after publication in the Royal Gazette.
  • Thailand will replace its uniform 60-day visa exemption scheme with a tiered, country-based system.
  • The revised scheme aims to balance tourism promotion and ease of international travel against the prevention of visa abuse and the strengthening of immigration control and national security.
  • Eligible countries will receive 30-day or 15-day visa-free entry, while three countries retain Visa on Arrival status; overlapping privileges are removed under the “one country, one entitlement” policy.
  • The TDAC system will be enhanced to strengthen immigration screening and monitoring.

Author: Panisa Suwanmatajarn, Managing Partner.

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New Apostille Rules Simplify Thailand Working and Retirement Visa Renewal Documents Requirement

The Immigration Bureau has issued Immigration Bureau Order No. 122/2026 (the “Order”), amending certain documentary requirements under Immigration Bureau Order No. 12/2025 for applications for renewal of visa. The Order came into effect on 28 May 2026.

Previously, where certain prescribed documents were unavailable, applicants were generally required to authenticate them through notarization by a notary public, legalization by a Royal Thai Embassy or Royal Thai Consulate-General, and super-legalization by Thailand’s Ministry of Foreign Affairs. The new Order introduces Apostille certification as an alternative method of authentication for specified documents.

Key Amendments

The amendments primarily benefit foreign nationals applying for the renewal of Non-Immigrant “B” (Business) and Non-Immigrant “O-A” (Retirement) categories. In particular, the changes are expected to benefit foreign nationals working for foreign companies operating in Thailand through their representative offices, regional offices, and branch offices set up in Thailand requiring renewal of their visa, for which the affidavits or certificates of incorporation relating to those offices are required to be submitted. The amendment also benefits foreign retirees required to submit health insurance documents or evidence of state welfare benefits issued or granted overseas.

Previously, such documents were generally required to be certified by the issuing authority and/or notarized, followed by legalization by a Royal Thai Embassy or Royal Thai Consulate-General and super-legalization by Thailand’s Ministry of Foreign Affairs. The amendment streamlines this process by reducing the number of authentication steps required for eligible documents.

The amendments also address practical difficulties faced by representative offices, regional offices, and branch offices of foreign companies in obtaining certain corporate registration documents. In practice, the Department of Business Development (DBD) may not issue particular certificates in certain circumstances The revised requirements therefore provide greater flexibility where equivalent DBD-issued documents are unavailable.

Conclusion

The Order represents a practical modernization of Thailand’s immigration procedures by introducing Apostille certification as an alternative method of authenticating documents for certain business and retirement-based applications.

Although the amendments do not alter the substantive eligibility requirements of renewal of visa, they simplify documentary compliance, reduce reliance on multiple layers of consular legalization, and offer practical solutions for foreign business entities that may encounter difficulties obtaining certain certifications in Thailand. Overall, the changes are expected to make the immigration process more efficient for both foreign businesses and foreign retirees.

Key Takeaways

The changes reflect Thailand’s continuing movement toward

Apostille certification is now recognized as an alternative to traditional embassy legalization for certain business and retirement-based extension of stay applications.

The amendments simplify document authentication and reduce administrative burdens for eligible applicants.

Foreign nationals working with representative offices, regional offices, and branch offices in Thailand may benefit from greater flexibility where equivalent DBD-issued certifications are unavailable.

Author: Panisa Suwanmatajarn, Managing Partner.

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Billing Software and Electronic Invoicing: Understanding Thailand’s Digital Tax Compliance Framework

Executive Summary:

As governments continue to digitalize tax administration, businesses are increasingly expected to adopt electronic invoicing solutions that comply with evolving regulatory requirements. Although the terms billing software and electronic invoicing are often used interchangeably, they represent distinct concepts that serve different commercial and legal functions.

In Thailand, billing software is not subject to a dedicated statutory or regulatory framework. Businesses are generally free to select accounting, billing, or enterprise resource planning (ERP) systems that best support their commercial operations, provided they comply with the Revenue Code and other applicable laws. Electronic invoicing, by contrast, is governed by the Revenue Department’s e-Tax Invoice & e-Receipt framework, which establishes the legal and technical requirements for issuing electronic tax invoices recognized for VAT purposes.

Understanding the distinction between these concepts is important for businesses implementing digital invoicing solutions. A billing system that efficiently generates commercial invoices does not necessarily satisfy the legal requirements for issuing electronic tax invoices. Businesses should therefore evaluate their invoicing systems not only from an operational perspective but also from a tax compliance standpoint.

Introduction:

Digital transformation has fundamentally changed the way businesses prepare invoices, maintain accounting records, and comply with tax obligations. Around the world, tax authorities have introduced electronic invoicing regimes to improve tax compliance, enhance transparency, and reduce administrative burdens for both taxpayers and regulators.

Although electronic invoicing has become an increasingly common feature of modern tax systems, countries have adopted different regulatory approaches. Some jurisdictions regulate the software used to generate invoices, while others focus on the legal validity and technical characteristics of the electronic tax documents themselves.

Thailand follows the latter approach. Rather than regulating billing software as a separate category of software, Thai law establishes a framework governing the issuance of electronic tax invoices through the Revenue Department’s e-Tax Invoice & e-Receipt system. Consequently, businesses remain free to use their preferred accounting or ERP software, provided that the electronic tax documents generated by those systems comply with the applicable legal and technical requirements.

For businesses operating in Thailand, particularly multinational enterprises implementing global ERP platforms, understanding the distinction between billing software and electronic invoicing is essential. While both are integral components of modern financial management, they perform different functions and are subject to different legal considerations.

Billing Software:

Billing software generally refers to applications used by businesses to prepare invoices, calculate taxes, record payments, manage customer accounts, and maintain accounting records. These functions support day-to-day commercial operations and are commonly integrated into accounting software or ERP systems.

Unlike some jurisdictions that regulate invoicing software, Thailand does not currently impose a dedicated legal or regulatory regime governing billing software itself. There is no statutory requirement for billing software to be licensed, certified, or approved by the Revenue Department before it can be used by businesses. Instead, Thai law focuses on the legal sufficiency of the invoices and accounting records generated by the software.

This does not mean that businesses have complete discretion in how billing systems are used. Regardless of the software selected, businesses remain responsible for ensuring that invoices comply with the Revenue Code, VAT is correctly calculated where applicable, accounting records are properly maintained, and supporting documentation is available for inspection by the tax authorities.

Accordingly, compliance under Thai law depends not on the software itself, but on whether the business uses that software in a manner that satisfies its statutory obligations. A business may therefore choose from a wide range of commercial accounting platforms, cloud-based invoicing applications, or ERP systems without obtaining prior approval from the Revenue Department.

Electronic Invoicing:

Electronic invoicing serves a different purpose. Rather than facilitating internal billing processes, it establishes the legal framework under which electronic tax invoices are recognized for VAT purposes.

Thailand’s electronic invoicing regime is principally governed by the Revenue Code, supplemented by the Electronic Transactions Act, Ministerial Regulation No. 384, and Revenue Department notifications prescribing the technical standards for electronic tax documents. Collectively, these instruments enable tax invoices and receipts to be created, transmitted, and retained electronically while ensuring their authenticity, integrity, and reliability.

Businesses wishing to issue electronic tax invoices under the Revenue Department’s e-Tax Invoice & e-Receipt framework must comply with prescribed legal and technical requirements. These include registration with the Revenue Department, generation of electronic tax documents in the prescribed format, use of appropriate electronic authentication mechanisms, transmission through approved channels where applicable, and maintenance of electronic records in accordance with the Revenue Department’s requirements.

An important characteristic of the Thai framework is that it regulates the electronic tax document rather than the accounting software used to produce it. Consequently, businesses may continue using their existing accounting or ERP systems, provided those systems are capable of generating electronic tax invoices that comply with the Revenue Department’s technical specifications. In practice, many businesses achieve this through system localization or integration with specialized e-Tax solutions or authorized service providers.

Thailand currently provides two principal electronic invoicing models. The e-Tax Invoice & e-Receipt system is designed for businesses requiring full electronic integration, while the e-Tax Invoice by Email system provides a simplified alternative for eligible businesses. Although both systems enable businesses to issue legally recognized electronic tax invoices, they differ in their technical implementation and authentication methods.

Key Takeaways:

  • Thailand does not regulate billing software as a separate legal category or require billing software to be certified or approved by the Revenue Department.
  • The Revenue Department’s e-Tax Invoice & e-Receipt framework governs the issuance of legally recognized electronic tax invoices and establishes the applicable technical and procedural requirements.
  • A commercial invoice generated by billing software does not automatically constitute an electronic tax invoice for VAT purposes.
  • Businesses implementing accounting or ERP systems should evaluate both operational functionality and compliance with Thailand’s e-Tax requirements.
  • Early coordination among finance, tax, legal, and information technology functions can help ensure a successful implementation of electronic invoicing while supporting long-term digital tax compliance.

Author: Panisa Suwanmatajarn, Managing Partner.

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Thailand’s Draft Immigration Act and Hotel Act: A Major Step Towards Digitalization and Regulatory Reform

Background

Thailand is taking another significant step in its regulatory reform agenda through proposed amendments to the Immigration Act, B.E. 2522 (1979), and the Hotel Act, B.E. 2547 (2004). The draft legislation forms part of the government’s broader Regulatory Guillotine initiative, which seeks to eliminate unnecessary legal requirements, simplify administrative procedures, and reduce compliance burdens for both businesses and the public.

The proposed amendments are also intended to enhance Thailand’s competitiveness by creating a more foreigner-friendly regulatory environment that encourages investment, facilitates tourism, and supports economic growth. At the same time, the reforms modernize enforcement by replacing criminal fines for minor regulatory violations with administrative (disciplinary) fines, consistent with Section 77 of the Constitution of the Kingdom of Thailand.

1. Draft Immigration Act (No. ..), B.E. ….

1.1 Modernization of Administrative Structure

Draft Sections 3 and 4 update the terminology used throughout the Immigration Act to reflect the current organizational structure of the Royal Thai Police. The definition of “Director-General” is repealed, and all references to the “Director-General” are replaced with “Commissioner-General of the Royal Thai Police.” In addition, the term “Immigration Division” is updated to “Immigration Bureau.”

1.2 Removal of Outdated and Redundant Reporting Requirements

One of the most significant reforms is the reduction of reporting obligations imposed on foreign nationals.

Under Draft Section 5, which amends Section 37 of the Immigration Act:

  • Section 37(1) is repealed, removing the prohibition on temporary residents engaging in employment. Because employment of foreigners is already governed by the Foreign Business Act, B.E. 2542 (1999), and the Emergency Decree on the Management of Foreign Workers, B.E. 2560 (2017), this provision is considered redundant.
  • Section 37(2) is repealed, abolishing the requirement for foreigners to notify immigration officials of their place of residence. This obligation duplicates the TM30 reporting requirement already imposed on property owners, possessors, and hotel operators.
  • Sections 37(3) and 37(4) are repealed, eliminating the requirements to report changes of residence and temporary travel to another province exceeding 24 hours. These obligations had already been exempted in practice under the Royal Thai Police Regulations B.E. 2563 (2020).
  • Section 37(5) is retained, preserving the existing 90-day reporting requirement for long-term foreign residents. However, the Commissioner-General of the Royal Thai Police will be empowered to prescribe more flexible reporting methods, procedures, and timeframes.

1.3 Elimination of Duplicate Hotel Reporting

Draft Section 6 repeals Section 38 of the Immigration Act, removing the requirement for hotel operators to submit duplicate reports to immigration authorities. Hotel managers will instead report guest information solely under the Hotel Act, through a single, unified reporting mechanism.

1.4 Flexible Permanent Residence Quotas

Draft Section 7 repeals Section 40 of the Immigration Act, removing the existing statutory quota of 100 permanent residence approvals per nationality and 50 approvals for stateless persons each year. Annual quotas will instead be determined by the government based on Thailand’s prevailing economic and social circumstances.

1.5 Reform of Penalties

Draft Sections 8 and 9 repeal Sections 75, 76, and 77 of the Immigration Act, replacing criminal penalties for minor reporting violations with administrative (disciplinary) fines. This amendment reflects the policy set out in Section 77 of the Constitution, under which criminal sanctions are reserved for serious misconduct.

1.6 Transitional Provisions

Draft Section 10 provides that existing procedures relating to residence reporting, address notifications, and permanent residence applications will remain in effect for a transitional period of up to one year after the Draft Act comes into force.

1.7 Administration of the Act

Draft Section 11 designates the responsible Minister to oversee implementation and ensure continuity throughout the transition period.

2. Draft Hotel Act (No. ..), B.E. ….

2.1 Alignment of Definitions

Draft Section 3 introduces the definition of “Foreigner” into the Hotel Act, adopting the same meaning as under the Immigration Act to ensure consistency between the two statutes.

2.2 Digitalization of Hotel Guest Registration

Draft Section 4, which repeals and replaces Sections 35 and 36 of the Hotel Act, modernizes hotel guest registration by requiring hotel managers to maintain guest records electronically.

Hotel managers will be required to collect only the information necessary for regulatory purposes and to submit guest registration data electronically to the Registrar every 24 hours. The Registrar will then automatically transmit information relating to foreign guests to the Immigration Bureau, establishing a single-window reporting mechanism.

The amendment also authorizes the Department of Provincial Administration (DOPA) and the Registrar to compile and disclose guest registration information to other government agencies, where such disclosure is authorized by law and serves a legitimate public purpose.

In addition, Draft Section 9 requires DOPA to establish and maintain the electronic registration platform.

2.3 Transition to Paperless Administration

Draft Section 5 repeals Section 37 of the Hotel Act, eliminating the requirement for hotel operators to obtain replacement paper registers where records have been lost or destroyed. This amendment supports the transition to a fully electronic registration system.

2.4 Reform of Penalties

Draft Sections 7 and 8 amend the penalty provisions by replacing criminal sanctions with administrative (disciplinary) fines for violations of Sections 35 and 36. Part 2 of the Act is also renamed to reflect the revised enforcement framework.

2.5 Transitional Provisions

Draft Sections 10 and 11 permit hotels to continue using existing registration methods and forms, including the traditional Ro.Ro. 4 register, until the new electronic system and prescribed digital forms become fully operational.

2.6 Entry into Force

The responsible Minister will oversee implementation throughout the transitional period. The Draft Act will enter into force 30 days after its publication in the Royal Gazette.

Conclusion

The Draft Immigration Act and the Draft Hotel Act together represent a significant milestone in Thailand’s regulatory reform agenda. By eliminating overlapped requirements, introducing integrated digital administration, and replacing criminal penalties with proportionate regulatory fines, the proposed legislation seeks to create a more efficient legal framework while maintaining effective immigration control.

If enacted, these reforms are expected to reduce compliance costs for businesses, simplify immigration procedures for foreign nationals, improve inter-agency coordination, and strengthen Thailand’s attractiveness as a destination for international investors, skilled professionals, and tourists.

Author: Panisa Suwanmatajarn, Managing Partner.

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National Semiconductor Policy Committee Signals New Opportunities and Legal Considerations for High-Tech Investment

The Thai Government has recently emphasized the establishment of a National Semiconductor Policy Committee as a key mechanism to advance the country’s semiconductor ecosystem. The initiative reflects a broader industrial strategy aimed at positioning the country as a regional hub for advanced manufacturing and digital infrastructure, while supporting growth in artificial intelligence (AI), data centers, automation, electric vehicles (EVs), medical devices, and advanced electronics.

While further policy details and implementing measures are expected to emerge, the announcement sends an important signal to investors, technology companies, manufacturers, and research institutions regarding the Government’s long-term commitment to the semiconductor sector.

Strategic Importance of the Semiconductor Initiative:

Semiconductors are foundational technologies that support virtually all modern industries, from consumer electronics and telecommunications to automotive systems, healthcare technologies, and AI applications. As geopolitical tensions and supply-chain disruptions have prompted many countries to diversify semiconductor production and sourcing, governments across Asia have intensified efforts to attract semiconductor-related investments.

The establishment of a dedicated policy committee suggests that the Government intends to coordinate national efforts across multiple ministries and agencies, including investment promotion, infrastructure development, workforce training, research and development (R&D), and international partnerships.

The policy direction is also consistent with broader economic objectives aimed at moving up the value chain and attracting investments in high-value, technology-intensive industries.

Potential Impact on Investment Promotion:

One of the most immediate implications may involve the expansion or refinement of investment promotion measures administered by the Board of Investment (BOI).

Companies engaged in semiconductor manufacturing, integrated circuit design, wafer fabrication, assembly and testing, advanced packaging, electronic component production, and supporting services may benefit from enhanced incentives as the Government seeks to accelerate industry development.

Potential areas of focus may include:

  • Corporate income tax exemptions and reductions;
  • Import duty exemptions for machinery and raw materials;
  • Incentives for R&D activities;
  • Incentives linked to workforce development and technology transfer;
  • Facilitation of foreign investment and skilled personnel mobility; and
  • Support measures for strategic supply-chain investments.

Investors considering semiconductor-related projects should monitor future BOI announcements and sector-specific incentive packages that may emerge from the Committee’s policy recommendations.

Foreign Investment Structuring Considerations:

The semiconductor industry frequently involves cross-border investment structures, multinational operations, and strategic collaborations among technology developers, manufacturers, and research institutions.

Foreign investors entering the sector should carefully evaluate:

  • Foreign ownership restrictions under applicable laws;
  • BOI-promoted structures and associated privileges;
  • Land ownership and industrial estate considerations;
  • Cross-border service and licensing arrangements;
  • Transfer pricing implications; and
  • Regulatory approvals applicable to strategic technologies and infrastructure projects.

As semiconductor investments often involve significant capital expenditure and long-term commitments, early legal and regulatory planning will be critical to maximizing available incentives and ensuring compliance.

Technology Transfer and Intellectual Property Issues:

Technology transfer is expected to be a central component of any national semiconductor strategy.

Foreign technology providers and local partners will need to carefully structure arrangements relating to:

  • Patent licensing;
  • Trade secret protection;
  • Know-how transfer;
  • Joint development projects;
  • Employee invention ownership;
  • Confidentiality obligations; and
  • Post-termination use of technology.

Given the highly sensitive nature of semiconductor manufacturing processes and design technologies, robust intellectual property protection mechanisms will be essential. Companies should review existing IP portfolios and ensure that contractual arrangements clearly allocate ownership rights, usage rights, and commercialization rights.

Particular attention should be paid to the treatment of improvements and derivative technologies developed through local operations or collaborative R&D projects.

Growing Importance of Research and Development Collaboration:

The Government’s emphasis on workforce development and innovation suggests increased collaboration among industry participants, universities, research institutions, and public agencies.

Such collaborations may create opportunities for:

  • Joint R&D projects;
  • Government-supported innovation programs;
  • Academic-industry partnerships;
  • Research grants and funding mechanisms; and
  • Talent development initiatives.

However, collaborative arrangements often raise complex issues concerning intellectual property ownership, publication rights, confidentiality obligations, commercialization rights, and dispute resolution mechanisms.

Clear contractual frameworks should therefore be established at the outset of any collaborative project.

Supply Chain Compliance and Due Diligence:

As semiconductor supply chains become increasingly globalized and subject to heightened scrutiny, companies participating in the sector may face expanded compliance obligations.

Areas requiring attention may include:

  • Supply-chain transparency;
  • Export control regulations;
  • Sanctions compliance;
  • Cybersecurity requirements;
  • Data governance obligations;
  • ESG and sustainability standards; and
  • Supplier due diligence processes.

Businesses supplying multinational semiconductor manufacturers may encounter contractual requirements relating to responsible sourcing, cybersecurity controls, and environmental compliance.

Companies seeking integration into global semiconductor supply chains should assess whether their existing compliance programs meet the expectations of international customers and regulators.

Linkages with AI, Data Centers, EVs, and Advanced Electronics:

The Government has expressly linked semiconductor policy to broader strategic sectors including AI, data centers, automation, EVs, medical devices, and advanced electronics.

This interconnected approach may create opportunities beyond traditional semiconductor manufacturing. Companies involved in AI infrastructure, cloud computing, digital services, robotics, automotive electronics, battery technologies, and medical technology may also benefit indirectly from policies designed to strengthen the semiconductor ecosystem.

The result could be a more integrated technology cluster that attracts both upstream and downstream investment activities.

Looking Ahead:

The establishment of the National Semiconductor Policy Committee represents a significant policy signal regarding the Government’s industrial priorities and ambition to strengthen participation in global technology value chains.

While detailed implementation measures remain to be developed, the initiative is likely to influence future investment promotion policies, R&D support programs, infrastructure planning, workforce development initiatives, and international technology partnerships.

Businesses considering investments in semiconductor-related activities should closely monitor forthcoming regulatory developments and assess how evolving policies may affect their investment structures, intellectual property strategies, technology transfer arrangements, and compliance frameworks.

Key Takeaways:

  • Collaboration among industry, universities, and research institutions is likely to increase, making clear contractual allocation of intellectual property rights essential.
  • The National Semiconductor Policy Committee signals a coordinated national strategy to develop the semiconductor ecosystem and strengthen participation in global supply chains.
  • Semiconductor policy is expected to support broader growth in AI, data centers, EVs, medical devices, automation, and advanced electronics.
  • New or enhanced BOI incentives may emerge for semiconductor manufacturing, design, R&D, and supporting activities.
  • Foreign investors should review investment structures, regulatory requirements, and available promotion mechanisms at an early stage.
  • Technology transfer, trade secret protection, patent licensing, and ownership of R&D outcomes will become increasingly important legal considerations.
  • Companies seeking participation in semiconductor supply chains should strengthen compliance programs covering export controls, cybersecurity, ESG requirements, and supply-chain due diligence.

Author: Panisa Suwanmatajarn, Managing Partner.

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