Tag: E-Commerce

on by

Thailand Implements Comprehensive Regulations for Cash-on-Delivery (COD) Services to Enhance Consumer Protection

Thailand’s Committee of the Consumer Protection Board (CCPB) has taken a significant step towards regulating Cash-on-Delivery (COD) services by classifying them as a controlled business. This move comes in response to the growing popularity of online services and various payment methods in Thailand, as well as the need to address issues such as fraud and inadequate security measures associated with COD transactions.

Following our previous articles on the ETDA’s Recommendation for an Online Merchant Management System with Cash on Delivery Service, the new regulations, set to take effect on October 3, 2024, establish comprehensive requirements for COD service providers, with a focus on enhancing transparency and protecting consumer rights. These rules build upon previous recommendations by the Electronic Transactions Development Agency (ETDA) for an Online Merchant Management System with Cash on Delivery Service.

Receipt Requirements for Cash-on-Delivery (COD) Payments:

Under the new regulations, COD service providers must issue detailed receipts that meet specific criteria:

  • Language and Readability:
    • The receipt must be in Thai.
    • The text must be clear and legible, with a font size no smaller than 2 millimeters and no more than 11 characters per inch.
  • Details to Include:
    • Provider and Service Provider Information:
      • Full name, address, telephone number, and email of both the provider and the service provider.
      Product Information:
      • Tracking number.Detailed description of the product.Amount charged for the product.Pick-up location details.Service provider’s information.Customer information.Authorized name on the invoice.Time limit for holding the payment (5 days before transferring to the provider).Time limit for returning the product.
    • Receipt Preparation:
      • The receipt must be issued immediately upon receiving payment from the customer.
  • Customer Rights to Refund:
    • Reasons for Refund:
      • If the customer receives a product they did not order, or if the product is damaged.If the customer receives a product they did not order and was charged for it, with proof that the product was not ordered.If the customer inspects the product upon delivery, using photos or videos as evidence, and finds it does not match the order.If the customer cannot receive the product at the time of delivery, discovers it was not ordered, and informs the service provider, they can refuse the product and request a refund.
    • Refund Processing:
      • The process for issuing refunds should be briefly described, outlining the necessary steps.
  • Prohibited Clauses:
    • The receipt must not include:
      • Clauses that exclude or limit the liability of the provider or service provider for issues with the product.
      • Clauses that deny responsibility or prohibit returns or exchanges if the product is incorrect, damaged, or defective.
      • Clauses stating that refunds will not be provided.

    These detailed requirements aim to ensure that consumers are fully informed about their purchases and their rights when using COD services. The regulations address the entire transaction process, from the initial order to potential refunds, providing a comprehensive framework for consumer protection.

    The new rules also establish a holding period for payments, requiring service providers to retain the payment for five days before transferring it to the product provider. This window allows customers time to report any issues with their order and request a refund if necessary.

    By implementing these regulations, the Thai government aims to create a more secure and transparent environment for online transactions, benefiting both consumers and businesses operating in this space. The detailed receipt requirements and clear refund policies should help reduce disputes and provide a standardized approach to handling COD transactions.

    As the October 3, 2024 implementation date approaches, businesses offering COD services in Thailand will need to ensure their practices align with these new requirements. This may involve updating their receipt systems, revising their refund policies, and training staff on the new procedures.

    The introduction of these comprehensive regulations demonstrates Thailand’s commitment to adapting its consumer protection laws to the evolving digital economy. As e-commerce continues to grow, such measures will be crucial in maintaining consumer trust and fostering a healthy online marketplace. These regulations set a new standard for COD services in Thailand, potentially serving as a model for other countries facing similar challenges in regulating online transactions.

    Key Takeaways:

    1. Thailand’s Committee of the Consumer Protection Board (CCPB) has announced new regulations for Cash-on-Delivery (COD) freight services.
    2. The regulations aim to address issues such as fraud and inadequate security measures associated with COD services.
    3. Detailed receipt requirements have been established, including specific formatting and content guidelines.
    4. Customer rights to refunds are clearly outlined, including situations where refunds are applicable and the refund process.
    5. The regulations prohibit certain clauses that limit liability or deny customer rights to returns or refunds.
    6. The new rules are set to take effect on October 3, 2024, following a public hearing process.

    Author: Panisa Suwanmatajarn, Managing Partner.

    Other Articles

    on by

    Thailand’s Proposed Electronic Transaction Bill: Modernizing the Digital Economy Framework

    Thailand is poised to modernize its electronic transaction legislation with a comprehensive overhaul of the Electronic Transaction Act B.E. 2544 (2001) (ETA). The proposed Electronic Transaction Bill (ETB), currently undergoing public consultation, aims to update the legal framework to better align with current technological advancements and international standards.

    The ETB retains the fundamental principle of functional equivalence between electronic and physical documents established in the ETA. However, it further clarifies compliance requirements for electronic documents to meet legal obligations traditionally imposed on physical documents. For instance, publishing information on an accessible online platform would be deemed equivalent to newspaper publication when required by law. The ETB also affirms that electronic information can be used as evidence in legal proceedings, with the burden of proof regarding credibility falling on the party questioning such information.

    A significant addition to the proposed legislation is the introduction of Electronic Transferable Records (ETRs), aligning with the UNCITRAL Model Law on Electronic Transferable Records. ETRs are defined as documents or records that can be used to claim rights against another party. Given their unique characteristics, such as control and endorsement methods, the ETB outlines specific requirements for ETRs. These include: (1) containing all messages/terms stipulated by law, (2) using a reliable method to control rights over the electronic transferable record, and (3) employing a reliable method to ensure information correctness.

    hands typing on a laptop keyboard

    The ETB also introduces provisions for Electronic Transaction Services (ETS), encompassing a range of digital services including identity proofing and authentication, electronic signatures, timestamping, transmission and storage of electronic information, registration and certification of websites and domain names, and ETR services. The ETB proposes a two-tiered governance approach for ETS providers: mandatory compliance with basic obligations and optional certification as a reliable service provider by the Electronic Transactions Development Agency (ETDA). This framework aims to enhance service quality and reliability while offering potential liability exemptions for certified providers under certain circumstances.

    To ensure a smooth transition, the ETB includes provisions to address the status of digital platform service providers currently regulated under the Royal Decree on the Operation of Digital Platform Services subject to Prior Notification B.E. 2565 (2022). These transitional measures aim to maintain regulatory continuity until a new digital platform law is enacted.

    The proposed legislation represents Thailand’s efforts to create a more robust and internationally aligned legal framework for electronic transactions. It seeks to enhance the credibility of digital transactions, reduce costs, and ultimately boost Thailand’s competitiveness in the global digital economy.

    As of July 2024, the ETB is undergoing its second round of public consultation, with an additional round planned before finalization. Following this process, the ETB will be submitted to the Cabinet and subsequently proposed to Parliament for deliberation. This comprehensive update to Thailand’s electronic transaction laws signifies a crucial step in adapting to the evolving digital landscape and supporting the country’s economic growth in the digital era.

    Author: Panisa Suwanmatajarn, Managing Partner.

    Other Articles

    on by

    Thailand Introduces New Regulation to Protect Online Shoppers

    The Office of the Consumer Protection Board (OCPB) in Thailand has approved a draft announcement aimed at addressing the growing concerns of e-commerce fraud and consumer protection in online shopping. The new regulations, set to be published in the Royal Gazette in July, will introduce significant changes to cash-on-delivery services and provide more rights to consumers.

    The Minister to the Prime Minister’s Office stated that numerous complaints have been received from consumers regarding issues with online purchases. These include receiving unordered packages with cash-on-delivery demands, difficulties in contacting sellers after problematic purchases, and inability to obtain refunds due to logistics companies claiming they have already paid the sellers.

    In the first quarter of 2024 alone, the Office of the Consumer Protection Board (OCPB) received a staggering 5,786 complaints related to consumer goods and services. Of these, 2,162 were specifically about online shopping – a testament to the growing pains of Thailand’s digital economy.

    To tackle these issues, the OCPB has introduced the “Dee-Delivery” measure, which imposes new requirements on logistics providers offering cash-on-delivery services. This comprehensive set of regulations, soon to be enshrined in law, promises to revolutionize the cash-on-delivery system that has long been a staple of Thai e-commerce.

    gray steel shopping cart

    Picture this, a courier arrives at your door with a package. Under the new rules, you are no longer at the mercy of what is inside. You can open it, inspect it, and if it is not what you ordered or if it is damaged, you can refuse it on the spot. No more battles for refunds or chasing ghost sellers.

    Key aspects of the new regulations include:

    1. Mandatory detailed information: Logistics companies must provide comprehensive details about the sender, including name, address, and contact information.
    2. Five-day holding period: Payment collected from consumers must be held by the logistics company for five days before transferring to the seller, allowing consumers time to report issues and request refunds.
    3. Right to inspect: Consumers are granted the right to open and inspect goods before making payment.
    4. Refusal rights: If problems are found during an inspection, consumers can refuse payment and reject the goods.
    5. Clear documentation: All transaction details must be clearly stated on the receipt in Thai language with specific font size requirements.

    The new measures also outline conditions under which consumers are entitled to refunds, such as receiving incorrect or damaged items, or goods that were not ordered.

    These regulations aim to enhance transparency in online transactions and provide consumers with more protection against fraudulent practices. The OCPB hopes that by implementing these measures, the number of complaints related to e-commerce will decrease, improving overall consumer confidence in online shopping.

    person marking check on opened book

    The new regulations are expected to take effect 120 days after their publication in the Royal Gazette, giving businesses time to adapt to the new requirements. Failure to comply with these regulations could result in significant penalties, including fines of up to 200,000 baht, imprisonment for up to one year, or both.

    This proactive approach by the Thai government demonstrates a commitment to addressing the evolving challenges in the e-commerce landscape and ensuring a safer online shopping environment for consumers.

    Author: Panisa Suwanmatajarn, Managing Partner.

    Other Articles

    on by

    Thailand’s ETDA Unveils Comprehensive Guidelines to Combat Online Advertising Fraud

    In a significant move to address the growing concerns of digital fraud and misleading advertisements, Thailand’s Electronic Transactions Development Agency (ETDA) has introduced a comprehensive set of guidelines aimed at regulating advertising on digital platforms. This initiative, detailed in the “Manual for Advertising Oversight on Digital Platform Services,” comes as a response to the increasing incidents of online scams, impersonation of public figures, and fraudulent activities that have resulted in substantial financial losses for unsuspecting users.

    The digital landscape in Thailand has witnessed a surge in sophisticated scams, often involving the impersonation of celebrities, influencers, and reputable businesses. These fraudulent activities have not only led to financial damages but have also eroded public trust in online platforms. Recognizing the urgent need for intervention, the ETDA has developed these guidelines to establish a more secure and trustworthy online advertising environment.

    User Authentication: At the heart of the new regulations is a robust system for advertiser verification. Digital platform operators are now required to implement stringent user authentication processes for all advertisers. The guidelines mandate a minimum Identity Assurance Level (IAL), which may involve using government-issued identification or other reliable methods to confirm the true identity of advertisers. This measure aims to create a significant barrier for potential scammers and impersonators, making it more challenging for them to operate anonymously on these platforms.

    Advertiser Data Management: The guidelines also place a strong emphasis on data management and transparency. Platform operators must maintain comprehensive records of advertisers in a machine-readable format. This includes the creation of watchlists for potentially problematic advertisers, blacklists for those who have violated policies or laws, and whitelists for trusted advertisers. By implementing these lists, platforms can more effectively manage the quality and reliability of advertisements appearing on their services.

    codes on tilt shift lens

    Pre-Publication Screening: Pre-publication screening is another critical component of the new guidelines. Digital platforms are expected to establish clear criteria for prohibited or restricted advertisements and implement thorough screening processes before any ad is published. This proactive approach aims to prevent harmful or misleading content from reaching users in the first place.

    Ongoing Monitoring: Recognizing that no system is perfect, the ETDA also mandates ongoing monitoring of published advertisements. Platforms are required to use a combination of automated systems and human review to continuously assess the content on their sites. The guidelines suggest prioritizing high-risk content for more intensive scrutiny, ensuring that potentially harmful ads are quickly identified and addressed.

    User Reporting Mechanisms: User empowerment is a key feature of the new regulations. Digital platforms must provide easy channels for users to report inappropriate or illegal advertisements. These reporting mechanisms should be prominently displayed alongside advertisements, allowing users to flag suspicious content quickly. Furthermore, platforms are required to have clear processes for handling these reports, including timely reviews and responses to user concerns.

    green and white line illustration

    Transparency: Transparency is emphasized throughout the guidelines. Platform operators are now required to disclose their policies, processes, and tools used in ad management and content moderation to users. This openness is intended to build trust between platforms and their users, providing clarity on how advertising is managed and moderated.

    The ETDA’s approach balances the need for stringent oversight with the practicalities of operating a digital platform. While the guidelines are comprehensive, they allow for flexibility in implementation, recognizing that different platforms may have varying business models and technical capabilities. The agency encourages platform operators to adapt these guidelines to their specific circumstances while maintaining the core principles of user protection and fraud prevention.

    By implementing these measures, the ETDA aims to create a more trustworthy online advertising environment in Thailand. The guidelines are expected to significantly reduce the incidence of fraud and scams on digital platforms, protecting consumers from financial losses and restoring confidence in online transactions and advertisements.

    As digital platforms begin to implement these new guidelines, Thai consumers can look forward to a safer online environment. The success of this initiative could potentially serve as a model for other countries grappling with similar issues in the digital advertising space. As the digital economy continues to grow, such proactive measures by regulatory bodies like the ETDA will be crucial in ensuring that the benefits of online platforms are not overshadowed by the risks of fraud and deception.

    Author: Panisa Suwanmatajarn, Managing Partner.

    Other Articles

    on by

    Brief Notification for the Digital Platform Services

    The Notification of the Electronic Transactions Commission regarding the Nature of the Digital Platform Services Requiring a Notification of the Brief List (“Notification”) was published in the Royal Gazette on 18 August 2023 by virtue of Section 8 of the Royal Decree on the Operation of Digital Platform Service Business that are Subject to Prior Notification B.E. 2565 (2022) (“Royal Decree”) and it will be enforced on 21 August 2023 onwards.

    This Notification is aimed to prescribe details of the qualification of the digital platform service providers under Section 8 of the Royal Decree  which is  (1) earning a yearly gross income in Thailand of not more than 1,800,000 Baht as a natural person, or not more than50,000,000 Baht as a juristic person, and (2) Digital platform service providers with no more than 5,000 monthly average users (“Digital Platform Service Providers”) to notify information listed below (a brief list) to ETDA prior to operating their platforms:

    • Platform operator’s information, i.e., natural person’s name-surname or juristic person’s name, national identification number or juristic person registration number, address, juristic person’s accounting period, and contact channel which can be URL or application.
    • Digital Platform Service Providers’ information, i.e., name, type, and channel of the Digital Platform Service Providers.
    • Digital Platform Service Providers’ point of contact in Thailand.

    In the Notification, we noticed that there are additional qualifications of the Digital Platform Service Providers specified therein which we view that those are in conflict with the principle of definition of the term “digital platform services” and Section 8 of the Royal Decree as it shall not include a digital platform service that is intended for offering goods or services of a single digital platform service operator or an affiliated company which is an agent of such operator, irrespective of whether the goods or services are offered to third persons or to affiliated companies.

    Furthermore, the aforementioned Digital Platform Service Providers must notify the ETDA of the following information on an annual basis, i.e., (1) within 60 days of the end of the calendar year in the case of a natural person’s platform operator or (2) at the end of the fiscal year in the case of a juristic person platform operator:

    • Value of transactions incurred on the service platforms (if any)
    • Gross income from providing the service platform in Thailand (if any)

    This Notification is only applicable to smaller size Digital Platform Service Providers. However, Digital Platform Service Providers in general are still obligated to comply with. The sanction for failure to notify the required information would be subject to the competent official issuing of an order prohibiting the Digital Platform Service Providers from providing the digital platform services.

    Author: Panisa Suwanmatajarn, Managing Partner.

    Other Articles

    on by

    Details of Terms and Conditions for the Digital Platform Service Businesses

    On 21 August 2023, the Royal Decree on the Operation of Digital Platform Service Businesses that are Subject to Prior Notification B.E. 2565 (2022) (“Royal Decree”) has come into force. In this regard, Section 17 of the Royal Degree requires the digital platform service and the search engine Providers that meet certain requirements to prepare and publish the terms and conditions with minimum information as prescribed in the Royal Decree (“Terms and Conditions”). The Royal Decree itself, however, did not provide details or clarifications in regard to such minimum requirements. As such, the Electronic Transaction Development Agency (“ETDA”) has issued a Notification of ETDA number Thor.Por.Dor. 4/2566 on the Details on the Publication of Terms and Conditions of Services for Users’ Knowledge (“Notification”).

    person marking check on opened book
    Photo by Pixabay on Pexels.com

    The Notification consisted of various details important for the digital platform service providers to comply with. The key provisions can be categorized as provisions that further clarify Section 17 of the Royal Decree and provisions that assign additional obligations to the digital platform service providers. Some of the key provisions are summarized as follows:

    1. The Terms and Conditions must be in Thai, easily understandable by the platform’s users, made easy in terms of accessibility, and composed of enough details for the user to make an informed decision whether to use the platform or not. The digital platform service providers must also notify the ETDA and provide evidence showing that they have published the Terms and Conditions for the users’ knowledge.
    2. Where the digital platform service providers treat each of the products, services, or contents of the business users differently, the digital platform service providers must clearly specify the differences in the Terms and Conditions.
    3. In addition to the prescribed minimum requirement in Section 17 of the Royal Decree, the digital platform service providers that meet the requirement of Section 16 (1) of the Royal Decree must also prescribe an additional item, such as an additional distribution channel, the ownership or entitlement in intellectual property after entering into the Terms and Conditions, ancillary or complementary goods and services that is offered to the users before the transaction is concluded, conditions for suspending or terminating the provision of services, etc.
    4. The Notification further provides an example, easing the digital platform service providers to comply with Section 17 of the Royal Decree, that is, the example of algorithms required to be included in the Terms and Conditions are given, for example, price, keywords, user demographic, quality of products, quality of seller, users’ review towards the goods or services.  
    5. Where Section 17 (8) of the Royal Decree requires the digital platform service providers to include in the Terms and Conditions, “an actions to be taken to illegal goods, services, or contents”, the Royal Decree further clarifies that the digital platform service providers must specify if the processes, measures, or mechanism used by the digital platform service providers in determining if a good, service, or contents are illegal or not, are done by an algorithm decision-making, or by human review. The Notification further requires the digital platform service providers to have in place a notice-and-takedown mechanism and details thereof.
    man in black suit sitting on chair beside buildings

    Please be reminded that the aforementioned information is only a brief detail prescribed under the Notification. Terms and Conditions to be prepared in accordance with the Notification are said to be of complex structures and details. Digital platform service providers must pay attention to the details to avoid any incompliance with the law.

    Author: Panisa Suwanmatajarn, Managing Partner.

    Other Articles

    on by

    ETDA’s Recommendation for an Online Merchant Management System with Cash on Delivery Service

    The Electronic Development Transactions Agency (ETDA) has recently proposed a draft of ICT Standards for Electronic Transactions, specifically recommending guidelines for an online merchant management system that offers cash-on-delivery (COD) services. The purpose of this recommendation is to establish consistent practices for service providers in this field, addressing emerging challenges and mitigating potential risks associated with COD transactions. Ultimately, the goal is to enhance customer confidence and trust in the process of buying and selling products through COD.

    The recommendation is structured into four main sections: scope, definition, introduction of COD, and conditions for online merchant delivery management services. Key points from each section are summarized as follows:

    • Authentication of COD online merchant service providers are required to authenticate online merchants before allowing them to activate their services on the platform. This includes notifying the merchants about the authentication criteria and the information that needs to be collected, such as their names, identification numbers, and bank account numbers, to be in compliance with relevant laws.
    • Online merchant delivery information must be maintained. Such information includes tracking numbers and recipient details. Additionally, any unusual behavior exhibited by online merchant service providers must be monitored.
    laptop technology ipad tablet
    • Provisions of recipient information on parcel cover sheets
      • Information on parcel cover sheets: service providers are obligated to include clear and visible information on the parcel cover sheets. This includes the service provider’s names, contact information, websites or communication channels, and details related to recipients’ support.
      • Information for assisting recipients: service providers must provide information on how the system assists recipients. This includes details on scenarios where the system can assist, channels for reporting problems, and any evidence that recipients may need to submit for investigation.
    • Monitoring and addressing online merchant delivery behavior to prevent scams related to COD transactions: service providers must continuously monitor and track incidents involving online merchants. They should establish procedures for addressing suspicious behavior, which include the following steps:
      • Suspected scammers: if more than 10% of recipients report unexpected deliveries or parcels, they did not purchase from a specific merchant. In this case, the service providers must permanently terminate that merchant’s account.
      • Non-compliant items: if the items received by recipients do not meet the specifications as specified, service providers should notify the online merchants and request information to investigate and resolve the issue for both the merchants and the recipients.
      • Incident recording for future analysis: service providers are required to maintain records of incidents involving online merchant behaviors, which can be analyzed in the future for further insights.
      • Gathering evidence and reporting wrongdoings: if evidence related to scams or other wrongdoings is gathered, service providers should report the findings to the relevant authorities.

    It is important to note that the above conditions and procedures are recommendations with no legal enforcement. They serve as guidance for service providers in the industry to establish best practices and maintain a high level of service quality and protection to the customers.

    Author: Panisa Suwanmatajarn, Managing Partner.

    Other Articles

    on by

    Thailand – Royal Decree on Controlling the Online Service Platform Business

    Thailand faces the similar problems as EU due to COVID-19 pandemic where people shift from physical sale to online sale. Throughout the operation of online platform for business, both producers and customers counter several troubles such as details of the product, ambiguous service terms, limited choices of delivery, delay in delivery, damages, products are not as advertised, fraud, unable to track the orders of products, unfair prices, or the problems of complaint system and their quality to tackle the complaint sent in. On the service providers’ side, they are in need of certain standard or guideline to a clearer operation from the governmental units. Another issue is the foreign or international online service platforms that have not registered their identity in Thailand making it harder to follow up of feedback or dispute arise in which sometimes create bias or unfair treatment and protection of international service providers and Thai service providers.

    As such the regulator introduces legal instrument to govern this online platform and digital service business especially such as the EU implement platform to business regulation (P2B) to attend operation of online intermediation services and business users. Leads to process of commencing a guideline to govern the online platform in Thailand, currently there is no rule or regulation issued to attend this matter but only a drafting of Royal Decree on Controlling the Online Service Platform Business that Must Be Registered B.E. …. (“Royal Decree”) as a scope of controlling to ensure security, safety, creditability in giving service to the customer which can develop a certain standard or qualification in giving fair and quality service.

    Before introduction of this draft, the service provider must register under Business Registration Act B.E. 2499 (1956) as certified of legal existence where the noncompliance result is in a form of fine. Under the Direct Sale and Direct Marketing Act B.E. 2560 (2017), online sellers with sales over 1.8 million baht per year must register the business as noncompliance result is in a form of fine and imprisonment. Not only the registration compliance, but the providers must also display the products or services in an appropriate manner as stated under Rule 4 of Announcement of the Central Committee on the Price of Goods and Services No. 70 B.E. 2563 (2020). However, the mentioned existing laws cannot solve the current problems, therefore, the new draft will come up to assist these existing laws.

    The draft royal decree introduces similar but new and different contents with clearer and wider range of definition and information of the business conducting on the digital platform, for instance define the term of online service platform, service providers on the online platform, users of the online platform. The draft emphasis clearer details of the types and characters of online service platform that need to notify Electronic Transactions Development Agency (ETDA) before operating the business of the details regarding the businesses and services or products display, relative data of users, complaint mechanisms, terms and conditions of services and products offer to the users, service terms and conditions, suspension or ban from using services of service providers. All these clauses introduce to endorse and support transparency and fairness.

    The essence of this draft Royal Decree is to create standard of service that ensure fairness, transparency and protection to the customers. The service providers governed under this draft Royal Decree will be depending on their gross income and numbers of platform users under Section 8 and the foreign service providers for Thai user in Thailand will be under Section 9. The service providers notify the ETDA of the details and information regarding the operation of online platform business will be under Section 11. The service providers under Section 15 must notify the users of service agreement and conditions in accordance with Section 16. Where the service providers do not hold Thai nationality but give services to consumers in Thailand, there must be a Thai representative acting in compliance with this regulation to ensure no bias treatment measures implemented such as complaint channels, dispute resolutions, compensation measures, conditions of displaying, advertising, and categorising products and services.

    The P2B and the draft Royal Decree set to promote fair, transparent, and predictable business environment for smaller businesses and traders on online platforms. The P2B applies to the providers of online intermediation services and search engines with certain set of rules. Providers subjected under the P2B is obliged to the conditions and qualifications set forth such as languages of terms and conditions and their informative characters, procedures in amend or change of terms and conditions of services, rights and obligations of the providers under the P2B, voluntary actions that could be done by the providers and notifying to the service providers and customers.

    Both P2B and draft Royal Decree have similar purposes and directions. Both oblige the platforms to implement conditions and terms regarding suspension or band of using the services from the platforms. But the P2B provides more details and specifications by categorising providers and conditions for each provider. It also concerns the users of services and contribute provisions to notify them of their rights and obligations.