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Thailand Tightens Registration Requirements for Partnerships and Limited Companies with Foreign Participation

Nominees: A Threat to Thailand’s Economy

Nominee arrangements — in which Thai nationals hold shares or capital contributions on behalf of foreign investors — have remained a longstanding compliance concern under the Foreign Business Act B.E. 2542 (1999) (the “FBA”). The Department of Business Development (the “DBD”) has now shifted a significant part of that scrutiny to the registration stage itself.

The use of nominees is a major national concern that undermines Thailand’s economic and business security by distorting market competition, reducing tax revenue, and eroding investor confidence. Foreign operators who rely on nominees unfairly bypass statutory business restrictions, undercutting law-abiding foreign investors and overwhelming Thai small and medium-sized enterprises (SMEs) that cannot compete against superior capital and resources — ultimately contributing to job losses and business closures. Nominee structures also facilitate tax evasion, money laundering, and other illicit financial activity, which compromises state revenue collection and damages Thailand’s international reputation by exposing gaps in regulatory and legal enforcement.

For these reasons, the rigorous inspection of, and crackdown on, nominee arrangements is a critical measure to protect the country’s economic interests, ensure fair competition, and safeguard the long-term stability of the Thai economy.

Background

Initial screening at the company incorporation stage previously offered partial protection against nominee risk by verifying Thai investment capital. However, bad actors circumvented these controls through subsequent corporate amendments — transferring shares or directorships to foreign nationals only after the company had already secured initial approval.

Legal Basis

To close this loophole, the DBD issued the “Central Partnership and Company Registrar Order No. 2/2569, Prescribing the Criteria and Supporting Documents for Applications for the Registration of the Incorporation and Amendment of Partnerships and Limited Companies Where Foreign Nationals Participate in the Investment or Hold Signing Authority in Partnerships and Limited Companies” (the “Order”). The Order took effect on 1 August 2026.

The Order extends DBD oversight across the full business lifecycle — from incorporation through post-registration amendments — to prevent unauthorized structural changes, while imposing stricter documentation requirements on all relevant registration applications.

It consolidates existing requirements by repealing two earlier orders:

  1. Order No. 2/2568, dated 1 December 2025 (B.E. 2568), concerning the registration of incorporation involving foreign investment, foreign directors, or foreign authorized signatories in a legal entity; and
  2. Order No. 1/2569, dated 16 March 2026 (B.E. 2569), concerning amendment registrations admitting foreign nationals as partners or as authorized signatory directors.

According to its preamble, the Order is intended to enhance the credibility of the commercial register, to prevent the concealment or disguise of funds derived from unlawful conduct through nominee arrangements, and to deter Thai nationals from providing assistance or support to, or jointly operating a business with, foreign nationals in the nature of a nominee.

New Legal Requirements

1. Registration of Incorporation

The additional documentary requirements apply to an application for the registration of incorporation in either of the following cases:

  • a partnership or limited company in which a foreign partner or shareholder contributes, or holds, less than 50% of the capital contribution or registered capital; or
  • a limited company with no foreign shareholder, where a foreign national serves as a director authorized to sign — whether solely or jointly — so as to bind the company.

Supporting documents required at incorporation

Applicants falling within the above categories must submit a Letter of Clarification on Investment, in the form annexed to the Order, together with the following bank statements:

  • a statement of the account from which each Thai partner or shareholder made payment, covering the three months prior to the date of payment and evidencing a withdrawal or transfer consistent with the amount and date of payment;
  • a statement of the account of the managing partner or director who received the funds, evidencing receipts consistent with the amount and date of payment from each partner and shareholder; and
  • where the receiving account is also the account relied upon to evidence payment under the first item above, an additional statement covering the three months prior to the date of receipt.

The third requirement addresses situations in which the managing partner or director settles their own contribution from funds already held in the receiving account, rather than by a traceable transfer. In such cases, the source of those funds must be explained separately in the Letter of Clarification.

2. Amendment Registrations Involving Foreign Nationals

A Letter of Confirmation of Investment, also in the form annexed to the Order, must be submitted with an application to register an amendment admitting a foreign national as a partner, or appointing a foreign national as an authorized signatory director, in either of the following cases:

  • a partnership in which all partners were previously Thai nationals, or in which foreign partners held 50% or more of the capital contribution, where the amendment results in foreign partners holding less than 50% and no foreign national serving as managing partner; or
  • a limited company in which all directors authorized to bind the company were previously Thai nationals, where an amendment to the directors — or to the number or names of the directors signing to bind the company — results in a foreign national holding sole or joint signing authority.

3. Additional Requirements for Recently Incorporated Entities

Where a partnership or limited company incorporated on or after 1 August 2026 submits an amendment application of the type described above within one year of its registration as a juristic person, it must additionally submit the amendment version of the Letter of Clarification on Investment, together with a bank statement evidencing that the entity — or the managing partner or director on its behalf — received the full amount of the capital contributions or share payments called up at incorporation.

This requirement addresses the sequencing of transactions whereby an entity is incorporated with Thai partners or directors and a foreign national is introduced shortly thereafter.

Legal Significance

The Order does not introduce a new prohibition; nominee arrangements already constitute an offence under Section 36 of the FBA. Its significance instead lies in shifting the evidentiary burden to the point of registration, and in the personal declaration now required of the signatory.

Under the Letter of Confirmation of Investment, the managing partner or authorized director confirms that all partners have genuinely made and paid their capital contributions, that all shareholders have genuinely paid for their shares, and that no Thai national has provided assistance or support to, or jointly operated a business with, a foreign national in the nature of a nominee. The signatory further acknowledges the following penalties:

  • Section 36 of the FBA: imprisonment not exceeding 3 years, a fine of THB 100,000 to 1,000,000, or both;
  • Section 137 of the Criminal Code (false statements to an official): imprisonment not exceeding 6 months, a fine not exceeding THB 10,000, or both; and
  • Section 267 of the Criminal Code (causing a false entry in a public document): imprisonment not exceeding 3 years, a fine not exceeding THB 60,000, or both.

Key Takeaways

  • Existing entities are unaffected until they register a qualifying amendment, at which point the Order applies in full.
  • The Order took effect on 1 August 2026 and applies to partnerships and limited companies in which foreign participation is below 50%, and to limited companies in which a foreign national holds signing authority.
  • Documentary requirements now extend to bank statements evidencing both the payment and receipt of capital contributions and share payments, supported by a prescribed clarification letter.
  • Amendment registrations introducing a foreign partner or foreign signatory require a signed Letter of Confirmation of Investment, which carries personal criminal exposure for the signatory.
  • Entities incorporated on or after the effective date are subject to additional requirements if a qualifying amendment is registered within their first year.

Author: Panisa Suwanmatajarn, Managing Partner.

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NBTC Issues AI Governance Guidelines for Telecom Licensees

Thailand’s National Broadcasting and Telecommunications Commission (NBTC) has issued new guidelines setting out its expectations for the responsible use of artificial intelligence (AI) by telecommunications licensees. Although the guidelines are not legally binding, they establish a comprehensive risk-based framework for AI governance and provide a clear indication of the regulatory standards that the NBTC expects telecom operators to adopt when deploying AI in the provision of telecommunications services.

The guidelines reflect the increasing regulatory focus on AI governance and complement existing legal obligations relating to cybersecurity, personal data protection, and telecommunications. They also align with broader national efforts to develop a comprehensive AI regulatory framework.

Scope of the Guidelines:

The guidelines apply to holders of telecommunications business licenses under Thailand’s telecommunications licensing regime, but only in relation to AI systems used to provide licensed telecommunications services.

Organizations that are not telecommunications licensees are not directly subject to the guidelines. Nevertheless, AI developers, technology vendors, cloud service providers, and outsourced service providers may be indirectly affected because telecommunications licensees are expected to exercise oversight over third-party AI solutions used in their operations. As a result, contractual obligations and vendor due diligence are likely to become increasingly important for suppliers serving the telecommunications sector.

The guidelines should be considered alongside existing legal requirements, including the Personal Data Protection Act, the Cybersecurity Act, the Computer Crime Act, and the NBTC Notification on the Protection of Telecommunications Service Users’ Rights in relation to personal data, privacy, and the freedom of telecommunications. They also complement the broader AI legislation currently under development by the Electronic Transactions Development Agency (ETDA).

Strengthening AI Governance:

A central feature of the guidelines is the expectation that AI governance should extend beyond technical implementation and become an organizational responsibility.

Telecommunications licensees are encouraged to establish governance structures at both the policy and operational levels, such as AI committees, working groups, or designated responsible officers. These governance bodies should oversee AI strategy, establish internal policies, supervise risk management, and define accountability throughout the AI lifecycle.

The guidelines also emphasize that responsibilities should be clearly assigned not only to internal personnel but also to third-party AI solution providers and outsourced service providers. Licensees are expected to ensure that contractual arrangements clearly define each party’s obligations regarding AI governance, risk management, and regulatory compliance.

A Principles-Based Approach to Responsible AI:

Rather than prescribing detailed technical requirements, the guidelines adopt a principles-based approach centered on six core expectations.

First, AI systems should comply with applicable laws, ethical principles, and internationally recognized standards. AI should respect privacy, human dignity, and fundamental rights, and organizations should consider implementing appropriate safeguards, including content filtering, to reduce the risk of generating harmful or unlawful outputs.

Second, AI systems should operate fairly. This includes using representative and reliable training data, assessing potential bias, and taking appropriate measures to mitigate discriminatory outcomes.

Third, cybersecurity and privacy protections should be integrated into AI systems. The guidelines encourage the adoption of internationally recognized security standards and recommend technical safeguards such as encryption, anonymization, and access controls to protect personal data and system integrity.

Fourth, organizations should promote transparency by maintaining documentation regarding AI design, development, and operation, while providing consumers with appropriate information about how AI systems influence decisions or recommendations.

Fifth, accountability should be clearly established throughout the organization. Internal policies should define responsibility for AI outcomes, while consumers should have accessible channels to submit inquiries or complaints regarding AI-enabled services.

Finally, AI systems should be reliable and robust. The guidelines recommend testing AI models to ensure that they produce accurate and consistent results, including under unexpected operating conditions.

Governance Throughout the AI Lifecycle:

The guidelines emphasize that AI governance should be integrated throughout the entire AI lifecycle rather than focusing solely on deployment.

Licensees are expected to conduct risk assessments before development begins, evaluate the capabilities and reliability of third-party AI providers, and maintain appropriate standards for data quality and traceability. Before deployment, AI systems should undergo testing for reliability, fairness, and operational performance.

Once AI systems are operational, organizations should continuously monitor performance, maintain appropriate human oversight, and periodically evaluate whether AI systems continue to operate as intended. The guidelines also address the retirement of AI systems, encouraging secure decommissioning processes that protect data and maintain appropriate records throughout the system’s lifecycle.

This lifecycle-based approach reflects the growing international trend toward continuous AI governance rather than one-time compliance assessments.

Consumer Transparency and Organizational Readiness:

Consumer protection is another significant feature of the guidelines.

Telecommunications licensees are encouraged to notify consumers when they are interacting with AI systems, such as chatbots or voicebots. Where AI-generated recommendations may influence consumer decisions, organizations should provide appropriate disclosures and allow consumers to request assistance from a human representative where appropriate. Effective feedback and complaint mechanisms should also be maintained.

Internally, the guidelines recognize that responsible AI governance requires organization-wide awareness. Licensees are therefore encouraged to provide AI-related training across all levels of the organization. Employees who use AI systems should understand the associated legal and operational risks, while technical personnel and external developers should receive training on organizational AI policies, ethical principles, and applicable regulatory requirements.

Practical Implications:

Although the guidelines do not create new legal obligations, they provide valuable insight into the NBTC’s regulatory expectations and are likely to influence future regulatory supervision and industry best practices.

Telecommunications licensees should consider reviewing their existing AI governance frameworks to determine whether governance responsibilities are clearly assigned and appropriately documented. Organizations should also evaluate AI risk management procedures, update contracts with AI vendors and outsourced service providers, assess consumer disclosure mechanisms, and ensure that staff receive appropriate AI governance training.

The guidelines may also have implications for corporate transactions involving telecommunications businesses. As AI becomes increasingly integrated into telecommunications operations, AI governance maturity, data governance practices, and vendor oversight may become important considerations during legal and regulatory due diligence.

Key Takeaways:

  • Telecommunications licensees should review their governance frameworks, contractual arrangements, AI risk management processes, consumer disclosure practices, and staff training programs to align with the NBTC’s expectations.
  • The NBTC’s AI guidelines establish a comprehensive risk-based governance framework for telecommunications licensees and provide a clear indication of the regulator’s expectations for responsible AI deployment.
  • Although nonbinding, the guidelines are likely to influence regulatory supervision and industry best practices within Thailand’s telecommunications sector.
  • AI governance is expected to extend throughout the entire AI lifecycle, encompassing organizational governance, risk management, vendor oversight, cybersecurity, consumer protection, and ongoing monitoring.

Author: Panisa Suwanmatajarn, Managing Partner.

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Thailand signals a shift toward expenditure-based management of universal healthcare

Thailand’s universal healthcare system has long been regarded as one of the country’s most successful public policy achievements. However, increasing healthcare utilization, an aging population, rising treatment costs, and fiscal constraints are prompting policymakers to reconsider how the system should be financed over the long term.

Recent policy discussions within the Ministry of Public Health indicate that the focus is no longer solely on expanding healthcare benefits. Instead, the government appears to be moving toward a framework that emphasizes expenditure management, efficiency, and value-based healthcare while maintaining universal access to essential medical services.

Shift from expanding benefits to managing sustainability:

Thailand’s public healthcare system is primarily delivered through three government-funded schemes:

  • the Universal Coverage Scheme (UCS);
  • the Social Security Scheme (SSS); and
  • the Civil Servant Medical Benefit Scheme (CSMBS).

Although annual government appropriations for these schemes have continued to increase, healthcare expenditure has grown at an even faster pace due to demographic changes, increasing prevalence of chronic diseases, advances in medical technology, and greater public expectations regarding access to treatment. Policymakers have therefore expressed concern that healthcare expenditure may outpace long-term fiscal capacity unless structural reforms are implemented.

Proposed expenditure management measures:

Current policy discussions suggest that future reforms may include greater reliance on expenditure controls rather than across-the-board budget increases.

Measures under consideration reportedly include:

  • expenditure ceilings for public hospitals;
  • tighter monitoring of hospital operating costs, pharmaceuticals, and medical supplies;
  • wider use of digital technologies and data analytics to improve financial oversight;
  • periodic review of healthcare benefit packages to prioritize clinically effective and cost-effective services; and
  • broader adoption of value-based healthcare models that reward providers based on patient outcomes rather than service volume.

These initiatives reflect an effort to improve efficiency without fundamentally changing the principle of universal healthcare coverage.

Potential implications for healthcare providers:

Public hospitals may face increasing pressure to operate within fixed budgetary allocations while maintaining service quality. More sophisticated financial management, procurement practices, and clinical governance are therefore likely to become increasingly important.

Healthcare providers may also experience:

  • greater scrutiny of prescribing practices;
  • stronger emphasis on evidence-based treatment pathways;
  • expanded use of health technology assessment in reimbursement decisions; and
  • increased reporting and compliance obligations relating to cost management.

Private healthcare providers participating in government reimbursement programs may likewise experience closer oversight of reimbursement methodologies and service delivery standards.

Regulatory considerations:

While no legislative amendments have fundamentally altered Thailand’s universal healthcare framework, any future implementation of expenditure caps or revised reimbursement mechanisms will require careful alignment with existing legislation governing public health financing and healthcare entitlements.

Future regulatory developments may include:

  • revised payment methodologies;
  • updated reimbursement criteria;
  • enhanced procurement controls;
  • expanded digital monitoring of healthcare expenditure; and
  • revised administrative guidelines governing public healthcare providers.

Businesses operating in the healthcare, pharmaceutical, medical device, and digital health sectors should therefore continue to monitor policy developments, as changes in reimbursement and procurement practices may influence market access and commercial strategies.

Key takeaways:

  • Thailand is shifting its healthcare policy emphasis from expanding benefits toward improving financial sustainability.
  • Expenditure management and value-based healthcare are emerging as central policy themes.
  • Public hospitals are likely to face tighter budgetary controls and enhanced financial oversight.
  • Healthcare suppliers should anticipate increasing scrutiny of reimbursement, procurement, and cost-effectiveness.
  • Although universal healthcare remains intact, future reforms are expected to focus on preserving the system through more disciplined allocation of healthcare resources rather than unlimited expenditure growth.

Author: Panisa Suwanmatajarn, Managing Partner.

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ETDA’s Proposed AI Sandbox Signals a New Phase of AI Governance

The Electronic Transactions Development Agency (ETDA) has opened a public consultation on a draft notification establishing an Artificial Intelligence (AI) Sandbox. Although the notification has not yet been adopted, it represents one of the clearest regulatory signals that Thailand is moving toward a structured governance framework for AI systems through a controlled testing environment.

For businesses developing or deploying AI solutions, the proposed AI Sandbox is more than a pilot initiative. It is likely to establish regulatory expectations that may influence future AI compliance standards across multiple sectors.

Why the AI Sandbox matters                                              

Regulatory sandboxes have long been used in the financial sector to facilitate innovation while allowing regulators to observe risks under controlled conditions. The proposed AI Sandbox extends this concept to AI technologies by providing an environment where AI systems can be tested before wider deployment.

Unlike traditional compliance regimes that focus primarily on post-deployment enforcement, an AI Sandbox emphasizes governance during the development and testing stages. This reflects an international regulatory trend toward proactive AI risk management.

Although participation in the Sandbox may initially be voluntary, organizations should not view it merely as an experimental program. Regulatory sandboxes frequently become the foundation for future best practices and may ultimately shape industry standards and supervisory expectations.

A shift toward risk-based AI governance

While the draft notification remains subject to consultation, it suggests that AI governance in Thailand is moving toward a risk-based model.

Businesses should expect greater emphasis on governance measures such as:

  • AI risk identification and assessment;
  • testing and validation before deployment;
  • documentation of AI models, datasets, and development processes;
  • human oversight over significant AI-assisted decisions;
  • ongoing monitoring throughout the AI lifecycle; and
  • governance mechanisms for accountability and incident management.

These principles are broadly consistent with international AI governance developments and demonstrate a growing expectation that organizations should be able to explain not only what an AI system does, but also how risks have been identified and managed.

Implications for businesses

The proposed framework has implications across numerous industries, particularly where AI systems influence commercial or operational decision-making.

  • Technology companies and SaaS providers
  • Software developers offering AI-enabled products may need to implement more formal governance processes throughout the product lifecycle. Technical documentation, testing records, model validation, and change management procedures could become increasingly important in demonstrating responsible AI practices.
  • Organizations that currently rely on informal development processes may eventually need governance structures comparable to those already used for cybersecurity and information security compliance.
  • Financial services and fintech
  • Financial institutions already operate within a highly regulated environment. AI governance requirements may become an additional layer of compliance where AI is used for credit scoring, fraud detection, investment services, customer onboarding, or automated decision-making.
  • Existing risk management frameworks may therefore need to expand to include AI-specific controls.
  • Healthcare and health technology
  • Healthcare providers and health technology companies using AI for diagnostics, treatment recommendations, clinical decision support, or patient management are likely to face heightened expectations regarding accuracy, validation, human supervision, and patient safety.
  • Testing within a controlled environment could become an important mechanism for demonstrating reliability before deployment.
  • HR technology
  • Organizations using AI in recruitment, employee evaluation, workforce management, or performance assessment should anticipate closer scrutiny of automated decision-making processes.
  • Transparent governance, human review, and measures to reduce discriminatory outcomes are likely to become increasingly significant compliance considerations.
  • Digital platforms
  • Platform operators deploying generative AI, recommendation algorithms, content moderation systems, or AI-powered customer services may also need stronger governance over system performance, monitoring, and accountability.
  • The ability to document how AI systems operate and respond to identified risks may become an important aspect of regulatory compliance.

Interaction with existing legal frameworks

Although the AI Sandbox is intended to facilitate innovation, participation is unlikely to exempt organizations from existing legal obligations.

Organizations testing AI systems would still be expected to comply with applicable laws, including those governing:

  • personal data protection under the Personal Data Protection Act;
  • electronic transactions;
  • cybersecurity obligations;
  • consumer protection;
  • intellectual property rights; and
  • sector-specific regulatory requirements.

For example, organizations using personal data for AI model training or testing should ensure that appropriate legal bases, transparency obligations, data security measures, and data subject rights continue to be observed.

Similarly, businesses developing generative AI applications should continue to assess potential intellectual property risks relating to training data, generated outputs, and ownership of AI-assisted content.

Preparing for future regulatory expectations

Although the draft notification has not yet entered into force, organizations should consider using the consultation period to evaluate their existing AI governance practices.

Practical steps may include:

  • identifying AI systems currently in operation;
  • classifying AI use cases according to potential risk;
  • documenting AI development and deployment processes;
  • establishing internal AI governance policies;
  • implementing human oversight for significant AI-assisted decisions;
  • reviewing contractual allocation of AI-related responsibilities with vendors and customers; and
  • ensuring that AI governance aligns with existing data protection and cybersecurity compliance programs.

Organizations that begin implementing these governance measures now are likely to be better positioned if the AI Sandbox becomes operational and if similar requirements are incorporated into future regulatory frameworks.

Looking ahead

The draft AI Sandbox notification demonstrates that Thai regulators are moving beyond high-level discussions about artificial intelligence and toward practical governance mechanisms.

Even if participation remains voluntary during its initial stages, the Sandbox is likely to influence regulatory expectations regarding responsible AI development and deployment. Businesses should therefore view the proposal not simply as a testing initiative, but as an indication of the governance standards that may shape future AI regulation.

Key takeaways

Businesses that prepare early are likely to be better positioned as AI governance requirements continue to evolve.

The proposed AI Sandbox represents a significant step toward a structured AI governance framework.

The initiative reflects a broader shift toward risk-based regulation and responsible AI development.

Organizations developing or deploying AI should begin strengthening governance, documentation, testing, and oversight processes.

Existing obligations under data protection, cybersecurity, consumer protection, and intellectual property laws will continue to apply during AI development and testing.

Author: Panisa Suwanmatajarn, Managing Partner.

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Super License Reform Moves to Final Stage Before Becoming Law

In our previous article, “Super License: The Draft Act on Facilitation in the Consideration of Licenses and Provision of Services to the Public,” we discussed the proposed overhaul of the administrative licensing regime and its potential to fundamentally modernize public services and regulatory approvals.

Super License: The Draft Act on Facilitation in the Consideration of Licenses and Provision of Services to the Public – The Legal Co., Ltd.

The legislative process has now reached a significant milestone. The Act on Facilitation in the Consideration of Licenses and Provision of Services to the Public B.E. 2569 has been approved by Parliament and is currently awaiting publication in the Government Gazette before coming into force. Once effective, the new legislation will repeal the Facilitation of Licensing by Government Agencies Act B.E. 2558 (2015) and introduce a substantially broader and more integrated framework for government licensing and public services.

A Shift from Licensing Control to Public Service Facilitation:

The new legislation reflects a significant policy shift in the administration of regulatory approvals. Rather than focusing solely on licensing procedures, it establishes a broader framework designed to improve the overall delivery of government services by emphasizing efficiency, transparency, digital integration, and reduced administrative burdens.

The scope of the law extends beyond traditional licensing procedures to cover registrations, notifications, approvals, and various public services provided by government agencies. This broader application aims to establish consistent administrative standards across the public sector while making interactions with government agencies more predictable and user-friendly.

Greater Transparency Through Mandatory Public Handbooks:

One of the most significant reforms is the enhanced requirement for government agencies to prepare comprehensive public handbooks.

These handbooks must clearly specify:

  • application procedures;
  • required documents;
  • statutory processing periods;
  • applicable fees;
  • approval criteria;
  • conditions imposed on applicants; and
  • written guidelines governing the exercise of official discretion.

Requiring agencies to disclose how discretion will be exercised represents an important development. It is intended to reduce inconsistent decision-making, improve legal certainty, and minimize opportunities for arbitrary administrative actions.

Digital Government and “Once-Only” Documentation:

The legislation further advances the government’s digital transformation policy by requiring agencies to utilize electronic information already available within government systems.

Where government agencies already possess information through interconnected databases, applicants generally should not be required to submit the same documents repeatedly. This “once-only” principle is expected to reduce paperwork significantly and improve the overall efficiency of administrative procedures.

The legislation also supports greater use of electronic application systems and centralized digital service platforms.

The Super License Mechanism:

Perhaps the most anticipated feature is the introduction of the Super License mechanism.

For business activities designated by the Cabinet, applicants will be able to obtain a principal license that automatically covers related subsidiary approvals normally issued by multiple government agencies. Instead of pursuing numerous sequential approvals, businesses will be able to complete much of the licensing process through a single application.

Although the categories of businesses eligible for the Super License mechanism will be determined through subsequent implementing measures, the reform is expected to benefit sectors that traditionally require multiple regulatory approvals, including manufacturing, hospitality, energy, and certain service industries.

The practical effectiveness of this mechanism will ultimately depend upon the implementing regulations and the level of coordination among participating agencies.

Faster Licensing Procedures:

The legislation introduces several measures intended to shorten administrative timelines.

Government agencies will be required to review applications promptly upon receipt, notify applicants immediately if documents are incomplete, and adhere to published processing periods. Where delays become unavoidable, agencies must notify applicants and explain the reasons for any extension.

In addition, the legislation provides for:

  • centralized application centers;
  • electronic submission and tracking systems;
  • expedited processing channels for eligible matters;
  • simplified renewal procedures for certain licenses; and
  • multilingual services where appropriate.

Collectively, these measures are designed to reduce procedural uncertainty while improving the overall applicant experience.

Deemed Approval for Certain Applications:

One of the most closely watched reforms is the introduction of a form of deemed approval.

For specified categories of lower-risk activities, where the responsible agency fails to complete consideration within the prescribed timeframe and does not properly extend the review period, the application may be treated as approved by operation of law.

This mechanism is intended to encourage administrative efficiency while providing greater certainty for businesses. However, it is not expected to apply universally, particularly where public safety, environmental protection, national security, or other significant public interests require substantive regulatory review.

Provisional Operations for Low-Risk Activities:

The legislation also introduces mechanisms allowing certain low-risk businesses to commence operations through notification or registration before obtaining full approval.

This represents a notable departure from the traditional approach, under which businesses generally must wait until all approvals have been formally issued before commencing operations. The reform seeks to facilitate earlier economic activity while maintaining appropriate regulatory oversight.

Increased Accountability for Government Agencies:

The legislation imposes stronger obligations on public officials responsible for licensing and service delivery.

Failure to comply with statutory procedures—such as requesting unnecessary documents, failing to meet prescribed timelines without justification, or otherwise violating procedural requirements—may constitute disciplinary misconduct.

These accountability measures reinforce the legislation’s broader objective of improving public confidence in administrative decision-making.

What Businesses Should Do Next:

Although the legislation has completed the parliamentary process, businesses should recognize that it will not become effective until publication in the Government Gazette.

In the meantime, companies that regularly interact with licensing authorities should begin assessing how the new framework may affect their operations. Particular attention should be paid to businesses that currently require approvals from multiple agencies, as they may eventually benefit from the Super License mechanism once implementing regulations identify eligible sectors.

Businesses should also monitor forthcoming subordinate legislation, ministerial regulations, and administrative guidelines, which will determine many of the practical details governing implementation.

Key Takeaways:

  • Businesses should begin reviewing their regulatory compliance strategies and monitor the issuance of subordinate legislation that will govern implementation of the new regime.
  • Parliament has approved the new Act, which is now awaiting publication in the Government Gazette before becoming effective.
  • The legislation replaces the existing licensing facilitation framework with a broader law covering licensing, registrations, notifications, approvals, and public services.
  • The new framework emphasizes transparency, digital government, reduced administrative burdens, and standardized procedures.
  • The Super License mechanism has the potential to significantly simplify regulatory approvals for businesses requiring multiple licenses, although further implementing regulations will determine its practical scope.

Author: Panisa Suwanmatajarn, Managing Partner.

Related Articles: Super License: The Draft Act on Facilitation in the Consideration of Licenses and Provision of Services to the Public – The Legal Co., Ltd.

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Thailand Launches “Economic Cabinet Plus” Plan to Drive High-Growth and High-Income Status

The Thai government has launched a major initiative to work more closely with the private sector on economic policy. Through a new fast-track mechanism and a Joint Public-Private Consultative Committee, the government aims to process private-sector proposals more efficiently and convert business ideas into concrete projects.

What the Government Has Agreed To Do

The initiative’s central aim is to cut red tape and streamline slow-moving bureaucratic processes. The government has established a special fast-track channel that allows economic proposals from business leaders to be reviewed and approved without the delays typical of the traditional system. A newly formed joint public-private committee is then tasked with translating these ideas into implemented projects.

To carry out this plan, the government is driving the economy through four main engines, designed to work in tandem to deliver both short-term and long-term results:

  1. Attracting new investment through a future investment hub and a fast-track approvals initiative aimed at resolving bottlenecks and accelerating project sign-off. The focus is on positioning Thailand as a regional hub for AI, digital technology, and financial services, while advancing the green economy and next-generation automotive industries.
  2. Shifting tourism strategy away from visitor volume and toward high-value, quality tourism — including wellness tourism and medical tourism — while pursuing Free Trade Agreements with major markets such as the EU, the US, and the UK.
  3. Upgrading the national skills base by prioritizing STEM and AI education, and building a stronger ecosystem for startups and private-sector research.
  4. Reforming internal government processes by reducing bureaucratic red tape, expanding digital government and e-licensing services to curb corruption, and updating regulations so that government budgets flow into the economy more quickly.

Under these four engines, the government has identified seven target industries for long-term growth:

  1. High-quality agriculture and food
  2. Future automotive
  3. Smart electronics and digital technology
  4. Medicine and healthcare
  5. High-quality tourism
  6. Global and regional trade
  7. The creative economy

The Government’s Goals

Working in close coordination with the private sector, the government has set measurable targets. First, it aims to raise Thailand’s economic growth potential above 3% annually — a marked improvement on recent performance. Second, it wants to place Thailand among the world’s top 20 most competitive economies, positioning the country as a regional investment hub. The overarching goal of this 12-year plan is to elevate Thailand to “high-income country” status, raising average annual per-capita income to roughly $15,000, up from the current $8,000–$9,000.

What This Means for Investors

For both Thai and foreign investors, the plan offers meaningful advantages. The fast-track system is designed to reduce red tape and shorten approval timelines for licenses and permits. Investors in AI, green energy, digital technology, and financial services — along with the seven target industries — can expect additional support and a more favorable regulatory environment. The government’s 12-year roadmap is also intended to give investors greater confidence in Thailand’s long-term policy stability.

What This Means for Thai Citizens

For Thai citizens, the plan is intended to translate into tangible benefits. Growth in high-tech, financial, and advanced manufacturing industries is expected to create higher-skilled, better-paying jobs. Investment in STEM and AI training aims to build a more competitive workforce, while faster budget disbursement and integration into new investment supply chains should benefit small and medium-sized enterprises (SMEs). As the economy expands, the government intends to reinvest additional revenue into public transport, healthcare, and education.

Key Takeaways

  • A new fast-track mechanism is intended to accelerate the transition from private-sector proposals to government action, organized around four core economic engines.
  • Official targets include lifting the country’s economic growth potential above 3%, placing Thailand in the global top 20 for competitiveness by 2030, and raising average per-capita income to roughly $15,000 within 12 years.
  • Investors can expect reduced red tape, faster licensing through e-government initiatives, and targeted support across seven priority industries.

Thai citizens stand to benefit from STEM/AI training programs, stronger SME support, higher-paying jobs, and improved public infrastructure.

Author: Panisa Suwanmatajarn, Managing Partner.

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Thailand Launches THIM App to Streamline Arrivals for Foreign Travelers

Thailand’s Immigration Bureau is rolling out a new mobile application — THIM (Thailand Immigration Mobile Application) — that allows foreign nationals to register their arrival details prior to boarding their flight, with the aim of facilitating immigration procedures for entering and staying in Thailand.

Key Features

THIM offers a faster, more user-friendly alternative for travelers to submit arrival information. The registration process can typically be completed in under three minutes. The platform also supports group submissions, enabling information for up to 10 travelers to be entered and processed simultaneously — a feature that significantly reduces administrative burden for tour groups and families. Compared to the existing web-based system, which is often slower and less intuitive, THIM provides a considerably more convenient experience for inbound travelers.

What’s Next: THIM as a Super Application

Looking ahead, THIM is expected to evolve into a comprehensive “Super Application” serving all categories of foreign nationals in Thailand — including short-term visitors, long-term residents, and permanent residents. The platform will function as a one-stop service for immigration-related matters, enabling users to request official immigration documents, submit applications along with supporting materials, and communicate directly with immigration officers online. This digital-first approach is intended to reduce the need for in-person visits to Immigration Bureau offices.

Additional planned features include an appointment scheduling system to help minimize travel time and waiting periods, as well as an emergency assistance function that will allow registered users to contact the Tourist Police through the application around the clock, 24 hours a day, seven days a week.

Language Support

During the initial launch phase, THIM supports four languages: English, Russian, Japanese, and Chinese, reflecting Thailand’s largest inbound visitor demographics. Future updates are expected to extend language support to at least 15 additional languages to better accommodate travelers from a broader range of countries.

Availability and Current Status

THIM is currently available for download on both iOS and Android devices. At present, users can access the Thailand Digital Arrival Card (TDAC) registration system through the application. Additional features and services will be introduced in subsequent updates, with a full platform launch anticipated in August 2026.

Key Takeaways

THIM is available now on iOS and Android in a trial phase, with a full launch expected in August 2026.

Thailand’s Immigration Bureau is introducing THIM, a mobile application enabling foreign nationals to register arrival details before their flight.

Registration takes under three minutes, with support for group submissions of up to 10 travelers simultaneously.

Future plans include expanding THIM into a Super Application, incorporating document requests, visa applications, officer appointments, and 24/7 Tourist Police access.

The application currently supports four languages: English, Russian, Japanese, and Chinese.

Author: Panisa Suwanmatajarn, Managing Partner.

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Consumer and Platform Accountability: Increasing Scrutiny of Digital Intermediaries in Scam-Related Advertising

Recent litigation involving a major online platform in connection with alleged scam-related advertising has drawn renewed attention to the role of digital intermediaries in protecting consumers from online fraud. While the dispute itself remains subject to judicial determination, it highlights broader policy and regulatory questions regarding the responsibilities of digital platforms that facilitate advertising and online commercial activities.

Although Thailand has not yet adopted a comprehensive platform accountability framework specifically addressing scam-related advertisements, the issue aligns with wider regulatory efforts to combat technology-enabled fraud, strengthen consumer protection, and enhance trust in the digital economy. As online scams continue to generate substantial consumer losses, digital platforms may face increasing expectations from regulators, policymakers, and the public to take a more proactive role in preventing harm.

Existing Legal Framework:

Consumer Protection Law

The Consumer Protection Act B.E. 2522 (1979) serves as Thailand’s principal legislation governing unfair and misleading advertising practices. The Act prohibits advertisements that are false, exaggerated, misleading, or otherwise likely to cause consumer misunderstanding.

Traditionally, enforcement efforts have focused on advertisers themselves. However, as digital advertising ecosystems become increasingly complex, questions have emerged regarding whether platform operators that facilitate the dissemination of advertisements should assume greater responsibility for preventing fraudulent or deceptive content from reaching consumers.

While the Act does not currently establish explicit platform liability for scam-related advertisements, its consumer protection objectives may influence future regulatory approaches to digital platform governance.

Technology Crime Prevention Framework

Thailand has significantly expanded its legal framework for combating online fraud through the Emergency Decree on Measures for the Prevention and Suppression of Technology Crimes B.E. 2566 (2023), as amended.

The Emergency Decree reflects a broader policy shift toward preventive measures and imposes obligations on various stakeholders within the digital ecosystem to cooperate in addressing technology-related crimes. Although the current framework primarily focuses on financial institutions, telecommunications providers, and other relevant service providers, it demonstrates an increasing willingness by policymakers to require private-sector participants to implement measures aimed at reducing fraud risks.

This regulatory approach may provide insight into how future obligations for digital platforms could evolve.

Computer Crime Law

The Computer Crime Act B.E. 2550 (2007), as amended, establishes legal mechanisms for addressing unlawful online activities and removing illegal content from computer systems.

Although the Act was not specifically designed to regulate online advertising, it forms part of the broader legal framework governing intermediary conduct and online content management. The Act illustrates Thailand’s recognition that service providers play an important role in preventing and addressing harmful online activities.

As digital risks continue to evolve, policymakers may look to existing intermediary-related principles when considering future platform governance measures.

Emerging Platform Accountability Trends:

Recent developments suggest that regulators are increasingly focused not only on the perpetrators of online scams but also on the systems and mechanisms that enable fraudulent advertisements to reach consumers.

Several themes are likely to influence future policy discussions.

Enhanced Advertiser Verification

One potential area of reform involves stronger verification requirements for advertisers.

Regulators may increasingly expect platforms to implement robust due diligence procedures before allowing advertisements to be published, particularly in high-risk sectors such as financial services, investments, health products, and online commerce.

Possible measures may include:

  • Verification of advertiser identity;
  • Verification of business registration status;
  • Confirmation of regulatory licenses where applicable; and
  • Risk-based screening of advertising accounts.

Such requirements could reduce opportunities for anonymous or fraudulent actors to exploit digital advertising systems.

Proactive Monitoring and Detection

Another emerging trend involves the expectation that platforms implement systems capable of identifying potentially fraudulent activities before consumer harm occurs.

This may include:

  • Automated monitoring of advertising content;
  • Detection of suspicious advertising patterns;
  • Escalation procedures for high-risk advertisements; and
  • Internal fraud-prevention mechanisms supported by technology and human review.

Although such obligations may increase compliance costs, regulators may increasingly view proactive monitoring as a necessary component of responsible platform governance.

Notice-and-Takedown Mechanisms

Future regulatory initiatives may place greater emphasis on the speed and effectiveness of platform responses to scam-related content.

Platforms may be expected to maintain clear procedures for:

  • Receiving consumer complaints;
  • Reviewing reports of fraudulent advertisements;
  • Removing harmful content within reasonable timeframes; and
  • Preserving evidence for law enforcement and regulatory investigations.

Effective notice-and-takedown systems are increasingly regarded as a key safeguard in digital marketplaces.

Transparency and Accountability Measures

Policymakers may also consider imposing enhanced transparency requirements on digital platforms.

Potential measures could include:

  • Disclosure of advertiser information;
  • Publication of platform enforcement policies;
  • Transparency reporting regarding fraudulent advertisements; and
  • Cooperation and reporting obligations involving regulatory authorities.

Such measures seek to improve accountability while strengthening consumer confidence in online transactions.

Potential Regulatory Developments:

At present, Thailand has not enacted legislation imposing comprehensive liability on digital platforms for scam-related advertisements. Nevertheless, several factors suggest that further regulatory developments remain possible.

First, technology-enabled fraud continues to be a significant public policy concern. Second, regulators increasingly favor preventive approaches that require cooperation from private-sector participants. Third, digital platforms occupy a central role in the dissemination of commercial information and consumer engagement.

As a result, future initiatives could emerge through:

  • Amendments to consumer protection legislations;
  • Sector-specific digital platform regulations;
  • Additional anti-fraud compliance requirements;
  • Regulatory guidelines issued by relevant authorities; or
  • Multi-agency cooperation frameworks addressing online fraud.

Businesses operating digital platforms should therefore closely monitor regulatory developments and assess whether existing governance frameworks remain sufficient in light of evolving expectations.

Implications for Platform Operators:

Even in the absence of immediate legislative reform, platform operators may benefit from reviewing their existing compliance and risk-management practices.

Areas for consideration include:

  • Advertiser onboarding procedures;
  • Fraud detection and monitoring capabilities;
  • Internal complaint management systems;
  • Content moderation policies;
  • Record retention practices; and
  • Cooperation protocols with regulators and law enforcement authorities.

Organizations that adopt robust governance measures at an early stage may be better positioned to manage regulatory risk and maintain consumer trust as expectations continue to evolve.

Key Takeaways:

  • Recent litigation involving a major online platform has intensified discussion regarding the role of digital intermediaries in preventing scam-related advertising.
  • Thailand currently does not impose comprehensive statutory liability on digital platforms for fraudulent advertisements, but regulatory expectations are evolving.
  • Existing laws, including the Consumer Protection Act, the Emergency Decree on Measures for the Prevention and Suppression of Technology Crimes, and the Computer Crime Act, demonstrate increasing policy emphasis on consumer protection and fraud prevention.
  • Future regulatory initiatives may focus on advertiser verification, proactive monitoring, notice-and-takedown procedures, and transparency obligations.

Digital platform operators should proactively assess their governance and compliance frameworks in anticipation of increasing regulatory scrutiny and consumer protection expectations.

Author: Panisa Suwanmatajarn, Managing Partner.

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Government Agencies Accelerate Work-from-Home Policies Through e-Office and Digital Government Initiatives

Introduction:

The public sector is continuing its digital transformation through expanded adoption of work-from-home (WFH) arrangements supported by electronic office systems and digital government infrastructure. In 2026, the government intensified these efforts as part of broader energy conservation measures while simultaneously advancing long-term public sector digitalization objectives.

Recent government directives signal a significant policy shift toward greater reliance on electronic document management, digital signatures, online collaboration tools, and cloud-based administrative platforms. Government agencies are therefore increasingly required to review and update internal regulations, operational procedures, and workforce management policies to support remote working arrangements without compromising public services, information security, or administrative accountability.

Cabinet Resolution Promoting Work-from-Home Arrangements:

On 10 March 2026, the Cabinet resolved that government agencies and state enterprises should immediately implement work-from-home measures for functions that do not directly involve public-facing services. The policy was introduced primarily as a response to energy concerns and rising fuel consumption, while also supporting broader governmental objectives relating to digital government development.

The Ministry of Digital Economy and Society (MDES) subsequently announced support for the policy through expanded utilization of the government’s e-Office platform and related digital systems. The initiative reflects the government’s continuing commitment to reducing paper-based administrative processes and promoting flexible work arrangements across the public sector.

e-Office as the Foundation for Remote Government Operations:

The e-Office platform serves as a centralized electronic office management system designed to enable government officials to perform their duties remotely while maintaining official administrative processes.

Core functionalities include:

  • Electronic document management (e-Document);
  • Digital workflow and document routing;
  • Electronic correspondence and records management;
  • Digital signature capabilities;
  • Online meeting and collaboration tools;
  • Task monitoring and reporting systems; and
  • Time attendance and work tracking functions through integrated Timesheet applications.

The system allows government personnel to access official documents, approve transactions, monitor workflow progress, and collaborate with colleagues from remote locations while preserving audit trails and administrative transparency.

According to government reports, more than 160 government agencies and local administrative organizations have already adopted the platform. Agencies may also utilize the Government Data Center and Cloud Service (GDCC) infrastructure to deploy e-Office solutions without incurring additional licensing costs.

Regulatory and Governance Considerations:

While technology enables remote work, successful implementation requires corresponding adjustments to internal regulations and administrative procedures.

Government agencies adopting WFH arrangements should review and update internal rules governing:

Performance Management and Supervision

Traditional attendance-based supervision may no longer be suitable in a remote work environment. Agencies should establish clear frameworks for:

  • Work assignment and delegation;
  • Deliverable-based performance measurement;
  • Reporting obligations;
  • Monitoring mechanisms; and
  • Accountability requirements for remote personnel.

The emphasis should shift from physical presence toward measurable outputs and documented performance indicators.

Working Hours and Attendance Controls

Although work may be performed remotely, agencies remain responsible for ensuring compliance with official working-hour requirements.

Appropriate measures may include:

  • Electronic attendance recording;
  • Timesheet systems;
  • Activity reporting requirements;
  • System log monitoring; and
  • Supervisor approval procedures.

Clear policies should be established regarding availability, response times, and communication expectations during official working hours.

Information Security and Data Protection

Remote access to government systems introduces cybersecurity and information security risks.

Agencies should establish policies addressing:

  • Secure remote access protocols;
  • Authentication requirements;
  • Use of government-issued devices;
  • Confidentiality obligations;
  • Storage and transmission of official information; and
  • Incident reporting procedures.

Particular attention should be given to sensitive government information and compliance with applicable cybersecurity and data governance requirements.

Continuity of Public Services

A fundamental principle of the government’s WFH policy is that public services must not be adversely affected.

Accordingly, agencies should identify:

  • Functions suitable for remote work;
  • Essential on-site operations;
  • Minimum staffing requirements;
  • Public service continuity plans; and
  • Escalation procedures for urgent matters.

Several agencies have adopted rotational work arrangements to balance operational efficiency with service delivery obligations.

Sector-Specific Implementation

Certain government sectors have already introduced tailored WFH frameworks.

For example, the Ministry of Public Health has implemented rotational remote-working arrangements designed to maintain uninterrupted healthcare services while reducing on-site staffing levels where operationally feasible.

Such approaches demonstrate that WFH implementation is not intended as a uniform solution across all agencies but rather as a flexible framework that must be adapted according to each organization’s operational requirements and public service responsibilities.

Implications for Government Agencies:

The 2026 policy initiative reflects a broader transition from temporary remote working measures toward institutionalized digital government operations.

Government agencies should therefore consider:

  • Updating internal regulations to formally recognize remote work arrangements;
  • Expanding deployment of e-Office and digital workflow systems;
  • Establishing objective performance evaluation frameworks;
  • Enhancing cybersecurity and data governance controls;
  • Developing clear WFH eligibility criteria; and
  • Ensuring uninterrupted public service delivery.

As digital government infrastructure continues to mature, WFH arrangements are likely to become a permanent component of public sector administration rather than merely an emergency or temporary measure.

Key Takeaways:

  • The Cabinet has directed government agencies and state enterprises to implement WFH arrangements for non-public-facing functions as part of energy conservation and digital transformation initiatives.
  • The government’s e-Office platform serves as a key technological enabler, providing electronic document management, digital signatures, workflow automation, online collaboration, and work tracking capabilities.
  • Agencies should revise internal regulations governing performance management, attendance monitoring, information security, and service continuity to accommodate remote work environments.
  • Cybersecurity, data protection, and accountability remain critical compliance considerations when implementing WFH policies.

The 2026 initiative represents a significant step toward long-term digital government operations and greater institutional adoption of flexible working arrangements within the public sector.

Author: Panisa Suwanmatajarn, Managing Partner.

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NBTC’s Third Broadcasting and Television Master Plan (2026–2030): Expanded Oversight of OTT Platforms and the Future of Digital Broadcasting

Introduction:

Thailand’s National Broadcasting and Telecommunications Commission (NBTC) is currently conducting public consultations on the Draft Third Broadcasting and Television Master Plan (2026–2030), which is intended to serve as the principal policy framework for the broadcasting sector over the next five years.

The draft plan reflects the NBTC’s recognition that the media landscape has undergone significant transformation as audiences increasingly consume content through online platforms and streaming services rather than traditional broadcasting channels. In response, the NBTC is proposing a broader regulatory approach that extends beyond conventional television and radio operators to encompass digital content ecosystems, online media platforms, and emerging forms of content distribution.

The proposed framework also addresses growing concerns regarding misinformation, the competitiveness of domestic digital platforms, and the future of the digital television sector as existing licenses approach expiry.

Greater Focus on OTT and Online Media Platforms:

A key feature of the draft plan is the NBTC’s intention to strengthen oversight of over-the-top (OTT) services and online media platforms.

The traditional broadcasting regulatory framework was designed primarily for licensed television and radio operators. However, the rapid growth of streaming platforms, social media services, and other online content providers has significantly altered viewing behavior and challenged the effectiveness of existing regulatory models.

The draft plan therefore contemplates the development of regulatory mechanisms appropriate for the digital environment, including measures aimed at enhancing accountability and governance of online content distribution platforms. While the specific regulatory tools remain under consideration, the proposal signals the NBTC’s intention to play a more active role in overseeing digital media services that reach Thai audiences.

This policy direction reflects a broader recognition that online platforms have become an integral part of the communications ecosystem and increasingly influence public discourse, information consumption, and media competition.

Measures to Combat Fake News and Harmful Content:

The draft plan identifies misinformation, disinformation, and content that may create social division or public disorder as important regulatory concerns.

The NBTC proposes closer cooperation with relevant government agencies, media organizations, and digital platform operators to strengthen mechanisms for monitoring and addressing false or misleading information disseminated through broadcasting and online channels.

Particular attention is expected to be given to content that may affect public safety, national security, social harmony, or public confidence in state institutions. The draft plan also contemplates the development of systems that promote responsible media practices and improve public awareness regarding information verification.

Although detailed implementation measures have not yet been announced, platform operators and content providers should anticipate increased regulatory attention to content governance and compliance frameworks in the coming years.

Promotion of Domestic Digital Platforms and Local Content:

Another important objective of the draft plan is the promotion of domestic digital platforms and the strengthening of Thailand’s content industry.

The NBTC has expressed support for initiatives that enhance the competitiveness of local media operators and encourage the development of platforms capable of serving Thai audiences while promoting domestic content creation.

The draft plan also seeks to encourage innovation in broadcasting technologies and digital content distribution. Such initiatives are intended to support sustainable growth within the media sector and reduce structural disadvantages faced by local operators in competing with large international digital platforms.

This policy direction aligns with broader national objectives relating to digital economy development and technological self-reliance.

Preparing for the Post-2029 Digital Television Landscape:

The draft plan also addresses the future of the digital television industry as existing digital television licenses are expected to expire around 2029.

Since the transition to digital broadcasting, television operators have faced substantial economic pressures arising from changing consumer behavior, fragmentation of audiences, and increasing competition from online media services. These developments have raised questions regarding the long-term sustainability of the current broadcasting model.

In response, the NBTC intends to develop a roadmap for the future of digital television. The roadmap is expected to examine the role of terrestrial broadcasting in an increasingly digital environment, potential adjustments to licensing frameworks, spectrum management strategies, and measures to support industry sustainability.

The outcome of these discussions is likely to influence the structure of Thailand’s broadcasting sector for years to come and may have significant implications for broadcasters, investors, content producers, and telecommunications operators.

Implications for Businesses:

The draft master plan demonstrates a regulatory shift towards a more integrated approach to media governance, where distinctions between traditional broadcasting services and online content platforms are becoming less pronounced.

Businesses that may be affected by future policy developments include:

  • OTT and streaming service providers;
  • social media and content-sharing platforms;
  • broadcasters and television operators;
  • telecommunications service providers;
  • digital advertising businesses; and
  • content creators and media companies.

Although the draft plan does not itself create immediate legal obligations, it provides a clear indication of the NBTC’s regulatory priorities and may serve as the foundation for future regulations, licensing requirements, and policy initiatives affecting the digital media sector.

Stakeholders should therefore monitor the consultation process and forthcoming regulatory developments closely.

Outlook:

The Draft Third Broadcasting and Television Master Plan (2026–2030) reflects the NBTC’s effort to modernize the regulatory framework governing Thailand’s broadcasting and media sectors in response to technological change and evolving consumer behavior.

By focusing on OTT regulation, combating misinformation, promoting domestic digital platforms, and preparing for the expiry of digital television licenses, the NBTC is signaling a broader and more proactive approach to media regulation in the digital era.

While many of the proposed measures remain at the policy stage, the draft plan provides important insight into the direction of future regulatory developments and the issues that are likely to shape Thailand’s communications and media landscape over the coming years.

Key Takeaways:

  • The NBTC is consulting on the Draft Third Broadcasting and Television Master Plan (2026–2030), which will guide broadcasting policy over the next five years.
  • Regulatory attention is increasingly shifting towards OTT services and online media platforms as digital content consumption continues to grow.
  • The draft plan proposes stronger measures to address fake news, disinformation, and other forms of harmful online content.
  • The NBTC seeks to promote domestic digital platforms and strengthen the competitiveness of Thailand’s content industry.
  • A roadmap is being developed to address the future of digital television ahead of the expected expiry of digital TV licenses around 2029.

Although no immediate legal obligations arise from the draft plan, businesses should monitor future regulatory initiatives that may affect platform governance, content regulation, and broadcasting operations.

Author: Panisa Suwanmatajarn, Managing Partner.

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