Thailand’s Electronic Transactions Development Agency (ETDA) has released a revised draft Electronic Transactions Act (ETA) for public hearing from May 12, 2026, to June 15, 2026. This is not merely an amendment to certain provisions of the current ETA, but a comprehensive redrafting of the entire act. The revised draft ETA introduces several significant changes from the current framework, with practical implications for businesses operating in Thailand. Unified Coverage of Public and Private Sectors The current law segregates government transactions into a separate chapter with distinct rules. The draft ETA eliminates this division, defining “transaction” to encompass civil and commercial juristic acts as well as administrative procedures, administrative contracts, and other acts of government agencies. Enhanced E-Signature Definition The definition of “electronic signature” is broadened to expressly include biometric data and refocused on identifying the signatory and demonstrating intent regarding the content of the electronic data. Shift in Burden of Proof When a party challenges the reliability of electronic data created using a “trusted electronic method” or a method prescribed by the ETDA, the burden of proof and the cost of proving unreliability shifts to the challenger. Introduction of New Digital Method Concepts The draft ETA introduces several new digital method concepts that are not currently recognized under the existing ETA framework. These include: Electronic timestamping (e-timestamp) Electronic registered delivery Electronic company seals Electronic stamp duty compliance Electronic identity authentication and verification Electronic transferable records (electronic bills of lading, promissory notes, and similar negotiable instruments) Recognition of Automated Systems and Electronic Contracting The draft ETA expressly recognizes the legal validity and enforceability of contracts formed through automated systems, including contracts concluded entirely between automated systems or between an automated system and a person. A party may not deny the binding effect of such contracts solely because no human review

In March 2026, the Intellectual Property Office of Vietnam (IP Office) issued a decision refusing a trademark application after considering an opposition based primarily on copyright grounds. The outcome is noteworthy because the foreign brand owner had neither trademark registrations nor applications in Vietnam at the time the opposition was filed, and the IP Office has historically applied a stringent approach to oppositions relying on copyright. The Opposition Maurten is a well-known Swedish sports nutrition brand recognized globally for its innovative hydrogel technology, which is designed to help endurance athletes fuel more effectively without gastrointestinal discomfort. The brand’s distinctive logo is characterized by clean lines and a bold black-and-white color scheme, and has long been associated with the company’s performance products. The brand’s logo is displayed above. An identical mark was filed for registration by a Vietnamese trademark squatter. In 2023, a Vietnamese individual filed an application for registration of an identical mark (Application No. 4-2023-38668), a practice commonly observed in Vietnam as trademark squatting. The brand owner engaged Tilleke & Gibbins to assist with strategy and filing an opposition to the mark. At the time, Maurten had no trademark rights or meaningful use in Vietnam, and global marketing data showed only modest figures without any local presence. Thus, to convince the IP Office to refuse the squatter’s application, instead of relying on trademark rights or use evidence, the opposition strategy centered on the copyright protection of the logo itself, as copyright arises automatically in Vietnam upon creation of the work and does not require registration. (It is worth noting, however, that the IP Office has traditionally been cautious in accepting copyright as a basis for refusing trademark applications.) On September 24, 2024, an opposition was filed on three main grounds: confusing similarity, copyright infringement of the artistic work,

For multinational franchisors operating in Thailand, a key risk after franchise termination is that former outlets may continue operating in ways that could easily mislead consumers into believing they remain within the authorized network. To justify such operations, former franchisees often argue that the termination was invalid or ineffective. As a result, these cases are often treated as contractual disputes, making it difficult for franchisors to obtain injunctive relief before a final judgment confirms that the termination was lawful. Franchisors face significant commercial and reputational harm during lengthy proceedings, including consumer confusion, disruption to franchise restructuring, and damage to brand reputation and customer trust. In an encouraging development, the Thai court in a 2025 case responded to the problem of unauthorized post-termination franchise operations by granting interim relief, recognizing broader brand and consumer harm, and awarding substantial damages, highlighting a successful litigation strategy of framing the dispute not merely as a contractual termination issue but as trademark infringement causing ongoing commercial injury. The Subway Case From December 2024 to mid-2025, an unauthorized “Subway®” franchise operation in Thailand attracted substantial public and media attention. Reports and online discussions about unauthorized Subway® stores circulated widely after complaints arose about food quality and customer experience at certain outlets that were allegedly operating after their franchise rights had expired. Because these stores continued to use Subway® trademarks, trade dress, and overall commercial appearance, many consumers were unable to distinguish them from authorized operations, resulting in reputational risks and customer confusion that affected the franchisor’s brand and franchise system in Thailand. Subway treated this matter with the utmost seriousness and moved promptly to protect its brand, franchise system, and customers. It filed a civil action with the IP&IT Court seeking a permanent injunction and damages. During the proceedings, the court granted a preliminary injunction

On April 28, 2026, the Central Bank of Myanmar (CBM) issued Notification No. 18/2026 introducing the new Foreign Remittance Business Regulations. The new regulations apply to companies intending to operate foreign remittance businesses in Myanmar that are not licensed banks, non-bank financial institutions, or other financial institutions. The regulations supersede and replace the previous regulatory framework governing foreign remittance businesses under CBM Notification No. 21/2019. While the overall structure remains familiar, the new regulations introduce more detailed requirements for licensing, operations, reporting, and compliance, with a stronger focus on transparency and regulatory oversight. Broader Licensing Requirements Under the new regulations, applicants must submit detailed business plans describing the use of information technology and mobile platforms, along with clear plans for handling remittances from workers abroad and resolving customer complaints. Financial Thresholds and Reporting Requirements The baseline financial thresholds remain unchanged. Licensees must maintain a security deposit of MMK 100 million in an escrow account, along with a separate revolving fund dedicated solely to remittance operations. The new regulations introduce more structured reporting obligations. Licensees are now required to submit daily remittance transaction data by the next business day before noon, in addition to monthly and periodic reporting requirements. Foreign bank account statements must also be submitted regularly, and licensees must provide updates on business operations every six months. Strengthened AML and CFT Framework The new regulations place a greater emphasis on anti-money laundering (AML) and counter financing of terrorism (CFT), with tighter controls over management changes. Any changes in shareholding, share transfers, or the appointment of key management personnel such as the managing director require prior approval from the CBM. Licensing Fees and Validity The new regulations increase licensing costs, while maintaining the same validity period of three years. The new regulations provide more detailed grounds for suspension and

On May 25, 2026, Vietnam’s Ministry of Health issued Circular No. 16/2026/TT-BYT governing free-of-charge medicine support programs for medical establishments (Circular 16). Circular 16 will take effect on July 10, 2026, replacing Circular No. 31/2018/TT-BYT, which currently regulates the same subject matter. Circular 16 introduces several significant changes compared to the existing legal framework. Removal of Prior Approval Requirement Under the current regulations, free-of-charge medicine support programs are divided into two categories: (1) entirely free-of-charge provision of medicines for all types of drugs and (2) partially free-of-charge provision applicable only to brand-name drugs under patent protection or drugs whose generic products with identical active ingredients and dosage forms are available in Vietnam. Under the current regulations, partially free-of-charge programs are subject to mandatory registration with the competent authority, while entirely free-of-charge programs could be implemented without prior approval. A key reform under Circular 16 is that it stipulates only entirely free-of-charge medicine support programs applicable to all types of medicines, thereby eliminating the partially free-of-charge category. In addition, free-of-charge medicine support programs may be carried out solely based on a written agreement between the pharmaceutical company and the medical establishment, without any requirement for prior approval from competent authorities prior to implementation. Written Agreement Requirements Circular 16 requires the pharmaceutical company and medical establishment to enter into a written agreement in accordance with a prescribed template. This agreement must include the following compulsory information: Information on the supported medicines Form of support (entirely free-of-charge provision to patients) Quantity of medicines provided Target patient groups and applicable indications Duration of the program Rights and obligations of each party Transitional provisions on the protection of patients’ rights upon completion of the program The agreement may contain other contents as agreed by the parties, provided that these do not contradict applicable laws.

Thailand’s Office of Insurance Commission (OIC) has opened a public hearing on proposed amendments to the OIC Notification on Criteria for Information Technology Risk Governance and Management for Life Insurance and Non-Life Insurance Companies B.E. 2563 (2020) via the centralized Law platform. The public consultation period runs from May 8, 2026, to June 9, 2026. The proposed amendments aim to elevate the IT risk governance and cybersecurity risk management framework to be more modern and aligned with international standards, with a focus on strengthening cyber resilience, enhancing the role of IT audits, and establishing data governance and data quality controls. The parties affected by these amendments include life insurance companies, non-life insurance companies, and external IT auditors. Key Changes Elevated Role of Board of Directors The proposed notification requires the company’s board of directors to oversee data governance, cybersecurity, and the responsible use of AI. Additionally, the board should include at least one director with IT knowledge or experience. Companies are also required to designate a head of security responsible for information security. The board’s duties are expanded to include oversight of data governance and AI usage, including establishing relevant policies and committees. Enhanced IT Security and Cybersecurity The revised notification consolidates the existing chapters on IT project management, IT security and cybersecurity to reduce redundancy, and introduces significant new measures. These include mandatory multi-factor authentication for material systems, enhanced data security measures such as data masking and data leakage prevention, security hardening requirements, web filtering, and mandatory vulnerability assessment and penetration testing at least annually. New requirements are also introduced for mobile application security, API security, and security measures for emerging technologies such as cloud computing and post quantum cryptography. The cybersecurity framework now encompasses identification, protection, detection, response, and recovery. The draft also introduces source code review

Vietnam’s AI regulatory framework has reached an important milestone. While the Law on Artificial Intelligence No. 134/2025/QH15 (AI Law) established the foundation for AI governance, many practical compliance requirements were left to implementing regulations. On April 30, 2026, the government issued Decree No. 142/2026/ND-CP (Decree 142), which took effect on May 1, 2026, and provides the first detailed guidance on the implementation of the AI Law. Although an official list of high-risk AI systems is still pending from the prime minister, Decree 142 provides valuable insight into how Vietnam’s risk-based AI regulatory framework will operate in practice. Risk Classification Framework The AI Law adopts a risk-based approach under which AI systems are classified as high-risk, medium-risk, or low-risk. Decree 142 builds on this framework by providing detailed guidance on how these classifications are determined. High-risk AI systems are determined based on factors such as (i) their potential impact on life, health, property, human rights, public interests, or national security; (ii) the sector in which they are deployed; and (iii) the scale of affected users or integration with critical infrastructure. The latest draft list of high-risk AI systems appears to follow these same principles. Medium-risk AI systems generally include systems that may mislead, influence, or manipulate users, particularly where users may not realize they are interacting with AI or AI-generated content. The focus is therefore on transparency and authenticity risks rather than broader societal or safety concerns. Low-risk AI systems are those that do not meet the criteria for either high-risk or medium-risk classification. Importantly, Decree 142 seeks to avoid over-classification. Certain systems may fall outside the high-risk or medium-risk regimes, including internal-use systems, office-support tools, technical editing applications, certain back-end processing systems, and AI systems used in artistic, gaming, cinematic, or other creative contexts. Providers must also review and

On May 11, 2026, Thailand’s Ministry of Social Development and Human Security released a draft Child Protection Act (“CPA”) for public review. The draft CPA would completely repeal and replace the current Child Protection Act B.E. 2546 (2003). This represents the most comprehensive overhaul of Thailand’s child protection framework in over two decades, reflecting the government’s stated objective of modernizing the law to address evolving social challenges—including those arising from digital technology—and to promote greater coordination among government agencies, local authorities, and civil society. The public review period closes on June 9, 2026. Key changes introduced by the draft CPA that could have significant implications for businesses, particularly online platform providers, media companies, and entities operating child-related services in Thailand, are set out below. Expanded Definition of “Child” Under the current CPA, a “child” is defined as a person under the age of 18, excluding those who have attained legal majority through marriage. The draft CPA removes the marriage exception entirely, broadening the scope of the law’s protections to include all individuals under 18 without exception. Replacement of “Abuse” with Broader Concept of “Violence” The current CPA uses the term “abuse/cruelty,” which covers acts causing harm to a child’s liberty, body, or mind; sexual offenses against children; and using children in harmful or immoral activities. The draft CPA replaces this with the broader concept of “violence,” which encompasses any act or omission causing harm to a child’s body, mind, or development; abandonment or neglect; improper exploitation; and sexual abuse. Notably, the new definition adds developmental harm as a recognized category of injury and captures all forms of misconduct regardless of the child’s consent. New Standalone Definition of Sexual Abuse, Including Online Conduct One of the most significant additions in the draft CPA is the introduction of a standalone definition