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January 8, 2026

Challenging Administrative Orders in Thailand: Why Timing Is Critical

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Doing business in Thailand means operating under a strict regulatory framework. From time to time, companies may receive unexpected administrative orders from government authorities that restrict their operations, impose new compliance obligations, or levy fines and penalties. When this happens, a business may challenge the order under Thailand’s administrative law system. The primary concern in pursuing administrative litigation is timing, as strict statutory deadlines apply and missing them can permanently affect a company’s rights.

First Step: Administrative Appeal

Many companies assume the first step is to immediately bring the matter before the Administrative Court to seek revocation or suspension of the order. Some even attempt to request an interim injunction to stop the order from taking effect. However, Thai law generally requires that the company first challenge the order through an administrative appeal with the same agency that issued it. Only after this process is complete can the matter be taken to court.

Seeking an interim injunction at this stage is also not possible. This is because Thai law does not allow a standalone application for an interim injunction; an injunction can only be requested together with the underlying complaint filed with the Administrative Court. Since a court complaint cannot be filed until the administrative appeal process has been exhausted, an injunction is usually not available at the early stage.

What Are the Timeframes for Administrative Appeal?

Thailand applies a two-stage administrative appeal process. The appeal must first be submitted to the same authority that issued the order, which will review its own decision. If that authority affirms its decision, the appeal is then escalated to the relevant higher authority for further review. In most cases, both stages must be completed before a company is allowed to proceed to court.

The timeframe for filing an administrative appeal is very strict. Generally, an appeal must be filed within fifteen days of the date the company receives the order. However, some laws provide different timelines. For example, the Building Control Act B.E. 2522 (1979) allows thirty days to challenge certain orders relating to license applications, while other legislation, like the Public Procurement and Supplies Administration Act B.E. 2560 (2017), requires challenges to public procurement bidding results to be filed within only seven days of the announcement. Businesses must therefore carefully check which law applies to their situation. Missing the deadline will usually mean losing the right to challenge the order altogether, including the right to bring the case before the Administrative Court. These deadlines cannot be extended, which often leaves companies with very little time to prepare their case.

Under the Administrative Procedure Act B.E. 2539 (1996), the reviewing authority must issue its decision within sixty days from receiving the administrative appeal, or within ninety days if it formally notifies an extension. If no decision is issued within the applicable review period, companies may proceed directly to the Administrative Court.

When Does the Court Filing Period Start?

If the administrative review process is completed and the outcome is unfavorable, companies generally have 90 days from receipt of the final review decision to file a complaint with the Administrative Court. If there is no decision on the administrative appeal within 60- or 90-day deadline described in the previous section, the 90-day court filing period will begin from the day the review period expires.

In some cases, specific laws provide different review periods for certain types of administrative matters. Where such laws apply, the ninety-day deadline to file a court complaint will be calculated based on the expiry of that specific review period. This makes it essential for companies to confirm the correct timeline that applies in each case.

Act Early to Protect Rights

Because administrative challenges in Thailand involve multiple procedural steps and strict timelines, companies should act promptly when an administrative order is received. Early consultation with experienced local administrative law counsel can help clarify the applicable procedures and deadlines, as well as strategic options. Any delay or misunderstanding of the timing requirements may seriously undermine, or completely eliminate, a company’s ability to challenge an improper or unlawful administrative order.

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