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November 7, 2023

Deadline Looms for Digital Platform Notification Requirement in Thailand

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Under Thailand’s Royal Decree on Digital Platform Services, domestic and in-scope overseas digital platform operators that are required to notify the Electronic Transactions Development Agency (ETDA) of their operations must do so by November 18, 2023 (or by August 20, 2024, for small or low-impact platforms).

This step is one of the essential requirements of the royal decree. Other key information on complying with the royal decree is as follows:

  • The royal decree aims to regulate the operation of “digital platform services,” which refers to the provision of electronic intermediary services that create a connection between consumers, merchants or businesses, or other types of users in order to create an electronic transaction in whole or in part, regardless of whether a service fee is charged.
  • The regulated digital platform services do not include digital platform services intended for offering the goods or services of a single digital platform service operator or an affiliated company that is an agent of the operator, irrespective of whether the goods or services are offered to third persons or to affiliated companies.
  • The royal decree has extraterritorial effect, whereby overseas operators targeting the Thailand market are subject to the royal decree if their services are accessible in Thailand.
  • Overseas operators are required to appoint a local coordinator in Thailand to coordinate with the ETDA.

Compliance and Enforcement

The ETDA released nine subordinate regulations under the royal decree; these took effect on August 21, 2023 (except for rules on platforms’ terms and conditions, which will take effect on January 3, 2024). Some important points on compliance and enforcement in the subordinate regulations, along with procedural guidance, are listed below.

  • The ETDA has been emphasizing that both domestic and overseas digital platform operators need to notify the ETDA of their operations within the specified timeline (i.e., by November 18, 2023).
  • Notifications must use the provided forms and must be accompanied by the required documents specified by the ETDA.
  • Notifications can be submitted through a notification portal developed by the ETDA for this purpose or directly at the ETDA office.
  • The ETDA maintains a list of the digital platforms that have already notified the ETDA on its website; the list currently exceeds 100 digital platforms from various industries and represents different types of businesses, such as AI services, marketplaces, advertising services, cloud services, gaming, and more.
  • So far, the ETDA has shown flexibility regarding compliance, but has also emphasized that it has the power to impose penalties and order business operators to comply with the law.
  • Noncompliance with the ETDA is subject to criminal fines and imprisonment.

Next Steps

Domestic and overseas operators of digital platforms need to assess their operations to determine the extent to which their digital platform service is subject to the royal decree. Once the assessment is completed, each operator should prepare the notification form and supporting documents and submit them to the ETDA before the applicable deadline. In addition, operators should complete a compliance checklist to ensure that the business is ready to comply with all other requirements of the royal decree and its subordinate laws.

For more information on compliance with the royal decree, or on any aspect of the requirements for digital platform services in Thailand, please contact Tilleke & Gibbins’ digital platform specialists Athistha (Nop) Chitranukroh at [email protected], Thammapas Chanpanich at [email protected], or Rada Lamsam at [email protected].

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