You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

January 30, 2026

Key Takeaways from Thailand’s Data Privacy Day 2026

Subscribe to Updates

Thailand’s Data Privacy Day 2026, hosted by the Office of the Personal Data Protection Committee (PDPC), underscored the country’s commitment to strengthening personal data protection, advancing regulatory maturity, and preparing organizations for the next phase of PDPA enforcement. The event marked a clear shift from policy-level compliance toward “Privacy in Action,” signaling that operational readiness and real-world implementation are now priorities.

The Office of the PDPC also emphasized that data protection is now a national economic enabler that supports digital trust, competitiveness, and sustainable growth, not just a compliance obligation.

The following insights summarize the key takeaways from the Data Privacy Day 2026 event.

PDPA in Real Life: What Happens to Your Data Today

The Office of the PDPC provided concrete data on enforcement trends and real-world compliance issues facing organizations across Thailand.

Complaints and trends. The Office of the PDPC’s Personal Data Protection Act (PDPA) Center recorded 2,672 PDPA-related complaints as of January 2026, with the highest volumes involving failure to comply with the data minimization principle, collection without lawful basis, and use and disclosure without lawful basis.

Administrative penalties. Several administrative penalties have been imposed on data controllers and data processors across various sectors, including government, healthcare, retail, SMEs and e-commerce, ranging from tens of thousands to several million baht. Most violations stemmed from weak security measures, failure to notify data breaches within the required timeline, absence of a data protection officer (DPO) when required, and noncompliance with governance requirements such as the Record of Processing Activities (ROPA) and data processing agreements with data processors.

Case studies. The Office of the PDPC highlighted specific examples of violations:

  • Hospitals misused personal data for purposes beyond their intended scope (e.g., using personal data collected for providing medical services to send birthday cards)
  • Vendors compromised systems due to inadequate password protocols and the absence of firewalls, resulting in unauthorized access

AI and Privacy: Regulatory Expectations in the Emerging Landscape

Thailand is moving toward a clearer regulatory framework for AI, with the AI Act currently in draft form. While the PDPA does not regulate AI itself, it governs personal data used within AI systems, meaning organizations, not the AI, remain fully accountable for any misuse or unlawful processing of personal data.

Key expectations highlighted for businesses include:

  • The use of AI is allowed, but accountability remains fundamental. Organizations must take full responsibility for how personal data is processed through AI systems.
  • Strong resource and access governance is necessary. Organizations must prevent uncontrolled AI usage and avoid over-sharing of data through proper data classification to restrict AI access to relevant datasets.
  • AI deployment may trigger obligations under other laws. While there is currently no specific law regulating the use of AI, AI deployment may trigger obligations under civil and commercial law, road traffic laws in relation to autonomous systems, and other regulations, reinforcing the need for comprehensive risk assessment.
  • Alignment with forthcoming guidelines. The Office of the PDPC is currently developing practical guidelines on personal data protection in the use and development of AI technologies. Organizations should align AI use with these forthcoming guidelines aimed at supporting safe innovation while adhering to PDPA requirements.

International Cooperation and Cross-Border Transfers

Efforts continue to advance Thailand’s participation in the Global Cross-Border Privacy Rules (CBPR) and strengthen alignment with regional data-protection frameworks. Organizations operating across borders should expect tighter scrutiny of cross-border transfers, including more rigorous requirements for risk assessments and transfer impact analyses to ensure compliance in multi-jurisdictional environments.

Data Breach Incident Monitoring

The PDPC Eagle Eye, a division within the Office of the PDPC, has launched advanced tools such as the PDPC Eagle Eye Crawler, which enables continuous URL access and facilitates 24-hour monitoring of data breach incidents. Additionally, the PDPC Eagle Eye shared details about their plan to send inspection letters to organizations for advisory reasons.

Privacy Maturity Model and Privacy Index

The Office of the PDPC introduced new tools to help organizations assess and improve their data protection practices.

The Privacy Maturity Model assesses an organization’s readiness for personal data protection. The Privacy Index measures data protection levels using both privacy data (such as survey results and Privacy Maturity Model scores) and secondary data (like public information), giving organizations an overview of their privacy risk management capabilities.

Information derived from the Privacy Maturity Model and Privacy Index can then be used toward obtaining the Personal Data Protection Certification Mark, an upcoming certification program to recognize compliant organizations.

Outlook for 2026

Based on the Office of the PDPC’s roadmap and expert discussions during the Data Privacy Day event, organizations should expect several key developments in the coming year:

  • Data privacy must go beyond policy and legal compliance to practical implementation in all systems and operations.
  • Heightened enforcement, driven by expanded automated surveillance capabilities such as the PDPC Eagle Eye Crawler and the rollout of inspection letters for advisory purposes.
  • Stronger national PDPA infrastructure, with continued development of PDPA Centers and Trustmark certification.
  • Closer alignment with international privacy standards, supporting Thailand’s role in cross-border digital trade and strengthened mechanisms to support trusted cross-border data flows.
  • Increased regulatory attention on AI governance, with forthcoming guidance to ensure AI use complies with data-protection principles and standards.
  • A nationwide push toward a “new data-ethics culture” emphasizing legal compliance, incident prevention, organizational cooperation, and the use of technology to strengthen national and public trust, anchored in the national goal of improving data security, attracting investments, and enhancing quality of life.

Organizations should treat 2026 as a critical year for operationalizing privacy compliance, building robust governance frameworks, and preparing for more active regulatory oversight. The shift from policy to practice means that demonstrable implementation, not just documentation, will be the standard by which compliance is measured.

Related Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

March 5, 2026
Thailand’s Securities and Exchange Commission (SEC) has filed a criminal complaint against a licensed digital asset broker, its overseas trading platform, and its executives for allegedly operating an unlicensed digital asset exchange targeting Thai customers. The case marks an escalation in the SEC’s enforcement efforts against unlicensed offshore platforms that attempt to serve Thai users through local licensed entities. Criminal Complaint On February 20, 2026, the SEC filed a criminal complaint with the Economic Crime Suppression Division against a local licensed digital asset broker, its overseas global trading platform, and its executives. The SEC alleges that the parties violated the Digital Asset Business Emergency Decree B.E. 2561 (2018) by cooperatively operating a digital asset exchange business on a cross-border basis since 2023 without the required SEC license. According to the SEC, the local broker promoted the overseas platform’s services to the public through Thai-language posts on social media channels, with services available exclusively to customers residing in Thailand. Access to the global platform was provided through the local broker’s website and mobile application. Customers who registered for the local broker’s services were automatically granted access to the global platform without having to undergo a separate identity verification process. The SEC also found that the local broker provided back-office system support services to the global platform. The SEC considers these activities to constitute joint operation of an unlicensed digital asset exchange. The former executives of the local broker are being held liable as the responsible persons during the relevant period. The SEC emphasized that the complaint initiates the criminal process, and the decision to prosecute or convict the accused parties will ultimately be made by law enforcement authorities and the criminal courts. Platform Blocking The SEC has also coordinated with the Ministry of Digital Economy and Society to block public
Read More
February 27, 2026
The Bank of Thailand (BOT) has officially implemented a new regulatory framework supervising systemically important retail payment systems (SIRPS), effective February 21, 2026, with PromptPay being the first payment system designated as a SIRPS. Under this new set of regulations, the BOT may designate payment systems under the Payment Systems Act B.E. 2560 (2017) as SIRPSs based on quantitative and qualitative assessments. Once a system is designated as a SIRPS, the operator becomes subject to expanded supervisory obligations beyond the general requirements of the Payment Systems Act. Enhanced Supervisory Requirements SIRPS operators must comply with a heightened supervisory regime across three key areas, outlined below. 1. Governance SIRPS operators must maintain robust and transparent governance structures, including: Balanced board composition, with at least one-third of the board comprising independent directors who represent stakeholders in the system (such as payment service providers, consumers, and experts). Independent directors may serve for no more than two consecutive terms. Subcommittees to assist the board in overseeing compliance, policy implementation, and operational strategy. Clear separation between executives responsible for risk and information security and those overseeing day-to-day business operations. Risk Management and System SecuritySIRPS operators must implement comprehensive risk management frameworks, including: Clear service agreements between the SIRPS operator and its direct participants (payment service providers who connect directly to the SIRPS), defining roles and responsibilities among stakeholders. These agreements must include obligations for direct SIRPS participants to supervise any indirect participants they onboard to ensure compliance with service agreements and business rules. A business continuity plan covering both IT and non-IT aspects, with annual review. The SIRPS must target service availability comparable to international payment infrastructures, including the ability to recover operations within two hours of a disruption and to maintain scalable operational capacity. Tools and controls to monitor and manage material or
Read More
February 26, 2026
Thailand is preparing to offer new tools for intellectual property enforcement as the Electronic Transactions Development Agency (ETDA) recently released for public consultation a draft notification requiring social media platforms to verify user identities and conduct know-your-customer (KYC) checks on advertisers. The draft Notification of the Electronic Transactions Commission on Measures to Prevent Technological Crimes for Social Media Service Providers, which is to be issued under the Emergency Decree on Measures for the Prevention and Suppression of Technological Crimes B.E. 2566 (2023), as amended in 2025, primarily aims to combat online fraud and technology-related crimes. However, its new obligations also provide IP owners with valuable tools to identify anonymous infringers. Key Regulatory Mandates The draft notification imposes several verification requirements on social media platforms operating in Thailand. These requirements also strengthen IP rights holders’ ability to identify anonymous infringers, as platforms must: Verify user identities through registered phone numbers and link all accounts to verifiable identities. Conduct KYC checks on advertisers, including individuals, companies, and any third-party payers. Perform heightened identity checks for high-risk or repeat offenders before publishing advertisements. Promptly remove content flagged by the Anti-Technology Crime Division and prescreen advertisements for prohibited or high-risk content. How IP Owners Can Use This Notification for Enforcement The phone number–based verification requirement enables IP owners to work more effectively with enforcement authorities in tracing individuals or entities responsible for infringing content. The comprehensive advertiser KYC obligations, including mandatory disclosure of third-party payment sources, create a clear audit trail even when bad actors attempt to obscure their identity through intermediaries or shell accounts. This traceability is essential for pursuing damages and dismantling organized counterfeit operations. The ETDA is now considering adjustments to the draft notification after receiving comments during the public consultation period, which ended on February 2, 2026. Following finalization
Read More
February 23, 2026
On February 17, 2026, Thailand’s Personal Data Protection Committee (PDPC) released its draft Guidelines on Personal Data Protection in the Development and Use of Artificial Intelligence. The draft guidelines, which translate data controller and data processor compliance obligations under the Personal Data Protection Act (PDPA) into measures tailored to AI development and deployment, are open for public comment until February 25, 2026. At a public hearing session on the draft guidelines held on February 19, the PDPC emphasized that its approach to AI is not to hinder innovation but to develop practical guidance supporting safe deployment while ensuring data protection. Although the guidelines are not legally binding, they indicate the regulator’s expectations and the likely direction of interpretation and enforcement. Scope of Application and Role of Stakeholders The guidelines will apply to all data controllers and data processors in Thailand, and to overseas data controllers and data processors whose data processing falls within the extraterritorial scope of the PDPA. The draft guidelines distinguish the roles of parties involved in AI deployment. Users of AI who determine the purpose of use and designate the input data, and retain outputs generated by the AI, are considered data controllers. In contrast, AI model providers or system integrators that process personal data under the instructions of the data controller are generally regarded as data processors. However, if an AI model provider utilizes user data for its own purposes, such as model fine-tuning or training, it may instead be classified as a data controller. Key Obligations for AI Data Collection and Use The basic principles of data processing under the PDPA must be maintained throughout the AI implementation lifecycle, from design to decommissioning, emphasizing accountability and privacy-by-design principles. The draft guidelines also stipulate the following: Data processing agreements (DPAs) should include model training prohibitions,
Read More