Thailand’s AI legislative framework took another step forward when the Office of the Consumer Protection Board (OCPB) issued a notification establishing guidelines for AI-generated advertising that may cause material misunderstanding about products or services. The notification, which is already in effect, was issued under the Consumer Protection Act B.E. 2522 (1979) and its amendments, which prohibit advertising that is unfair to consumers or may cause harm to society, including false or exaggerated statements and statements that may cause material misunderstanding about products or services. The notification addresses emerging advertising practices, including the use of images edited using software or AI to attract consumer interest or build credibility. The OCPB noted that such advertising may result in consumers misunderstanding the essential characteristics, condition, or usage of products, which violates consumer rights and causes damage. Key Requirements on AI-Generated or Digitally Manipulated Advertising Content For advertisements using still images or videos created or edited with software programs or AI tools that may cause the depicted product or service to differ from the actual product sold or service provided—which may cause misunderstanding regarding the condition, quality, quantity, or other essential aspects of the products or services—advertisers and business operators must comply with the following requirements: Prior authorization. Obtain approval from relevant regulatory authorities where required by law. Accurate representation. Ensure that the advertised size, quantity, volume, number, or composition matches the actual product or service being sold, whether in still images or videos. Mandatory AI disclosure labels. Display clear disclosures when AI or software is used to create or edit images, such as: “Real image or simulation edited using AI” “Photo from actual location or simulation edited using AI” “Photo from actual product or edited simulation” “Image created by AI” “Video created by AI” Clarity of disclosure. Ensure disclosures are clearly visible,

Thailand’s Ministry of Finance and Securities and Exchange Commission (SEC) have issued regulations broadening the criteria for determining who qualifies as a “major shareholder” of licensed securities and digital asset business operators. Under relevant SEC regulations, major shareholders of a regulated entity must obtain regulatory approval and undergo screening by the SEC. The revised framework introduces both shareholding-based and control-based tests to determine which shareholders require regulatory approval for a wider range of indirect ownership structures and de facto control. The Ministry of Finance notification took effect on February 21, 2026, while the SEC’s clarifying rules took effect on March 4, 2026. These changes aim to enhance transparency around beneficial ownership and strengthen regulatory oversight of entities operating in Thailand’s capital markets. Expanded Definition Under the revised framework, a “major shareholder” now includes persons who directly or indirectly hold more than 10% of the voting rights in a regulated company, as well as persons who exercise control over the regulated company or its shares. This system of two separate tests, based on both shareholding and control, differs from the prior regime, which focused primarily on shareholding thresholds and applied a more limited method for determining indirect shareholdings. The two tests (detailed below) operate independently of each other, and any person identified by either of the tests will be deemed a major shareholder. Shareholding-Based Test Broadens Indirect Ownership Attribution For the shareholding-based test, the SEC recognizes two existing methods for identifying indirect ownership, together with a new proportional attribution method. Any person captured under these methods, which are described below, will be regarded as a major shareholder of the regulated company and must obtain SEC approval as a major shareholder. First, the existing framework continues to apply to both first-tier and chain ownership structures. Approval is required for (1) first-tier

Over the past several years, numerous automobile manufacturers have brought electric vehicles (EVs) to the market and received positive feedback from consumers in Thailand and around the world. EVs have gained popularity due to their lower maintenance costs, reduced energy expenses, and environmental benefits. However, reports have emerged of EVs causing problems such as battery fires, autopilot malfunctions leading to accidents, and safety systems such as brakes engaging automatically under inappropriate conditions. Even when these situations do not cause injury to drivers or passengers, they raise significant concerns for EV manufacturers, importers, and sellers operating in Thailand. These problems may seriously impact businesses if the products are identified as unsafe under Thailand’s Product Liability Act (PLA), officially known as the Liability for Damages Arising from Unsafe Products Act. Under this law, authorities or courts can order business operators to recall products from the market or prohibit their export, import, or sale. To manage and mitigate the risk of being found liable for damages due to an unsafe product under the PLA, EV business operators should be aware of the scope of the law. Potentially Liable Parties The PLA identifies several types of entrepreneurs and business operators—both individuals and entities—as “potentially liable parties” (PLPs) who may be held liable under the law. In the EV context, this could include vehicle manufacturers, battery suppliers, software developers whose systems are integrated into the vehicle, and local importers or distributors. Specifically, the PLA covers: Manufacturers or hirers Importers Sellers of goods for which the manufacturer, hirer, or importer cannot be identified Any other party who uses the name, trade name, trademark, or statements associated with the alleged unsafe products, or acts in a manner that causes them to be perceived as a manufacturer, hirer, or importer Definition of “Product” and “Unsafe Product” The

Thailand’s Legislation Consideration Committee of the Ministry of Interior has ruled that in-game loot boxes in online games do not constitute gambling under the Gambling Act B.E. 2478 (1935). This first-of-its-kind ruling provides useful guidance for online game operators and digital entertainment companies operating in Thailand. Background The ruling came in response to an inquiry concerning an online role-playing game operator that launched a campaign featuring a loot box mechanism. The mechanism allowed players to purchase a token in exchange for the opportunity to receive a virtual loot box containing randomized in-game items. The key features of this were as follows: The items received were digital, noncash items usable only within the game. The items could not be exchanged, redeemed, or converted into cash with the game operator. Items may differ in rarity but remain purely virtual. The central question was whether paying money to obtain randomized in-game items constituted a risk-based activity involving the chance to receive money or property of monetary value, which would constitute gambling under the Gambling Act. Committee Ruling The committee reached the following conclusions regarding the characteristics of the game’s loot-box mechanism: No cash or monetary equivalent: Players did not receive cash or property that could be exchanged for cash. The in-game items were merely usage rights within the online game ecosystem. No real-world monetary valuation: There was no determination of item value in real currency, and no mechanism for redeeming or converting items into money with the game operator. Any off-platform trading of in-game items between players is irrelevant to online game operators, as any value arising from such transactions is determined by the market rather than by the operators themselves. Service fee characterization: Payments made by players purchasing in-game loot boxes constituted fees for online game services. Accordingly, the committee concluded