Thailand’s official draft Platform Economy Act (PEA) was released on January 15, 2025, for public comment until February 15, 2025. The draft PEA is positioned as a general or overarching law for digital intermediary services and digital platform service businesses. The official release of the draft came after the sharing of the set of principles that would form the basis for the official draft PEA in November 2024. The draft PEA incorporates those principles and adds more detailed provisions. Especially notable is that the draft PEA requires all intermediary service providers and online platform operators—both Thai and foreign—to appoint a point of contact to liaise with the Electronic Transactions Development Agency (ETDA) if they have any users in Thailand. However, the draft PEA does not mandate establishment of a local entity in Thailand. Types of Intermediary Services The draft PEA sets out a three-tiered classification system for different types of service providers, ordered from fewest obligations to most: Intermediary services. Intermediary services are further divided into three subcategories: mere conduit, caching, and hosting. Each type of intermediary service has different safe harbor provisions, which define their scope and limitations. Online platform services. Online platform services are defined as involving “the provision of intermediary services in the hosting category that involve facilitating the matching of various types of users to enable transactions or interactions, whether or not a fee is charged. Additionally, such services may include other provisions to facilitate these transactions or interactions.” Key obligations for online platform providers include: Informing users of their rights and duties under relevant laws Implementing a notice-and-action mechanism Disclosing advertising information Publishing T&Cs, including details such as service fees, algorithms, and complaint management mechanisms. Very large online platform services. Very large online platform services (VLOPs) have extra duties beyond regular online platform services,

On January 13, 2025, Thailand’s cabinet approved in principle the draft Entertainment Complex Act, as proposed by the Ministry of Finance. This landmark legislative proposal, which would allow casinos as part of larger “entertainment complexes,” will now proceed through further parliamentary review and approval. Key provisions of the draft act are described below. Corporate structure: Entertainment complexes must be operated by Thai-registered limited companies or public limited companies with a minimum paid-up capital of THB 10 billion. Directors of the licensed entity must be individuals and have the qualifications and none of the prohibited characteristics specified in the draft act. The draft act does not impose restrictions on foreign-majority ownership structures; however, it is worth monitoring whether any amendments addressing this matter are introduced during the legislative process. Operating conditions: Each entertainment complex must be located in an area designated under a royal decree. It must also include at least four types of entertainment businesses listed in the annex to the draft act (e.g., shopping mall, hotel, sports stadium, amusement park), along with a casino. The allocation of casino space must comply with regulations to be specified at a later date. Licensing conditions: Licenses will be valid for 30 years, renewable in increments of up to 10 years. The license issuance fee is THB 5 billion, the annual fee is THB 1 billion, and the renewal fee is THB 5 billion. The Entertainment Complex Policy Committee, chaired by the prime minister, will review and approve applications. Online gambling restrictions: Licensees are prohibited from offering gambling through internet-connected systems or electronic devices that allow access from outside the casino premises. Labor requirements: Thai and foreign employee ratios must adhere to prescribed regulations. Land privileges: Lease agreements for land use are limited to 50 years. Renewal is permitted for up to

Thailand’s Department of Industrial Works (DIW) has issued a new regulation (Ministerial Regulation Re: Designation of Type, Kind, and Size of Factories (No. 3) B.E. 2567 (2024)), which removes the factory license requirement for electricity generation from solar energy installations on rooftops, roof decks, or any part of a building used for residential or other purposes, regardless of capacity. The new rules took effect on December 28, 2024. Under the previous regulations, solar rooftop installations had to seek approval from the DIW if their capacity exceeded 1,000 kW (1 MW), which added time and administrative costs when adopting renewable energy solutions. Benefits and Further Compliance The updated regulation benefits industrial operators by facilitating faster installation times and lower costs, as solar rooftops can now be installed without the need for prior approval of a factory license from the DIW. Operators can now more easily contribute to environmental sustainability and carbon reduction efforts. Despite the lifting of the factory licensing requirement, other compliance obligations, such as an energy business license (or exemption from an energy business license), a controlled energy production license, and a construction permit, may still apply. Reason for the Change Removing the classification of rooftop or building-installed solar power plants as factories aligns with Thailand’s renewable energy goals and reduces regulatory burdens for industrial operators. Additionally, it supports the achievement of energy policies aligned with the UN’s Sustainable Development Goals and Thailand’s international commitments to reduce greenhouse gas emissions through the participation of all sectors. For further details on how this change affects business operations or to explore strategies for renewable energy implementation, please contact Supasit Boonsanong at [email protected], Charuwan Charoonchitsathian at [email protected], or Phareeya Yongpanich at [email protected].

The State Bank of Vietnam’s Circular No. 50/2024/TT-NHNN regulating safety and security for the provision of online services in the banking sector (“Circular 50”), issued on October 31, 2024, took effect on January 1, 2025, with delayed effectiveness for certain provisions on (i) network, communication, and security systems, online banking application software, and mobile banking application software (July 1, 2025); (ii) transaction confirmation for payment transactions conducted via the straight-through processing method (January 1, 2026); and (iii) authentication forms and reporting obligations (July 1, 2026). The cybersecurity situation in Vietnam is complicated, and the banking and finance sector has been one of the top targets of high-tech criminals. Circular 50 seeks to enhance user protection by expanding the technical requirements to more services in the banking sector as well as standardizing how transactions are authenticated. Expanded Scope of Services Covered Previous regulations on safety and security of online services in the banking sector only covered banking services and intermediary payment services. Circular 50 expands the scope to include other services of credit institutions and foreign bank branches such as credit information services, foreign exchange services, securities depository services, and services related to factoring and letters of credit, which now need to comply with technical requirements and standards for online services such as firewalls and DMZ network barriers. Risk-Based Approach to Authentication Circular 50 sets out standards for payment transactions and card transactions by: Classifying various online transactions based on the type of client, the purpose of the transfer, the value of the specific transaction, and the total value of certain transactions during the day; and Applying various types of authentication for the corresponding types of online transactions, e.g., using passwords or PINs for small-value online transactions, and using OTPs (through SMS, voice, or email), biometric matching, or e-signatures for