Thailand has expanded the circumstances under which state agencies may bypass competitive bidding procedures to address urgent security challenges. On November 28, 2025, Thailand’s Ministry of Finance published the Ministerial Regulation Determining Cases of Procurement by Specific Method (No. 6) B.E. 2568 in the Royal Gazette, introducing a new pathway for procuring supplies and services needed to address cyber and military threats that may affect the stability of government agencies or the nation. For technology vendors, cybersecurity firms, and defense contractors, this regulatory change creates immediate opportunities to engage directly with government buyers facing urgent security challenges. New Fast-Track Category for Security Threats The regulation amends Thailand’s Public Procurement and Supplies Management Act B.E. 2560 (2017) to add a new category of procurement that qualifies for the “specific method”—a noncompetitive, direct selection process. Previously, agencies could use this expedited method only in limited circumstances, such as emergencies, cases with proprietary technology requirements, or national security operations. The new provision explicitly covers procurement of supplies related to preventing or resolving cyber or military threats that could impact the stability of a state agency or the country. This addition recognizes the urgent nature of modern security challenges, where competitive bidding timelines may leave agencies vulnerable during critical threat windows. State agencies dealing with active cyberattacks, preparing defensive measures against anticipated threats, or responding to military security concerns can now move directly to negotiate with qualified vendors rather than conducting lengthy public tender processes. Vendor Considerations Vendors offering cybersecurity solutions now have a regulatory avenue to work directly with government clients when stability concerns are present. These solutions include threat detection systems, anti-ransomware tools, incident response services, firewalls, and security consulting. Similarly, defense contractors providing military equipment or specialized security supplies can pursue direct engagement channels where traditional procurement methods would create

Thailand’s Department of Business Development (DBD), through its Office of Central Company and Partnership Registration, has released multiple draft orders for public consultation until December 12, 2025. These draft orders aim to strengthen the business registration process, with a focus on the requirements for establishing and amending the principal office address of a partnership or limited company, verification of authorized signatories, and measures to identify and prevent registrations involving persons linked to suspicious or high-risk activities. The draft orders’ proposed requirements are outlined below. Principal Office Verification The principal office address of a partnership or limited company, including house registration code, house number, full address details, and building name, must be fully aligned with the civil registry. The registrar will strictly verify this before accepting any registration or amendment. If the address used for registration is already registered for at least five other companies, the company must submit a consent letter from the person authorized to allow use of the principal office, along with supporting documents proving the right to use the address. Signatory Certification Compliance Duties Persons certifying directors’ signatures on registration forms are responsible for verifying their identities, maintaining up-to-date information, and complying with the requirements of the DBD’s Biz Regist digital registration system. Certain supporting documents proving the qualifications of certifying persons are also required, with some exceptions for specific professional roles. Identity and qualification verification must be renewed upon the completion of one year from the date of registration as a certifying person, or if the certification credentials expire before the one-year period ends, in accordance with the verification requirements. Verification of Suspicious Parties Any partner, shareholder, or director linked to a predicate offense will be required to meet with the registrar in person for further verification steps. For all parties related to a company

Recent high-profile corporate fraud and accounting scandals have brought increased scrutiny to governance, compliance, and enforcement practices in Thailand, highlighting the legal and practical challenges facing companies operating in the country. As regulators and law enforcement authorities sharpen their focus on financial misconduct, cybercrime, and corruption, businesses must navigate a complex and evolving investigative landscape. Tilleke & Gibbins’ investigations and compliance team examines these issues in the Thailand chapter of The Practitioner’s Guide to Global Investigations – Tenth Edition, published by Global Investigations Review (GIR). The chapter provides a detailed overview of Thailand’s legal framework for corporate investigations, offering practical guidance for companies and counsel responding to regulatory and criminal scrutiny. The Thailand chapter covers key topics including corporate criminal liability, enforcement priorities, internal investigations, data protection considerations, dawn raids, whistleblowing, cyber-related investigations, and cross-border cooperation. It also addresses emerging issues such as cybersecurity enforcement, economic sanctions compliance, and anticipated developments affecting investigations in Thailand. The chapter is authored by John Frangos, Chitchai Punsan, Alongkorn Tongmee, Michael Ramirez, Piyawat Vitooraporn, and Michelle McLeod. The Thailand chapter is available as a PDF below, and the full guide can be accessed on the GIR website.