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September 28, 2026

Thailand Expands Mandatory Electronic Appeals in Public Procurement

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Thailand has expanded the mandatory use of the Electronic Government Procurement (e-GP) system to cover submissions of procurement appeals to all government agencies subject to the Public Procurement and Supplies Administrative Act B.E. 2560 (2017) (Government Procurement Act). The expansion, which was set out in an official circular dated September 16, 2026, from the Public Procurement and Supplies Administrative Ruling Committee, takes effect on October 1, 2026.

Notable Changes

Under the expanded framework, bidders challenging an e-bidding or selective-method procurement result must file their appeal exclusively through e-GP within seven working days of the result being announced by the Comptroller General’s Department. While the system accepts filings around the clock during that window, submissions on the final day must be fully completed by 16:30 according to the e-GP system clock—merely starting a draft or uploading materials before the cutoff does not count as a confirmed submission.

Government agencies that disagree with an appeal, in whole or in part, will also report their findings and supporting documents to the Appeals Committee through e-GP using the prescribed Appeal Opinion Report, also within seven working days of receipt.

Withdrawals of appeals must likewise follow prescribed e-GP steps that vary depending on whether the matter is still under agency review, has been forwarded to the Appeals Committee, or has already been resolved.

Excluded Categories

Certain categories of procurement are not subject to the new guidelines on filing appeals electronically. These include:

  • Procurement of supplies for confidential government use.
  • Procurement conducted by government agencies operating overseas where the bidder is a foreign legal entity with no legal representative in Thailand, or where the bidder is a non-Thai national.
  • Consulting service procurement under chapter 7 of the Government Procurement Act
  • Design or construction supervision procurement under chapter 8 of the Government Procurement

These exclusions apply to the electronic appeal guidelines specifically and should not be read as removing other review rights.

Contingency for System Failures

A narrow contingency exists for last-day system failures. If the Comptroller General’s Department acknowledges an e-GP outage on the final filing day, an appellant may file directly with the agency by letter or email, still by 16:30. This is not a general extension, and bidders should retain evidence of both the acknowledged outage and timely delivery.

Recommended Actions

Organizations participating in, advising on, or administering Thai public procurement should take the following steps before October 1, 2026:

  • Review procurement pipelines to identify which procurements will enter the new regime.
  • Confirm e-GP access and user permissions well before bid results are due.
  • Establish internal monitoring protocols tied to the seven-working-day window.
  • Prepare appeal grounds and evidence in parallel with bid activity.
  • Test system access and revise internal processes accordingly.

Particular care should be taken with pending cases and excluded categories of procurement, for which case-specific advice may be especially useful.

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