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July 17, 2025

Thailand Introduces New Obligations for Online Marketplaces

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On July 9, 2025, Thailand issued a notification that introduces comprehensive operational requirements for digital platform service providers operating as goods marketplaces, effective December 31, 2025 (i.e., 180 days after its publication in the Government Gazette).

The regulation’s official name is Notification of the Electronic Transactions Committee Re: Other Actions for Digital Platform Service Operators in the Category of Marketplace for Goods with Specific Characteristics under Section 18(2) of the Royal Decree on the Operation of Digital Platform Service Businesses that are Subject to Prior Notification B.E. 2565 (2022), B.E. 2568 (2025).

Scope of Application

The notification applies exclusively to goods marketplace operators formally designated by the Electronic Transactions Development Agency (ETDA), which on the same day designated 19 platforms that had previously notified the ETDA of their operations. The goods requiring enhanced oversight by these operators are limited to those regulated by the Thai Food and Drug Administration (FDA) and the Thai Industrial Standards Institute (TISI).

Development from Earlier Draft

An earlier draft of the notification had included a requirement for offshore platforms to establish a local entity, but this requirement was removed from the final notification.

Key Obligations

Despite the removal of the local entity requirement, the notification imposes a range of additional obligations on designated goods marketplace operators:

  • Transparency. Operators must implement robust transparency measures, including clear, accessible, and understandable disclosures to users in Thai. These disclosures must cover all relevant terms and conditions, comprehensive product information, and complaint management procedures. Operators must also submit an annual compliance report to the ETDA within 60 days after the end of their accounting period, including statistics on regulated goods.
  • Business user registration and identity verification. Before permitting the sale or advertisement of regulated goods, operators must collect and verify business user information, including contact details, identification documents, registration numbers, bank account details, and self-certification of legal compliance. This information must be cross-checked against government databases or other trusted sources, and verified registration details must be displayed alongside relevant product listings.
  • Product listing and compliance. Operators must establish and enforce policies requiring business users to display evidence of compliance (e.g., licenses, certificates) before listing regulated products. Product listing policies must forbid the listing of prohibited items (e.g., certain drugs, narcotics, IP-infringing goods). Operators must verify the authenticity of compliance documents with relevant government databases prior to listing and offer tools for consumers to independently verify this information. Listings must include detailed product information, such as product name, image (with Thai label), standard or FDA marks, registration or license numbers, and contact channels for the seller or manufacturer.
  • Notice-and-takedown mechanism. Operators must implement a system for users to report illegal or noncompliant products, with categories for product standards, prohibited items, and IP infringement. Reports must be processed within three days, with notifications sent to both the reporting user and the business user. Business users then have three days to dispute the report or provide supporting evidence.
  • Actions against noncompliant business users. Operators must include in their terms of service that failure by business users to provide accurate or complete documentation may result in service suspension for up to thirty days, with written notice and an opportunity to respond. For repeated or serious violations, operators must terminate services and impose the maximum penalties allowed under their terms and conditions.

In addition to the listed obligations, designated platforms are also subject to additional requirements under section 20 of the Royal Decree on Digital Platform Services, including conducting risk assessments and implementing risk mitigation measures, as well as other obligations outlined in the notification.

Operators must also cooperate with the TISI, FDA, and other relevant agencies by providing business user information upon request, particularly in cases involving legal violations.

Next Steps

To prepare for compliance with the new obligations, marketplace operators should:

  • Review the designated list issued by the ETDA to determine whether the platform is subject to the additional obligations under this notification.
  • Review and update internal policies, user terms and conditions, and business user verification systems to ensure alignment with the new regulatory obligations.
  • Establish clear communication channels to handle compliance inquiries, takedown requests, and consumer redress mechanisms.
  • Develop or enhance technical systems to support inspection, reporting, and risk management requirements.
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