You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

April 21, 2026

Thailand Launches Consultation on Draft Rules for Data Subject Access Requests

Subscribe to Updates

Thailand’s Personal Data Protection Committee (PDPC) has launched a public consultation period on a draft notification setting out criteria for data subject access requests (DSARs). The draft notification addresses practical uncertainties in handling DSARs by introducing standardized procedural requirements for data controllers. The consultation period runs from April 16 to May 15, 2026. The notification will enter into force 30 days from the date of its publication in the Government Gazette.

Key Features of the Draft Notification

The draft notification covers the following key areas:

  • Scope of information subject to access. Data controllers must enable data subjects to access at least the following upon request: (1) personal data collected directly from them; (2) personal data obtained from other sources; and (3) the source of personal data obtained from other sources without consent. Information required under section 23 of the PDPA and information that must be recorded pursuant to section 39 of the PDPA—such as the categories of personal data collected and purposes of processing—must also be made available.
  • Submission channels and formal requirements. Data controllers must provide at least in-person and postal channels for DSARs, while electronic or other channels are optional. Requests may be made either directly by the data subject or through an authorized representative, and must be signed and include sufficient identifying information, a preferred response method, and DSAR details. Identity verification documents (and proof of authority if the request is through a representative) are required, and additional documentation may be requested for verification or communication purposes. Data controllers may use different verification methods for DSARs submitted via electronic or other channels, provided this does not create undue obstacles to the exercise of data subject rights.
  • Verification and response timelines. Data controllers must complete preliminary verification within seven business days of receiving a request. If a request is incomplete or inaccurate, or the requestor’s identity cannot be verified, the data controller must request rectification or additional documentation to be provided within a specified timeframe, which must not be set at less than 10 days. Failure to respond within this timeframe will result in the request being deemed abandoned, without prejudice to the data subject’s right to submit a new request. If the data subject does provide the requested information or documents, the request will be deemed received on the date correct and complete information or documents are provided. Responses must be provided within 30 days of receipt, extendable by a maximum of 30 days for large-volume requests or due to other necessities, provided the requestor is notified.
  • Access methods. Access may be provided through inspection of personal data, copies of documents, or data in electronic or other requested formats, where technically feasible.
  • Refusal of DSARs. Requests may be refused where compliance is prohibited by law or court order or would adversely affect third-party rights (including fundamental rights, trade secrets, or intellectual property). Where possible, redaction or other measures should be applied for partial compliance. Refusals must be communicated with reasons and recorded in the record of processing activities.
  • Fees. Electronic access or copies that do not require recording media or involve direct transmission costs must be provided free of charge. Reasonable fees may be charged for copies or labor-intensive requests, subject to actual costs and capped rates set out in the draft notification’s schedule. Data subjects must be informed of applicable fees prior to or at the time of exercising their rights.
  • Recordkeeping. Data controllers must retain DSAR records, along with any documentary evidence, for at least two years.

Next Steps

Stakeholders may submit comments until May 15, 2026. Once the rules are finalized, organizations will be expected to reassess their DSAR workflows, particularly verification and response timelines.

Related Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

September 17, 2026
Thailand’s Office of the Consumer Protection Board (OCPB) has released for public comment a draft bill to amend the Consumer Protection Act B.E. 2522 (1979), the country’s foundational consumer protection legislation. The draft amendment aims to modernize the nearly five-decade-old framework to address the rapid growth of digital commerce, online advertising, influencer marketing, and new business models. The public consultation period is open until October 10, 2026. Expanded Definitions Covering Digital Commerce The draft significantly broadens several core definitions to capture modern commercial activities: “Consumer” is expanded to include natural persons and nonprofit juristic persons who purchase or receive services, including those solicited by businesses and end users who do not directly pay for the goods or services. “Business operator” now explicitly covers advertising business operators and hired advertising persons, such as influencers and content creators. “Advertising media” is expanded to include digital platforms, social media, and social media user accounts. “Label” now encompasses electronic labels—symbols, codes, or other electronic formats displaying product information. Influencer and Advertising Disclosure Requirements In addition to these expanded definitions, “hired advertising person for selling goods or services” is a new definition covering influencers, content creators, live streamers, affiliate marketers, and virtual online media operators who receive monetary compensation or other benefits for advertising goods or services. Hired advertising persons—including influencers and content creators—must disclose to consumers that content is advertising and reveal their relationship with the business owner. Disclosure is required when the business owner employs the advertiser, pays or provides other benefits for the advertisement, or provides free or discounted products or services. These requirements apply where consumers would not otherwise know that the business has a connection to the person presenting the content. Labeling Requirements for Importers The draft introduces a clearer labeling obligation for importers of label-controlled goods, who must
Read More
September 11, 2026
Thailand’s National Broadcasting and Telecommunications Commission (NBTC) has published a new five-year master plan that will bring significant regulatory changes to the broadcasting and digital media sectors, including formal licensing requirements for internet-based audiovisual services. The Master Plan for Broadcasting and Television, 3rd Edition (B.E. 2569–2573/2026–2030) was published in the Government Gazette on September 1, 2026, and will affect OTT platforms, internet-based audiovisual service providers, and traditional broadcasters. Licensing Reform The NBTC will develop new licensing frameworks ahead of existing digital television license expirations, which are slated to occur between 2028 and 2030. This creates both uncertainty and opportunity for incumbents and new market entrants. New licensing criteria will also be developed for audiovisual services delivered over the internet, meaning previously unregulated internet-based providers may face licensing, fee, and content obligations for the first time. The plan also calls for a new law to govern converged communications services. OTT Regulation and Content Oversight The plan explicitly acknowledges and aims to lessen the regulatory asymmetry between traditional broadcasters—which are subject to licensing, fees, and content regulation—and internet-based services that currently face fewer obligations. The NBTC intends to develop regulatory frameworks to bring internet-based audiovisual services, including OTT platforms, streaming services, and user-generated content platforms, under content, consumer protection, and licensing requirements. Consumer Protection and Digital Rights The NBTC will strengthen its oversight of broadcasting, television, and telecommunications operators to ensure compliance with consumer protection and personal data protection requirements. This includes updating relevant notifications and orders and more strictly enforcing rules against practices that unfairly exploit consumers. These measures may layer NBTC-specific requirements on top of Thailand’s existing Personal Data Protection Act obligations. Stricter enforcement against practices that exploit consumers is a priority, with particular scrutiny on advertising practices. The NBTC will modernize complaint resolution processes, meaning service providers should
Read More
September 7, 2026
On September 4, 2026, Thailand’s prime minister convened the first meeting of the Data Center Business Policy Committee. The committee endorsed a draft policy framework for the data center industry and tasked four subcommittees with developing the standards that would sit beneath it, shifting away from fragmented, agency-by-agency approvals toward a unified national strategy aiming to maximize economic value while managing environmental and infrastructure concerns. Proposed Scope and Pillars of the National Data Center Policy Framework The proposed framework would cover all types of data centers, including internal or captive facilities operated within a company or its affiliates, rather than only commercial third-party providers. If adopted in this form, companies running private data centers purely for internal purposes would also become subject to regulatory oversight. Minimum safety and operational standards would be established, with uniform enforcement across all categories. The committee endorsed a draft policy framework with four key pillars: Industrial classification: Data centers exceeding 2 MW would be classified as industrial operations, which may require factory licenses and environmental impact assessments under the Factory Act. Resource pricing: Utility rates would be structured to reflect both direct and indirect costs, supporting green energy and green data center standards. Centralized screening: A centralized review would evaluate project suitability and resource allocation. Operators may be required to submit proposals through periodic “pitching” rounds, where projects are competitively assessed on their potential economic and strategic benefits to Thailand. Digital ecosystem: The framework would prioritize data sovereignty, tax incentives, and conditions promoting domestic digital businesses, AI, and cloud infrastructure. Multidimensional Evaluation Criteria and Subcommittees Four subcommittees will be established to develop standards responsible for the following dimensions: Economic: Criteria for assessing the economic viability of data center projects, for use in prioritizing data centers based on infrastructure readiness, demand type (including AI factories),
Read More
September 4, 2026
Foreign business restrictions on telecommunications, treasury center businesses, and intragroup support services were eased when Thailand published the Ministerial Regulation Prescribing Service Businesses Not Requiring Permission for Foreign Business Operations (No. 5) B.E. 2569 (2026) in the Government Gazette on August 28, 2026. The ministerial regulation expands the categories of service businesses that foreign investors may operate without a foreign business license (FBL) under the Foreign Business Act B.E. 2542 (1999) (FBA). Of particular relevance to the telecommunications, fintech, and technology sectors, the ministerial regulation exempts: Type 1 telecommunications licensees, which do not have their own networks; Treasury center businesses operated in accordance with Thailand’s exchange control regulations; and Certain intragroup administrative, human resources, and information technology management services. Telecommunications Services Foreign-owned businesses providing telecommunications services under a type 1 telecommunications license may now operate without obtaining an FBL. This may streamline market entry for qualifying telecommunications and digital infrastructure businesses. The exemption applies only to the FBA licensing requirement. Operators must continue to comply with applicable requirements under the Telecommunications Business Act and the regulations of the National Broadcasting and Telecommunications Commission, and the change does not affect foreign ownership restrictions applicable to type 2 or type 3 telecommunications businesses. Treasury Center Businesses The ministerial regulation also exempts qualifying treasury center businesses from the FBL requirement. This may facilitate centralized treasury functions in Thailand, including liquidity management, foreign exchange management, and intragroup funding arrangements. Treasury center operations remain subject to applicable requirements of the Bank of Thailand and other competent authorities. Intragroup Administrative, HR, and IT Services Certain administrative, human resources, and information technology management services provided between affiliated entities are also exempt, provided the relevant entities satisfy prescribed ownership or management criteria. The exemption is available where the service provider and recipient are related through specified ownership
Read More