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

March 19, 2026

Thailand Opens Public Consultation on New PDPA Guidelines

Thailand’s Personal Data Protection Committee (PDPC) has launched a public consultation period to gather input for a forthcoming set of guidelines under the country’s Personal Data Protection Act (PDPA). This initiative follows the PDPC’s issuance of guidelines on consent and notification requirements in September 2022.

The main consultation period, using an online questionnaire to gather feedback, runs until March 23, 2026. In addition, an interview-style online session for private-sector participants was held on March 17, and a two-day in-person event will be held on April 1–2—this is already fully booked and  walk-ins will not be accepted, but the session will be livestreamed on the PDPC’s Facebook page.

The PDPC will use the public feedback to design draft guidelines that accurately reflect the operational realities of both public and private organizations, after which the guidelines will be shared with the public.

Consultation Scope

The PDPC has identified six priority areas for which upcoming guidance may be issued:

  • Legal bases for processing: The online questionnaire assesses respondents’ understanding of consent requirements and seeks views on priority issues, such as explanations of the legal bases and considerations for selecting an appropriate legal basis depending on the nature of the processing activity.
  • Security measures and data breach notification: The questionnaire examines respondents’ understanding of data breach reporting and security measure obligations. Topics proposed for inclusion in the guidelines include data breach prevention measures, incident response plans, risk assessment methods, and reporting procedures.
  • Data protection officers: Respondents are invited to share their expectations regarding the DPO’s role and their experiences in contacting a DPO. The survey also asks respondents to identify priority issues, such as response timeframes for data subject requests and complaint procedures.
  • Marketing and direct marketing: The online questionnaire seeks input on preferred topics for guidance, including individuals’ rights to refuse marketing communications, mechanisms for withdrawing consent, and methods for individuals to verify how organizations use their personal data for marketing purposes.
  • Records of processing activities: Proposed topics include the concept and importance of ROPAs and how individuals may exercise their right to request information regarding the processing of their personal data.
  • National ID cards and CCTV for access control: Some questions concern the collection of personal data through CCTV and other data capture methods. Proposed topics for guidance include data minimization, retention practices, and security measures.

The PDPC is also seeking feedback on the preferred format of the guidelines, which may include summary handbooks, infographics, case studies, FAQs, or comparative tables.

Practical Implications

Although the guidelines will be nonbinding, they are expected to have a significant influence on regulatory expectations and enforcement practices. Organizations may find it difficult to deviate from the recommended approaches once issued, as the PDPC is likely to rely on the guidelines when reviewing PDPA compliance. The guidelines are also expected to shape industry norms and may prompt organizations to revisit existing compliance frameworks.

Action Items

Interested organizations should aim to submit feedback through the online questionnaire by March 23, 2026, to ensure the guidelines reflect operational realities and sector-specific challenges.

Upon issuance of the final guidelines, which current indications suggest will be developed over approximately eight months, organizations should review their data protection framework to assess whether updates are required.

RELATED INSIGHTS​ 

April 2, 2026
Thailand’s Personal Data Protection Act (PDPA) enforcement has entered a new phase, and the insurance industry is squarely in the regulatory spotlight. The Personal Data Protection Committee (PDPC) considers insurers “large-scale” processors of sensitive data—including health records, financial information, and biometric data—making the sector a focal point for enforcement action. In August 2025 alone, the PDPC issued administrative fines totaling THB 21.5 million, and fines for individual violations have ranged from THB 50,000 to THB 2 million. The PDPC has also deployed its “Eagle Eye Crawler,” an AI-driven surveillance tool that monitors websites around the clock for data leaks and noncompliant privacy notices. This article highlights the key regulatory developments directly affecting insurers and outlines practical steps toward compliance. What Has Changed: OIC and PDPC Alignment The Office of Insurance Commission (OIC) has synchronized its sector-specific rules with the PDPA through the Notification on Customer Personal Data Protection (No. 2) B.E. 2568 (2025). The combined effect of the PDPC’s general enforcement push and the OIC’s sectoral guidance creates four critical compliance areas for insurers. Consent unbundling. Consent for marketing must be strictly separated from the core insurance contract; bundling marketing consent into the policy application is no longer permissible. Agent and intermediary oversight. Insurance intermediaries are generally classified as data processors, meaning that insurers—as data controllers—must provide specific written instructions and security protocols to all agents and brokers. A 2026 enforcement trend shows controllers being held liable for the “weak security” of their vendors and downstream processors. Enhanced privacy notices. Insurers must provide a summary privacy notice alongside the full policy, plainly stating categories of data, purposes, lawful bases, disclosure recipients, cross-border transfers, retention periods, data subject rights, and easy marketing opt-out channels. DPO registration and ROPA. All organizations involved in “regular or systematic monitoring of data subjects on
March 30, 2026
On March 24, 2026, the Trade Competition Commission of Thailand (TCCT) published its long-anticipated Guidelines on Multi-Sided Platforms and E-Commerce Businesses in the Government Gazette, following the conclusion of a public hearing conducted last year. The guidelines entered into force on March 25, 2026, and significantly expand the application of Thai competition law to digital platform ecosystems. These rules introduce targeted restrictions on platform conduct, such as price-ranking algorithms and tying and bunding, that leverages network effects, and will have far-reaching implications across Thailand’s digital economy—affecting not only platform operators but also platform participants, including sellers, logistics providers, advertisers, and payment service providers operating on or alongside such platforms. The guidelines clarify how existing prohibitions under the Trade Competition Act B.E. 2560 (2017) (TCA)—including abuse of market dominance, cartel conduct, and unfair trade practices—apply in the context of platform-based business models. While many provisions reflect earlier draft guidelines, the final version delivers more precise definitions and clearer enforcement parameters, increasing regulatory certainty while also raising compliance expectations. Applicability The guidelines introduce core definitions that determine their coverage: Multi-sided platform: A platform that acts as an intermediary connecting two or more groups of users, enabling them to have direct interaction in order to exchange or rely on services from one another. Examples include digital platforms for trading goods or services (e-commerce), as defined below. Digital platform for trading goods or services (e-commerce): A platform that acts as an intermediary connecting the distribution, purchase, sale, or exchange of goods or services. This includes operations carried out to facilitate transactions or interactions between business operators through an electronic transaction system, regardless of whether a service fee is charged. Operator of a digital platform business for trading goods or services: A provider of digital platform services for trading goods or services, as described
March 27, 2026
Thailand’s National Broadcasting and Telecommunications Commission (NBTC) has publicly indicated that it is preparing a new regulatory framework for data center operators that may introduce foreign-ownership restrictions. In particular, the NBTC is considering reclassifying data center operations from a type 1 telecommunications business license to a type 3 license. If implemented, this change would subject data center operators to a significantly more stringent regulatory regime, especially in relation to foreign ownership and control. The NBTC has indicated that it intends to propose a draft framework to the NBTC board. This would be followed by a public hearing process, with a view to implementing the new rules within 2026. Under the Telecommunications Business Act B.E. 2544 (2001), as amended, telecommunications businesses operating under type 3 licenses are subject to foreign ownership restrictions, including a requirement that less than 50% of the total issued shares be held by foreign shareholders. In addition, type 3 licensees are subject to foreign dominance restrictions, which prohibit arrangements that allow foreigners to dominate the business. These foreign dominance restrictions are broad in scope and may capture various forms of direct and indirect control or influence. This includes circumstances in which a foreign national is able to influence or control the formulation of policy, management, or business operations, or the appointment of directors or senior executives. At this stage, the exact scope of the proposed rules remains unclear. Businesses with existing or planned data center operations in Thailand should therefore monitor upcoming NBTC developments in this regard and prepare for the expected public hearing process.
March 27, 2026
Vietnam’s emerging governance framework for artificial intelligence (AI) is developing through a multi-layered structure comprising three components: Policy instruments setting national priorities for AI development; Regulatory framework governing development, provision, deployment and use of AI; and Technical standards and voluntary guidelines. Policy level. At policy level, the foundation for a strategic framework for AI development and governance was laid in 2021 by the National Strategy for Research, Development and Application of AI until 2030, aimed at strengthening the national AI ecosystem and positioning Vietnam as a regional AI innovation hub. Subsequently, resolution No.57-NQ/TW (2024) identified AI as a key driver of science, technology, innovation and national digital transformation. AI was also designated as a strategic technology under decision No.1131/QD-TTg (2025) listing priority technologies across sectors. Regulatory framework. At the legislative level, the new Law on Artificial Intelligence took effect on 1 March 2026, establishing the core regulatory framework governing development, provision, deployment and use of AI systems. Controlled testing for emerging AI technologies is implemented under the Law on Science, Technology and Innovation. The AI Law is expected to be further operationalised through implementing instruments, most notably a draft decree guiding the AI Law, and draft decision of the prime minister identifying high-risk AI systems (both published in February 2026). A decision establishing priority datasets for AI development is also anticipated. Compliance obligations may also arise under sectoral regulatory regimes, including data protection, cybersecurity, banking, consumer protection, e-commerce and intellectual property, particularly where AI systems are used in automated decision-making or data-driven services. Technical standards and non-binding guidelines. Vietnam’s AI governance framework is also supported by technical standards and voluntary guidelines. A key instrument is decision No.1290/QD-BKHCN (2024), providing guidelines for responsible research and development of AI systems, and represents Vietnam’s first national AI ethics code. The Ministry of Science and Technology