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

Subscribe to Updates

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 Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

December 26, 2025
The Bank of Thailand (BOT) has released the Guidelines for Digital Fraud Management, which took effect on December 17, 2025, incorporating certain amendments to the draft guidelines issued in March 2025. These official guidelines aim for end-to-end digital fraud prevention, with a particular focus on mule accounts, to enhance trust and security in Thailand’s financial system. The guidelines apply to “financial service providers,” including: Financial institutions and special financial institutions under the Financial Institution Business Act; and Operators of Inter-institutional Fund Transfer System e-money services and e-fund transfer services under the Payment Systems Act. Besides commercial banks and e-money operators that offer fund-transfer services, other providers may adopt requirements based on risk proportionality and baseline standards set out in the guidelines (for instance, an e-money operator that does not offer e-fund transfer services could consider implementing a fraud monitoring and detection system according to the risk level of its service). The guidelines establish the following key requirements: Policy and oversight. Directors and senior executives of financial service providers must adopt appropriate “end-to-end” fraud management policies and KPIs to manage digital fraud, covering prevention, monitoring, detection, management, resolution, and support for affected customers. The fraud management policy must be regularly reviewed, and whenever there is a situation or change that significantly affects the efficiency of the fraud management. Any significant update to the policy must first be approved by the board of the financial service provider. The BOT also encourages providers to collaborate in establishing industry standards aligned with applicable laws and regulations to ensure consistency and best practices across the sector. Fraud management processes. Financial service providers must establish a clear framework for managing digital fraud throughout the customer lifecycle—from customer onboarding to service termination—covering at least the following processes: Know your customer (KYC) and customer due diligence (CDD):
Read More
December 15, 2025
Thailand is taking steps to energize its startup scene by drafting the Startup Promotion Law. This draft law aims to remove obstacles, open new funding opportunities, and provide coordinated government support. The goal is to make it easier for Thailand-based startups to grow and compete on a global stage. Why Is This Law Needed? For many years, Thai startups have operated under traditional company law frameworks that were not designed with high-growth businesses or with fundraising opportunities in mind. Restrictions on issuing bonds, offering shares to outside investors, and repurchasing shares for employee incentive programs made it challenging for emerging companies to access capital and accelerate their growth. The draft Startup Promotion Act seeks to remove these obstacles and foster a more competitive, entrepreneur-friendly environment in Thailand. Who’s in Charge? Two main organizations will oversee the startup ecosystem: Startup Promotion Committee: This group, to be appointed by the National Science, Research, and Innovation Policy Council, will set national strategies, policies, and budget; design promotional campaign and incentives; and propose further legislative amendments to promote startups. National Innovation Agency (NIA): Under the draft act, the NIA will be the main contact for startups and will serve as the secretariat office of the Startup Promotion Committee, coordinating data, advising startups, maintaining the public registry, and providing funding and investment (grants, repayable grants, loans, and equity) under committee criteria and, where applicable, cabinet approval. What Startups Are Eligible for Benefits? To be officially recognized and access benefits, a company must: Be a private limited company less than 10 years old at the time of application. Existing companies that already exceed the 10-year threshold may still apply for startup statues within one year of the law’s enactment, as long as they otherwise still qualify for the new regime. Have average annual revenue not
Read More
December 12, 2025
Tilleke & Gibbins has updated the Cambodia, Myanmar, Thailand, and Vietnam chapters in Multilaw’s Global Data Protection Guide, which collects expert advice from Multilaw member firms in 90 jurisdictions around the world (including a Laos chapter, which is also authored by Tilleke & Gibbins). The guide provides answers to key issues concerning the fast-developing data protection and privacy laws around the world, and helps data protection officers and in-house counsel understand how the regulatory regime for data protection can affect their organizations in various jurisdictions. Each section of the guide identifies the main laws that govern data protection in that jurisdiction, and gives a detailed overview of the legal principles in place as well as the enforcement authorities responsible for overseeing compliance. The guide also covers issues related to data subject rights, data protection officers, impact assessments, data breach notification requirements, and cross border data transfers. The use of personal data in marketing is also considered, with specific information on electronic marketing rules, cookies, and marketing to businesses and consumers. Multilaw, of which Tilleke & Gibbins is a longtime member, is a global network of carefully selected independent law firms able to provide expert legal advice in complex environments around the globe. The full guide is available for free on the Multilaw website.
Read More
December 11, 2025
On December 10, 2025, the National Assembly of Vietnam passed a new Cybersecurity Law, which will take effect on July 1, 2026. The new Cybersecurity Law was developed based on the consolidation of the 2018 Cybersecurity Law and the 2015 Law on Network Information Security. While the final approved version of the new Cybersecurity Law has not yet been published, according to official reports, the following notable requirements are confirmed to be included: The new Cybersecurity Law dedicates a specific article to prohibited acts related to cybersecurity, under which it strictly prohibits posting or disseminating information online that propagandizes against the Socialist Republic of Vietnam. The law also prohibits, among other things, (i) the appropriation, trading, seizure, or intentional disclosure of information classified as state secrets, work secrets, business secrets, personal secrets, family secrets, and private life; (ii) intentionally eavesdropping, recording, or filming online conversations without authorization; and (iii) the use of artificial intelligence (AI) or new technologies to conduct prohibited acts. The Ministry of Public Security (MPS) has the authority to require enterprises providing telecommunications, internet, and online services, as well as system administrators, to remove information violating cybersecurity laws from systems under their management. The MPS is also assigned responsibility for ensuring information security in cyberspace and data security, establishing mechanisms for IP address identity management, verifying digital account registration information, and issuing warnings and sharing information on cybersecurity threats. Information systems are classified into five levels (similar to the 2015 Law on Network Information Security) based on the degree of harm to national security and social order if an incident occurs. The MPS is the lead agency assisting the government in state management of cybersecurity. The Ministry of National Defense is responsible for managing military information systems, and the Government Cipher Committee manages cryptographic and cipher
Read More