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

August 6, 2025

Thailand Releases Draft Guidelines on Government Cloud Adoption and Data Classification

Subscribe to Updates

Thailand’s Digital Government Development Agency (DGA) has released drafts of two pivotal documents to guide Thai government agencies in adopting cloud technology and classifying data for cloud usage. These draft guidelines, open for public hearing through August 12, 2025, are part of the national “Go Cloud First” policy, which aims to accelerate digital transformation, improve efficiency, and ensure robust data security across the public sector. The new standards will have significant implications for both government agencies and cloud service providers operating in Thailand.

Highlights of the draft guidelines are presented below.

Government Cloud Usage Guidelines

  • Cloud-first transformation: All government agencies are directed to prioritize cloud solutions for new IT projects, in line with the cabinet’s “Go Cloud First” policy.
  • Cloud model selection: Agencies must assess their needs and select the most appropriate cloud deployment model—public, private, hybrid, or community cloud—based on the sensitivity of the data and operational requirements.
  • Service types: The guidelines provide criteria for choosing between Infrastructure as a Service (IaaS), Platform as a Service (PaaS), and Software as a Service (SaaS), emphasizing the importance of using standard, non-customized services where possible.
  • Cost management: Agencies are required to plan and separate cloud-related expenses, ensuring transparency and efficient budget allocation.
  • Cloud migration: The guidelines outline the steps for migrating to the cloud and highlight the role of cloud service providers in facilitating the process, including supporting innovation and enabling smooth exit strategies.
  • Procurement compliance: All cloud procurement must comply with public sector procurement laws and regulations. Only providers meeting government-mandated standards can be selected.
  • Security and shared responsibility: The guidelines clarify the division of security responsibilities between cloud providers and government agencies. While providers manage infrastructure security, agencies remain responsible for data, application, and access controls.
  • Legal framework: Agencies must comply with the Digital Government Administration Act, Cybersecurity Act, Personal Data Protection Act (PDPA), and other relevant laws.

Cloud Data Classification Guidelines

  • Three-tier data classification: Government data is classified into three categories:
    1. Official data: Low-sensitivity data, suitable for public cloud storage.
    2. Protected data: Data that could cause harm if disclosed (e.g., tax, medical, or financial records), recommended to be stored in domestic public clouds with enhanced security.
    3. Highly protected data: Critical or top-secret data (e.g., national security information), must be stored in sovereign or state-controlled clouds within Thailand, with the highest security measures.
  • Data sovereignty and localization: The guidelines stress that all government data is recommended to be stored within Thailand to ensure compliance with local laws and maintain data sovereignty. Exceptions require DGA approval, except for highly protected data. The guidelines also distinguish between data at rest and data in transit or processing. While the focus of localization is on data at rest, data in transit (e.g., during transmission) or temporary processing outside Thailand could be permitted under certain technical and legal safeguards, provided no unauthorized access occurs. A localization exemption could be granted with special approval from the DGA.
  • Cross-border data transfers: Storing data outside Thailand is generally prohibited for sensitive information, with limited exceptions subject to DGA approval. The guidelines define “data that should be in Thailand” as data at rest (i.e., data stored on servers), and this does not include data in transit (data being transferred) or data being processed.
  • Risk assessment: Agencies must conduct risk assessments based on confidentiality, integrity, and availability to determine the appropriate level of security and cloud deployment.
  • Security controls: The guidelines mandate strict access controls, encryption, and compliance with international standards (e.g., ISO 27001) for sensitive data.
  • Legal compliance: The framework aligns with the Official Information Act, PDPA, Cybersecurity Act, and other national security regulations.

Implications and Action Steps for Government Agencies and Cloud Providers

Under the new guidelines, cloud adoption will be highly encouraged for government agencies. Any deviation from the cloud-first approach will need to be justified, with the decision-making process documented.

Government agencies who have implemented or are seeking to implement cloud technology will need to review and update their internal policies to align with the new guidelines, implement robust data classification and risk assessment processes for all digital services before migrating data to the cloud, and plan cloud migrations accordingly.

To be eligible for government contracts, cloud service providers will need to meet stringent security, localization, and compliance standards, and prepare for increased scrutiny regarding data residency, security certifications, and service transparency.

Outlook

These new guidelines represent a significant step forward in Thailand’s digital government strategy. All stakeholders should familiarize themselves with the requirements to ensure compliance, minimize risk, and support the secure and efficient adoption of cloud technology in the public sector.

Related Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

July 6, 2026
Tilleke & Gibbins has contributed the Vietnam chapter to Data Protection & Privacy 2027, a global guide published by Lexology Panoramic that provides comparative insights into data protection and privacy regimes across multiple jurisdictions. The Vietnam chapter offers a comprehensive overview of the country’s data protection framework, addressing both regulatory structure and practical compliance considerations for businesses operating in or engaging with Vietnam. Topics covered include: Law and the regulatory authority: Legislative framework; data protection authority; cooperation with other data protection authorities; breaches of data protection law; judicial review of data protection authority orders Scope: Exempt sectors and institutions; interception of communications and surveillance laws; other laws; personal information formats; extraterritoriality; covered uses of personal information Legitimate processing of personal information: Lawful bases for processing; grounds for legitimate processing; types of personal information Data handling responsibilities of owners of personal information: Transparency; exemptions from transparency obligations; data accuracy; data minimization; data retention; purpose limitation; automated decision-making Security: Security obligations; notification of data breaches; internal controls Accountability: Data protection officer requirements; record-keeping; risk assessment; design of personal information processing systems Registration and notification: Registration requirements; other transparency duties Sharing and cross-border transfers of personal information: Sharing with processors and service providers; restrictions on third-party disclosures; cross-border transfers; further transfers; localization requirements Rights of individuals: Right of access; other statutory rights; compensation Enforcement: Enforcement mechanisms; exemptions, derogations, and restrictions; further exemptions and restrictions Specific data processing: Cookies and similar technologies; electronic communications marketing; targeted advertising; sensitive personal information; profiling; cloud services The chapter concludes with an update on key legal and regulatory developments over the past year and emerging trends in Vietnam’s data protection landscape. The full Vietnam chapter is available as a PDF through the button below. Readers can also gain 30 days of complementary access to the full Data
Read More
July 2, 2026
Thailand’s Electronic Transactions Development Agency (ETDA) released a new version of the draft Act on Artificial Intelligence on July 2, 2026, for a public hearing period expected to be approximately 30 days. The draft act adopts a risk-based regulatory approach modeled in part on international frameworks—particularly the EU’s AI Act—while incorporating provisions tailored to Thailand’s regulatory landscape and digital economy objectives. If enacted in its current form, the law would introduce extraterritorial obligations, a tiered risk classification system, strict liability for AI-related damages, and new transparency requirements for AI-generated content. Scope and Extraterritorial Application The draft act applies to AI development, deployment, or any other action affecting people in Thailand, even if the action occurs outside the country. Of note: This extraterritorial reach creates compliance obligations for global AI companies whose systems impact Thai residents or consumers, even if the provider has no physical presence in Thailand. Foreign AI providers serving Thai deployers or users must appoint a local coordinator or authorized representative. Depending on the type of AI system, the representative may need full authority to act on behalf of the provider without any limitation of liability. Certain activities are exempt from the draft act’s oversight, including AI used by natural persons solely for personal or household activities, AI for educational research conducted by higher education institutions with ethics committee approval, research and development activities conducted prior to distribution or service provision, and other AI systems prescribed by royal decree. Risk-Based Classification Framework The draft act establishes a tiered risk classification system with three main categories: Prohibited AI. The act outright prohibits AI systems employing cognitive-behavioral manipulation using subliminal techniques, AI systems causing unfair broad-scale discrimination from processing irrelevant data, and other categories of serious risk as determined by announcement of a forthcoming committee that will be responsible
Read More
June 25, 2026
On June 18, 2026, Thailand’s Office of the Personal Data Protection Committee (PDPC) published two notifications in the Government Gazette establishing Thailand’s first formal certification framework for personal data protection standards under the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The notifications, which took immediate effect, introduce a voluntary certification framework aimed at promoting accountability, strengthening organizational data protection governance, and aligning Thailand more closely with international frameworks that recognize certification as a key compliance tool. Certification Criteria The first notification sets out the assessment criteria for organizations seeking certification. Applicants must undergo an evaluation against a framework comprising four assessment categories, 10 focus areas, and 128 assessment criteria covering key elements of a privacy management program. These include: Organizational oversight and internal policies and procedures. Human resource development, including staff training and awareness programs. Clearly defined operational processes and procedures covering data subject rights, transparency obligations, records of processing activities, and lawful basis management, as well as contractual safeguards such as data-processing and data-sharing agreements and risk assessments, including Data Protection Impact Assessments. Technical measures encompassing data security controls and breach response capabilities Based on the assessment results, organizations may be awarded either a PDPA Compliance Certificate or a higher-level PDPA Certificate accompanied by a certification mark. Application and Assessment Process The second notification establishes the application and assessment process for obtaining certification. Eligible applicants include government agencies and private-sector entities that demonstrate sufficient privacy governance maturity and meet the prescribed eligibility requirements. Applicants must submit their applications along with supporting documentation for review. Upon receiving an application, the Office of the PDPC will conduct a detailed evaluation, which may include both documentary review and on-site inspections. Incomplete applications may be rejected, though applicants are typically given a limited period to correct deficiencies before a final decision
Read More
June 23, 2026
On May 26, 2026, Thailand’s Department of Land Transport (DLT) published for public consultation a draft amendment to the Ministerial Regulation on Electronic Ride-Hailing Vehicles that would, for the first time, allow juristic persons (legal entities) to register vehicles as electronic ride-hailing cars—a right that currently belongs exclusively to natural persons, limited to one person per one vehicle. If finalized in its current form, the regulation would significantly expand the supply side of Thailand’s ride-hailing market by enabling corporate fleet operators to enter the space. The public comment period is open through June 24, 2026. Key Principles Under the Draft Regulation Under the proposed amendment, juristic persons that maintain a fleet of at least 50 vehicles will be permitted to register vehicles as electronic ride-hailing cars. This represents a fundamental shift from the current framework, which restricts registration to individual natural persons on a one-person-one-car basis. Vehicle Specifications Corporate-owned ride-hailing vehicles must meet the following requirements: Be brand new from the factory, or no more than two years old from first registration with no more than 20,000 km of use. Not be a vehicle that has been reconstructed or repaired after involvement in a serious accident affecting safety—a standard consistent with public transport vehicles (RorYor. 6). Be classified as small, medium, or large in accordance with ministerial or director-general specifications. The vehicles may be equipped with safety devices such as interior or exterior cameras (video/photo recording) and can retain the original factory color of the vehicle body (no mandatory color change is required). License Plates Corporate ride-hailing vehicles will use license plates of the same size, characteristics, and color as those for private passenger vehicles not exceeding seven seats (RorYor. 1), rather than public transport plates. Potential Impact The government has stated that the regulation is intended to: Promote
Read More