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August 7, 2026

Thailand Seeks Input on Competition Guidelines for Digital Platforms, Modern Trade, and On-Demand Delivery

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On July 31, 2026, the Trade Competition Commission of Thailand (TCCT) launched a one-month public consultation period on proposed regulatory guidelines for competition in three business segments: (1) digital platforms; (2) modern trade and credit terms; and (3) ride-hailing and on-demand delivery, including food delivery and mart/quick commerce. At the same time, the TCCT released a market report on ride hailing and on-demand delivery that is likely to influence the guidelines and their interpretation and enforcement.

The consultation runs until August 31, 2026. Stakeholders have a limited window to submit practical, evidence-based input that may shape the next phase of Thailand’s regulatory framework for competition.

Scope of the Consultation

The public consultation targets updating existing guidance in three business sectors that have experienced transformative growth and structural change:

  • Digital platforms: The TCCT has actively monitored this sector in recent years and has coordinated with other regulators, primarily the Electronic Transactions Development Agency (ETDA) and the Ministry of Commerce. In March 2026 the TCCT’s Guidelines on Multi-Sided Platforms and E-Commerce Businesses took effect, and in July the TCCT established a digital platform subcommittee to regulate and prevent unfair trade practices in digital platform businesses. This activity followed a TCCT market report on e-marketplace businesses in September 2025.
  • Modern trade and credit terms: This sector was the focus of the TCCT’s 2019 Guidelines on Unfair Trade Practices between Wholesale and Retail Operators and Manufacturers or Suppliers (widely known as the “Modern Trade Guidelines”) , as well as its 2021 Guidelines on Unfair Trade Practices regarding the Credit Terms under which Small and Medium Enterprises (SMEs) Sell Products or Services to a Purchaser (also known as the “Credit Term Guidelines”), which were amended the following year.
  • Ride-hailing and on-demand delivery (including food delivery and quick commerce): The TCCT published the Guidelines on Unfair Trade Practices between Digital Platform Operators for Food Delivery and Restaurants (or the “Food Delivery Guidelines”)in December 2020, but no specific guidelines currently exist for ride-hailing and mart/quick commerce.

The TCCT’s decision to revise existing guidelines follows field research across multiple provinces and in-depth market structure analysis. The findings of that research suggest that current guidelines may not fully capture fast-changing trading practices, platform ecosystems, and sector-specific market dynamics. The consultation is therefore an opportunity for operators to explain how their markets work in practice, identify where regulatory assumptions may not reflect commercial realities, and help the TCCT design rules that are targeted, workable, and proportionate.

TCCT’s Market Report on Ride-Hailing and On-Demand Delivery

Alongside the call for public consultation, the TCCT has released a detailed market report for the ride-hailing and on-demand delivery sectors, conducted by its Market Structure and Business Systems Division.

In the ride-hailing sector, a single platform held approximately 70 percent market share in 2024, but by 2026 the market had evolved into a behavioral duopoly between two leading platforms holding around 45–50 percent and 45 percent, respectively, with smaller players holding minimal shares. The rapid ascent of the challenger platform resulted from aggressive pricing strategies, including waiving commission fees for drivers during its market-entry phase. A newer entrant that launched in early 2024 introduced a zero-commission model charging drivers a flat THB 20 platform fee per trip.

The food delivery market has experienced more dramatic concentration. The market, valued at approximately THB 100 billion over 2022–2025, underwent a major structural shift in May 2025 when a pioneering operator with more than 19 percent market share announced its permanent withdrawal from Thailand due to sustained losses. At the same time, a domestic financial group completed the sale of its loss-making food delivery platform to a consortium of local investors. These exits left two leading food delivery platforms controlling a combined 80–90 percent of transaction volume in 2026, with a third operator holding approximately 10 percent as a supporting player within a broader regional e-commerce group.

The report identifies systemic entry barriers that reinforce market concentration. These include:

  • Indirect network effects that create a “chicken-and-egg problem” whereby new platforms cannot attract drivers or delivery riders without passengers or customers, and vice versa, forcing entrants to subsidize both sides simultaneously at enormous cost.
  • Multihoming barriers that impose hidden costs on drivers wishing to work across multiple platforms—including uniforms, insulated delivery bags, high-performance smartphones, fast internet packages, and advance deposits—compounded by loyalty programs designed to incentivize single-platform commitment.
  • Data and ecosystem advantages that enable incumbents to leverage their market power and achieve economies of scope, including superior algorithmic pricing, demand forecasting, and integrated financial services such as digital wallets and buy-now-pay-later schemes that create switching costs and lock in users.

The report also documents several categories of potentially anticompetitive conduct. Pricing behaviors include:

  • Surge pricing through opaque algorithms that may discriminate unfairly against consumers in urgent need.
  • Predatory pricing or pricing below cost to eliminate smaller competitors, followed by raising prices and commission rates once market dominance is achieved (recoupment).
  • Unfair commission fees imposed on small merchants with high platform dependency, coupled with unilateral changes to rider compensation without advance notice.

Nonprice conduct includes:

  • Price parity clauses that prohibit restaurants from offering lower prices on their own websites or competing platforms.
  • Self-preferencing through algorithm manipulation to promote in-house food preparation or captive logistics services.
  • Exclusivity arrangements that coerce merchants or riders to avoid competitors in exchange for preferential commission rates or marketing tools.

Next Steps for Business Operators

The public consultation marks a significant shift toward more responsive competition law enforcement in Thailand’s digital platform economy. The TCCT is expected to play a more active role through heightened ex-ante oversight and sector-specific guidance, and it has signaled its intention to align enforcement more closely with international competition policy trends—including the EU’s Digital Markets Act (DMA), foreign competition authority enforcement experience, and Thailand’s broader policy direction toward OECD accession. The outcome of this consultation, in conjunction with the TCCT’s market studies, will likely shape how Thailand’s competition rules are interpreted and applied across these sectors.

Participation in the consultation is thus important not only to comment on existing and future guidelines but also to influence the market study assumptions that may underpin future law reform and enforcement priorities. This is a valuable opportunity to help the TCCT understand the nature of participants’ businesses, the commercial justification for existing practices, and the differences between Thai market conditions and foreign market dynamics and regulatory models.

Business operators should act promptly to:

  1. Identify which aspects of the consultation and market study may affect their business model, commercial terms, data practices, pricing policies, commission structures, merchant or supplier arrangements, and platform governance.
  2. Prepare factual evidence and practical examples showing how the relevant markets operate in Thailand.
  3. Submit clear, well-supported comments before the consultation closes on August 31, 2026.

To encourage this process, Tilleke & Gibbins is helping operators assess the consultation’s impact and develop practical advocacy positions. We can also lead industry-wide discussions and engagements with the TCCT and other regulators so that the consultation reflects insightful market practices and a balanced regulatory approach.

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