Thailand’s Anti-Corruption Cooperation Committee has issued a major update to the anticorruption standards required for private entities engaging in high-value state projects. The update, titled “Announcement re: Procurement Limits and Minimum Anticorruption Standards (No. 2),” replaces and amends key provisions of the original announcement dated September 25, 2024.
Published in the Government Gazette on April 10, 2026, the new rules take effect on May 10, 2026, and apply to projects valued at more than THB 300 million (approximately USD 9.3 million).
The key amendments to the anticorruption standards are detailed below.
Expanded Definition of Conflict of Interest
The 2026 regulation significantly broadens the scope of what constitutes a conflict of interest compared to the 2024 version, which focused primarily on basic kinship and business ties. Under the new rules, a conflict of interest includes using one’s position or authority to seek benefits for oneself, a group, close associates, or business, including through business relationships, kinship ties, or relationships with spouses or individuals living together as partners without marriage registration. The 2026 announcement also introduces specific examples that were largely absent from the 2024 text, such as holding shares in similar businesses that submit proposals for the same project, or submitting proposals for projects in which a relative, spouse, or unregistered partner is an “involved party” in that procurement.
Continuous Compliance: The “Final Payment” Rule
Under the 2024 rules, the coverage period for anticorruption policies was less strictly defined. The new regulation mandates a continuous timeline: policies or certifications must remain effective from the date of bid submission until the contractor receives the final payment installment under the contract. If a certification or policy is set to expire before the final payment, the contractor must submit a new self-audit form and supporting evidence to the state agency before the original document expires.
Mandatory Qualification Requirements in the TOR
State agencies will now bear an explicit administrative obligation to embed anticorruption requirements in their procurement documents. Specifically, agencies must define in the scope of work (TOR) and procurement announcements that bidders are required to meet minimum anticorruption standards. Bidders must attach an updated Entrepreneur Information Check Form, along with supporting evidence, as part of their proposal, and must fulfill every requirement in the checklist to pass the qualification stage.
Updated Self-Audit Form
The 2026 regulation invalidates the self-audit form attached to the 2024 announcement and replaces it with a new version. The new form requires specific confirmation of the following:
- A written, current anticorruption policy;
- Designated units or persons responsible for anticorruption compliance;
- Whistleblowing systems and annual training plans; and
- Policy reviews conducted at least every three years.
Compliance Actions
Given the expanded conflict of interest definition, companies should immediately review their internal disclosure policies to ensure they capture unregistered partnerships and indirect business ties. Project management teams must also track the expiration of anticorruption certifications as a critical contract milestone, since any lapse in coverage could jeopardize final payments or future eligibility.
