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June 19, 2025

Thailand to Step Up Enforcement of Royal Decree on Digital Platform Services

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Thailand’s Electronic Transactions Development Agency (ETDA) has announced plans for increased enforcement of the Royal Decree on the Operation of Digital Platform Service Businesses That Are Subject to Prior Notification B.E. 2565 (2022). The ETDA outlined a comprehensive enforcement framework and review process during an online meeting with digital platform service operators on June 11, 2025.

The ETDA’s enhanced enforcement approach includes systematic reviews of notification submissions, formal correction orders, and potential criminal penalties for noncompliance. Digital platform operators should immediately assess their current notification status and prepare for increased regulatory scrutiny.

Review and Amendment of Previously Submitted Notification Data

The ETDA will begin reviewing operation notification forms and annual reports submitted by digital platform service operators to assess each platform’s risk level and develop tailored regulatory obligations. In this comprehensive review process, the ETDA will:

  • Examine the accuracy and completeness of submitted notification data;
  • Request additional information as needed by phone or email; and
  • Issue formal orders as needed requiring operators to correct or complete missing information.

Operators who fail to comply with ETDA orders may face suspension of operations, revocation of their notification receipt, and public disclosure of their noncompliant status on the ETDA’s website. The ETDA will conduct follow-up workshops in July 2025 for operators whose data remains unclear or incomplete.

Enforcement Framework and Penalties

The ETDA outlined a three-tiered enforcement framework with escalating consequences for different types of violations, as follows:

  • Failure to notify before commencing operations: Operators who begin services without proper notification may face criminal penalties under the Electronic Transactions Act, including up to one year of imprisonment, fines of up to THB 100,000 (approx. USD 3,070), or both. Additional consequences include suspension of operations and potential liability for company directors.
  • Failure to correct or comply with official orders: Noncompliance with ETDA correction orders may result in suspension until corrections are made, prohibition of business operations until compliance is achieved, or revocation of notification if corrections are not completed within 90 days. The ETDA may also impose daily compulsory fines until full compliance is achieved.
  • Operating while suspended or notification receipt revoked: Continuing operations during suspension or after revocation carries the same criminal penalties as failure to notify, including up to one year of imprisonment, fines of up to THB 100,000 (approx. USD 3,070), or both, plus potential director liability.

Appeals Process

Orders issued by ETDA officials (e.g., for data correction) and orders issued by the ETDA director (e.g., for platform designation) must be appealed within 30 days of receipt. Orders imposing compulsory fines must be appealed within 15 days. Operators may escalate appeals to the Administrative Court if dissatisfied with initial outcomes.

Cross-Agency Collaboration

The ETDA may coordinate with other government agencies to strengthen enforcement efforts. Key partnerships include collaboration with the Ministry of Digital Economy and Society for content takedown requests and coordination with foreign embassies for international enforcement matters.

Next Steps

The ETDA will conduct a second workshop in July 2025 to assist digital platform service operators in completing their data for notification. The ETDA will also publish a list of high-risk platforms during this period.

Digital platform operators should immediately review and update their submissions to ensure accuracy and completeness. Failure to correct unclear or incomplete data may result in legal action, including revocation of notification receipts and the enforcement of penalties outlined above.

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