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

February 20, 2026

Thailand’s Competition Law: What to Watch in the Year Ahead

The past year has been an important one for the Trade Competition Commission of Thailand (TCCT). With a right combination of commissioners bringing expertise in competition law, investigations, administrative procedures, court processes, and sector-focused industries, the regulator has pushed forward with stronger enforcement efforts and closer cooperation with both domestic and international stakeholders.

In 2025 the TCCT participated in major international initiatives—including peer reviews conducted by the OECD and ASEAN. These efforts reflect Thailand’s ongoing ambition to elevate its competition law framework to meet international expectations and build trust among global communities.

There was also significant momentum around potential amendments to the Trade Competition Act (TCA). Political parties, the TCCT, the private sector, and civil society all agreed that the 2017 law could benefit from clearer rules and more effective enforcement tools. Although a draft amendment passed an initial reading and moved to a subcommittee for revision, the process stalled following the dissolution of Parliament.

At the same time, the TCCT invested heavily in strengthening its own internal capabilities. It expanded collaborations with organizations such as the OECD, ASEAN authorities, the EU, and counterparts in Japan and Australia.

The TCCT also published sector-specific market studies, including on digital platforms and e‑marketplaces and on cold‑rolled steel. The regulator also shared draft guidelines aimed at regulating online platforms—although these have not yet been finalized.

What’s Next for the TCCT?

Looking ahead, the TCCT is set to keep building on the momentum it has created and be a more active, transparent, and practical regulator. It is likely to become even more visible in the public sphere as it steps up efforts to raise awareness about competition law, especially among businesses that may not traditionally follow or be familiar with such regulatory developments. Digital markets, including e‑commerce and online marketplaces, will remain a particular area of focus as the TCCT continues to monitor the fast‑evolving landscape.

The TCCT is also working to refine how it enforces the law. Following recent peer reviews by the OECD and ASEAN, the regulator intends to issue more detailed and better‑structured decisions. This shift is aimed at giving businesses clearer explanations of the legal and economic reasoning behind the TCCT’s findings. Over time, these decisions should help companies better understand how the rules are applied in practice and contribute to broader legal and academic discussions in the field.

Internally, the TCCT is reviewing the full suite of legal tools available under the TCA. The goal is to ensure these mechanisms, such as injunctions and settlements by fines, are used more efficiently and consistently. To support this, the TCCT is expected to introduce new rules or guidelines on fine levels and calculation methods. If implemented, these standards would bring Thailand’s penalty system closer to international practices, including those used in the US and EU.

New Draft Rules on Consultation for Advance Decisions

On February 4, 2026, the TCCT released a draft notification outlining updated criteria and procedures for requesting advance decisions under section 59 of the TCA. Section 59 allows businesses to proactively ask the TCCT to review whether a planned activity, such as a business strategy, marketing program, or other proposed conduct, could potentially violate the TCA.

For many businesses, this preliminary consultation tool is an effective way to reduce regulatory and competition‑law risks. Businesses that have taken advantage of this process have found that obtaining an advance decision can provide meaningful legal certainty, as the decision is binding once issued.

Business Outlook

Throughout the coming year, businesses operating in Thailand would be well-advised to stay closely informed about the TCCT’s enforcement practices and forthcoming guidelines. Proactive engagement with competition authorities, regular compliance reviews, and timely consultation on planned initiatives can help mitigate legal risks and capitalize on new opportunities as the regulatory landscape continues to mature. As 2026 unfolds, companies that prioritize adaptability and a forward-thinking approach to competition law will be best positioned to navigate the shifting environment successfully.

RELATED INSIGHTS​ 

April 28, 2023
On March 28, 2023, Cambodia’s Ministry of Economy and Finance and Ministry of Commerce issued Inter-Ministerial Prakas No. 168 on Penalties for Persons Violating the Law on Competition. This release was in line with the country’s recent establishment of a framework and thresholds for merger filings. The penalties for violating the Law on Competition center on the following three offenses: 1.  Entering into vertical agreements. This can be done by: requiring buyers to resell goods or services in limited geographic locations; requiring buyers to resell goods or services to specific customers or specific types of customers; requiring buyers to purchase goods or services from one seller only; preventing sellers from selling goods or service to other buyers; or requiring buyers to buy additional goods or services that are not related to the goods or services being sold. 2. Abusing a dominant market position. This can be done by: requiring or persuading suppliers or customers to not do business with competitors; refusing to supply goods or services to competitors; selling goods or services subject to commercial terms that require buyers to buy other goods or services separately that are not related to the purpose of the transaction; selling goods or services below production cost; or refusing to give competitors access to the necessary means of selling their goods and services. 3.  Undertaking a business combination that actually or potentially restricts or distorts market competition. Each of these violations is punishable by a fine of 3% to 10% of the infringer’s total turnover during the period of violation, limited to three years. Next Steps The first half of 2023 has seen three new regulations strengthening Cambodia’s competition law framework, as noted above. Although certain unclear terms do remain, regulators are expected to issue additional decisions in 2023. For more details on
March 29, 2023
On March 14, 2023, the Competition Commission of Cambodia (CCC) set out its merger filing thresholds in Decision No. 095 on Thresholds for Prior Notification of Business Mergers. This was a follow-up to the recent issuance of a regulation outlining the requirements and procedures for merger and acquisition filings. Decision No. 095 applies to all business combinations subject to premerger notification requirements under this prior regulation. The thresholds for when the CCC must be notified of a merger are laid out in the table below. In current practice, the term “turnover” typically refers to a company’s total sales revenue, while “input purchase turnover” denotes the value of materials or equipment acquired for production purposes. Although this reflects the initial interpretation of these terms, it is advisable to seek confirmation or clarification from the CCC before the filing to ensure accuracy and alignment with their current definitions, as it is conceivable that the interpretation may change. Decision No. 095 leaves room for the Ministry of Commerce to amend these thresholds as deemed necessary. Outlook In the last two years, Cambodia has steadily issued regulations to strengthen its legal framework for competition. Although gaps remain, especially with regard to enforcement of fines and certain unclear terms, more regulations are likely in 2025 and 2026.
March 17, 2023
On March 6, 2023, Cambodia issued requirements and procedures for merger and acquisition (M&A) filings to allow the country’s competition regulator to monitor the impact of M&A transactions on the Cambodian market. These rules are contained in Sub-decree No. 60 on the Requirements and Procedures for Business Combinations. This subdecree is the latest in a series of detailed regulations issued to develop Cambodia’s competition and antitrust law framework since the 2021 enactment of the Law on Competition, which formally established the Cambodia Competition Commission (CCC), set out the CCC’s complaint and investigation procedures, listed prohibited anticompetitive practices, and outlined applicable penalties. Sub-decree No. 60 applies to any business combination that may materially affect competition in Cambodia, regardless of where in the world it takes place. Premerger and Postmerger Notifications The parties to a business combination must notify the CCC of the proposed combination if the transaction meets certain thresholds, which will be determined by the CCC at a future date. The notification must include, among other things, key terms of the relevant agreements, incorporation documents and financial statements of the parties, and an indication of the types of goods or services provided by the parties. All documentation submitted must be in Khmer, except for names, addresses, and certain other items. The CCC will determine within seven working days whether it requires additional information or documentation. Once it has all necessary documentation, the CCC will issue a decision on the proposed business combination within 30 days—the combination may be approved outright or declared subject to a secondary review. Sub-decree No. 60 states that a proposed business combination will not be subject to secondary review if the market share of each party does not exceed 30 percent in each relevant market, among other criteria. However, the CCC reserves to right to
March 3, 2023
The newly released Licensing 2023 guide published by Lexology Getting the Deal Through features a chapter on Vietnam by four licensing specialists from Tilleke & Gibbins. The comparative guide provides companies and other interested readers with information on licensing law and practice in various jurisdictions around the world. Licensing 2023 provides detailed information on the following topics: Restrictions, laws and licensing arrangements Intellectual property issues: Paris Convention for the Protection of Industrial Property, contesting the validity of licensor’s IP rights, invalidity and expiry of IP rights, security interests, proceedings against third parties, sublicensing, jointly owned IP, first to file, scope of patent protection, trade secrets, copyright Software licensing: Perpetual licensing, legal requirements, user restrictions Royalties and payments, currency conversion, and taxes: Relevant legislation, restrictions, taxation of foreign licensors Competition law issues: Restrictions on trade, legal restrictions, and IP-related court rulings Indemnification, disclaimers, and damages: Prevalence and enforceability of indemnity provisions and contractual waivers of damages Termination: Right to terminate, impact of termination Bankruptcy: Impact of licensee or licensor bankruptcy Dispute resolution: Governing law, arbitration, enforceability, injunctive relief, contractual waivers The Vietnam chapter was authored by Linh Thi Mai Nguyen, partner and head of Tilleke & Gibbins’ trademark team in Vietnam; Son Thai Hoang, trademark executive; and Chi Lan Dang, associate, of Tilleke & Gibbins’ trademark team, along with corporate and commercial senior associate Tu Ngoc Trinh, who has extensive experience in franchising and competition law. The Vietnam chapter is available below as a PDF. Tilleke & Gibbins also contributed the Thailand chapter to Licensing 2023. To browse all jurisdictions covered by the guide, please visit the Getting the Deal Through website.