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January 9, 2026

Thailand’s Tech Industry Outlook for 2026

Thailand continues to advance its legal and regulatory framework for the technology sector, with several key laws undergoing review and proposed amendments. These developments reflect Thailand’s broader efforts to ensure that its regulatory landscape keeps pace with rapid technological change and aligns more closely with international standards and best practices.

The following are key legal developments and proposed legislative reforms in 2026 that are expected to impact businesses operating in the technology sector and the broader Thai business landscape.

Data Privacy and Cybersecurity

Personal Data Protection Act B.E. 2562 (2019)

Following the full enforcement of Thailand’s Personal Data Protection Act (PDPA) in June 2022, businesses and practitioners have identified practical implementation challenges and interpretative issues. These challenges were reflected in an effectiveness assessment conducted by the Personal Data Protection Committee (PDPC) in late 2024. The PDPC published a set of principles for public consultation to identify issues and directions for potential amendments to the PDPA.

  • Key issues: Emerging issues include clarifying the definitions of “data controller,” “data processor,” and “criminal record”; revisiting the scope of sensitive personal data to better reflect Thailand’s context; proposing amendments to the hierarchy of legal bases to avoid misconceptions of consent as the default legal basis; and clarifying the required level of expressiveness for explicit consent, as well as rules for collecting personal data from other sources.
  • Current status: The first round of public consultation has concluded.
  • Next steps: The proposed amendments are proceeding to a revised draft following the consultation outcomes.

Cybersecurity Act B.E. 2562 (2019)

Thailand is moving forward with proposed amendments to enhance the effectiveness of its national cybersecurity framework, as evolving digital technologies bring new risks such as misinformation, system intrusions, and attacks on critical infrastructure, making cybersecurity a national priority.

  • Key issues: The amendments aim to clarify and strengthen the roles and duties of private entities, particularly critical information infrastructure (CII) operators, in preventing, mitigating, and responding to cyber threats. Key highlights include broadening the meaning of “cyber threat” from a narrow technical focus to a holistic assessment of potential national and public impacts; introducing defined terms such as “cyber threat incident,” “computer data,” and “computer system”; strengthening risk management and incident response by CII operators; and expanding the scope of CII organizations to include public and private entities related to industrial work.
  • Current status: The third round of public consultation has concluded.
  • Next steps: The draft amendments are being revised following the consultation outcomes.

Child Online Safety

Penal Code Amendments

Recent Penal Code amendments, effective December 30, 2025, introduced provisions on sexual harassment and revised provisions on sexual assault. Offenses under these provisions that take place through online channels may result in a court order requiring the removal of the relevant content within a prescribed period, with penalties imposed for failure to comply with such a court order. Thailand is proposing further amendments to address technology-related crimes and online platform-facilitated crimes against minors, including child grooming and sexting.

  • Key issues: The proposals introduce new offenses covering online grooming, transmission of sexually explicit content to minors, and sexual extortion, alongside stricter penalties and extended extraterritorial jurisdiction, reflecting a strengthened focus on child protection in the digital environment.
  • Current status: The first round of public consultation has concluded.
  • Next steps: The Office of the Council of State will consider the draft at the third reading in January 2026.

Artificial Intelligence

AI Regulatory Framework

The Electronic Transactions Development Agency (ETDA) has continued its efforts to develop an AI regulatory framework by opening a public hearing on draft principles for future AI legislation.

  • Key issues: The proposed principles focus on a risk-based approach to AI development and deployment while supporting innovation through measures such as data reuse and sandbox mechanisms. (See more details here.)
  • Next steps: The initiative currently remains at the drafting stage, and a further public hearing on a provision-by-provision draft is expected in 2026.

Fintech

Payment Systems Act B.E. 2560 (2017)

Thailand’s payments landscape continues to be shaped by the Payment Systems Act and an active supervisory agenda from the Bank of Thailand (BOT) focused on fraud risk, interoperability, and digital-first service models.

  • Key issues: The BOT’s Guidelines for Digital Fraud Management took effect on December 17, 2025, and impose end-to-end fraud controls across prevention, monitoring, detection, and remediation for financial institutions and operators of inter-institutional fund transfer systems, e-money, and e-fund transfer services under the Payment Systems Act.

Emergency Decree on Digital Asset Businesses B.E. 2561 (2018)

Thailand’s Securities and Exchange Commission (SEC) has released relaxed digital asset regulations that pave the way for tokenization of carbon credit and renewable energy assets, expanding financing and trading options in the environmental sector.

  • Key issues: The amended regulations permit the offering, trading, and provision of other services related to tokenized carbon credits, tokenized renewable energy certificates (RECs), and tokenized carbon allowances through licensed digital asset exchanges, brokers, and dealers. This regulatory development is aimed at facilitating the green economy and the country’s net-zero goal, while increasing the diversity of products in the regulated digital assets market.

Digital Platforms

Royal Decree on the Operation of Digital Platform Service Businesses That Are Subject to Prior Notification B.E. 2565 (2022)

Thailand’s platform governance entered a more prescriptive phase in 2025-2026 as regulators moved from system registration to targeted oversight of higher-risk platform categories. In parallel, Thailand is developing a primary law, the draft Platform Economy Act (PEA), which, if enacted, is expected to supersede the royal decree and consolidate user-protection and competition tools for the platform economy.

  • Key issues: During 2025, the regulator designated online marketplaces with particular risk characteristics under section 18(2) of the royal decree and imposed additional duties focused on merchant traceability and accountability and compliance with goods standards and takedown mechanisms. With respect to the draft PEA, the principles remain under development at the Council of State, with further drafting and a subsequent hearing expected. Latest policy signals continue to envisage adoption of an EU Digital Services Act–inspired regime, with the royal decree expected to be repealed upon commencement and transitional oversight mechanisms to apply.
  • Next steps: Operators should maintain compliance with the royal decree while monitoring developments in new or amended applicable regulations, as well as the PEA’s trajectory.

Telecommunications

Foreign Satellite Operators Draft Notification

Proposed by the National Space Policy Committee (NSPC) for public consultation on August 20, 2025, with the comment period concluding on September 3, 2025, this draft aims to replace the existing notification issued in 2021 to better align with current national policies on foreign satellite usage.

  • Key issues: The draft notification permits both Thai and foreign satellite operators to use foreign satellites to operate a business providing satellite communication services within Thailand. The consideration for granting permission takes into account technical justifications, economic benefits, social benefits, and national security considerations.
  • Next steps: The draft amendments are being revised following the public consultation outcomes.

Gaming

Draft Gaming Industry Promotion Act

The draft was initially proposed by the Digital Economy Promotion Agency (DEPA) under the Minister of Digital Economy and Society (MDES) by opening a public hearing on draft principles for a future Gaming Act.

  • Key issues: The draft law aims to support the growth of Thailand’s online gaming sector while safeguarding youth and society. The draft law introduces registration requirements for developers and platforms (potentially including offshore entities), which may include a rating system. It is also expected to apply to all types of games, with particular focus on games that incorporate gambling-like features, such as lucky draw mechanisms or point-accumulation and reward-redemption systems. This reflects the Thai government’s position of combating online gambling and online scam activities.
  • Next steps: The initiative currently remains at the drafting stage, and DEPA has recently announced that it will proceed with proposing the Draft Act to the MDES for consideration and subsequent submission to the Cabinet. Further public hearing is expected within 2026.

Looking Ahead

Thailand’s technology regulatory landscape continues to develop through a combination of new legislation, subordinate regulations, regulatory guidance, and evolving enforcement priorities. Technology sector businesses should actively monitor these developments and begin preparing for possible compliance adjustments. In particular, companies should review their data governance frameworks, cybersecurity readiness, platform governance structures, and AI risk management practices to ensure they are well positioned as Thailand’s technology regulatory landscape continues to evolve.

We will continue to monitor these developments closely and provide quarterly updates to keep you informed of any significant changes or new regulatory measures impacting Thailand’s technology sector.

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March 10, 2026
Thailand’s Ministry of Finance and Securities and Exchange Commission (SEC) have issued regulations broadening the criteria for determining who qualifies as a “major shareholder” of licensed securities and digital asset business operators. Under relevant SEC regulations, major shareholders of a regulated entity must obtain regulatory approval and undergo screening by the SEC. The revised framework introduces both shareholding-based and control-based tests to determine which shareholders require regulatory approval for a wider range of indirect ownership structures and de facto control. The Ministry of Finance notification took effect on February 21, 2026, while the SEC’s clarifying rules took effect on March 4, 2026. These changes aim to enhance transparency around beneficial ownership and strengthen regulatory oversight of entities operating in Thailand’s capital markets. Expanded Definition Under the revised framework, a “major shareholder” now includes persons who directly or indirectly hold more than 10% of the voting rights in a regulated company, as well as persons who exercise control over the regulated company or its shares. This system of two separate tests, based on both shareholding and control, differs from the prior regime, which focused primarily on shareholding thresholds and applied a more limited method for determining indirect shareholdings. The two tests (detailed below) operate independently of each other, and any person identified by either of the tests will be deemed a major shareholder. Shareholding-Based Test Broadens Indirect Ownership Attribution For the shareholding-based test, the SEC recognizes two existing methods for identifying indirect ownership, together with a new proportional attribution method. Any person captured under these methods, which are described below, will be regarded as a major shareholder of the regulated company and must obtain SEC approval as a major shareholder. First, the existing framework continues to apply to both first-tier and chain ownership structures. Approval is required for (1) first-tier
March 6, 2026
Thailand’s Legislation Consideration Committee of the Ministry of Interior has ruled that in-game loot boxes in online games do not constitute gambling under the Gambling Act B.E. 2478 (1935). This first-of-its-kind ruling provides useful guidance for online game operators and digital entertainment companies operating in Thailand. Background The ruling came in response to an inquiry concerning an online role-playing game operator that launched a campaign featuring a loot box mechanism. The mechanism allowed players to purchase a token in exchange for the opportunity to receive a virtual loot box containing randomized in-game items. The key features of this were as follows: The items received were digital, noncash items usable only within the game. The items could not be exchanged, redeemed, or converted into cash with the game operator. Items may differ in rarity but remain purely virtual. The central question was whether paying money to obtain randomized in-game items constituted a risk-based activity involving the chance to receive money or property of monetary value, which would constitute gambling under the Gambling Act. Committee Ruling The committee reached the following conclusions regarding the characteristics of the game’s loot-box mechanism: No cash or monetary equivalent: Players did not receive cash or property that could be exchanged for cash. The in-game items were merely usage rights within the online game ecosystem. No real-world monetary valuation: There was no determination of item value in real currency, and no mechanism for redeeming or converting items into money with the game operator. Any off-platform trading of in-game items between players is irrelevant to online game operators, as any value arising from such transactions is determined by the market rather than by the operators themselves. Service fee characterization: Payments made by players purchasing in-game loot boxes constituted fees for online game services. Accordingly, the committee concluded
March 5, 2026
Thailand’s Securities and Exchange Commission (SEC) has filed a criminal complaint against a licensed digital asset broker, its overseas trading platform, and its executives for allegedly operating an unlicensed digital asset exchange targeting Thai customers. The case marks an escalation in the SEC’s enforcement efforts against unlicensed offshore platforms that attempt to serve Thai users through local licensed entities. Criminal Complaint On February 20, 2026, the SEC filed a criminal complaint with the Economic Crime Suppression Division against a local licensed digital asset broker, its overseas global trading platform, and its executives. The SEC alleges that the parties violated the Digital Asset Business Emergency Decree B.E. 2561 (2018) by cooperatively operating a digital asset exchange business on a cross-border basis since 2023 without the required SEC license. According to the SEC, the local broker promoted the overseas platform’s services to the public through Thai-language posts on social media channels, with services available exclusively to customers residing in Thailand. Access to the global platform was provided through the local broker’s website and mobile application. Customers who registered for the local broker’s services were automatically granted access to the global platform without having to undergo a separate identity verification process. The SEC also found that the local broker provided back-office system support services to the global platform. The SEC considers these activities to constitute joint operation of an unlicensed digital asset exchange. The former executives of the local broker are being held liable as the responsible persons during the relevant period. The SEC emphasized that the complaint initiates the criminal process, and the decision to prosecute or convict the accused parties will ultimately be made by law enforcement authorities and the criminal courts. Platform Blocking The SEC has also coordinated with the Ministry of Digital Economy and Society to block public
February 27, 2026
The Bank of Thailand (BOT) has officially implemented a new regulatory framework supervising systemically important retail payment systems (SIRPS), effective February 21, 2026, with PromptPay being the first payment system designated as a SIRPS. Under this new set of regulations, the BOT may designate payment systems under the Payment Systems Act B.E. 2560 (2017) as SIRPSs based on quantitative and qualitative assessments. Once a system is designated as a SIRPS, the operator becomes subject to expanded supervisory obligations beyond the general requirements of the Payment Systems Act. Enhanced Supervisory Requirements SIRPS operators must comply with a heightened supervisory regime across three key areas, outlined below. 1. Governance SIRPS operators must maintain robust and transparent governance structures, including: Balanced board composition, with at least one-third of the board comprising independent directors who represent stakeholders in the system (such as payment service providers, consumers, and experts). Independent directors may serve for no more than two consecutive terms. Subcommittees to assist the board in overseeing compliance, policy implementation, and operational strategy. Clear separation between executives responsible for risk and information security and those overseeing day-to-day business operations. Risk Management and System SecuritySIRPS operators must implement comprehensive risk management frameworks, including: Clear service agreements between the SIRPS operator and its direct participants (payment service providers who connect directly to the SIRPS), defining roles and responsibilities among stakeholders. These agreements must include obligations for direct SIRPS participants to supervise any indirect participants they onboard to ensure compliance with service agreements and business rules. A business continuity plan covering both IT and non-IT aspects, with annual review. The SIRPS must target service availability comparable to international payment infrastructures, including the ability to recover operations within two hours of a disruption and to maintain scalable operational capacity. Tools and controls to monitor and manage material or