Thailand has enacted comprehensive sexual harassment legislation that significantly expands criminal penalties and creates new compliance obligations for online platform operators. The Act Amending the Penal Code (No. 30) B.E. 2568 (2025), enacted on December 29, 2025, and taking effect the following day, introduces a comprehensive definition of sexual harassment, establishes new criminal offenses with graduated penalties, and imposes content removal obligations on social media platforms and computer system service providers. The amendment, which establishes a comprehensive framework for addressing sexual harassment in both physical and digital environments, significantly expands legal exposure for online service operators. It also grants courts authority to order takedowns of violating data accessible to the public. Definition of Sexual Harassment The law introduces “sexual harassment” as a distinct statutory concept covering physical conduct, verbal conduct, sounds, gestures, expressions, postures, communications, surveillance, stalking, and acts committed through computer systems or electronic devices. Conduct qualifies as sexual harassment when it is sexual in nature and likely to cause the victim distress, annoyance, embarrassment, humiliation, fear, or a sense of sexual insecurity. Criminal Offenses and Penalties The amended Penal Code establishes graduated penalties based on the severity and context of the harassment—including enhanced penalties for public or online conduct. For instance: Basic sexual harassment is punishable by imprisonment for up to one year, a fine of up to THB 20,000, or both. Continuous or repeated harassment that prevents normal life escalates penalties to imprisonment for up to two years, a fine of up to THB 40,000, or both. Critically for online operators, harassment committed in public places, in the presence of the public, or through computer systems accessible to the general public triggers imprisonment for up to three years, a fine of up to THB 60,000, or both. Acts of harassment committed by supervisors, employers, or others in positions of authority over victims are punishable by

Doing business in Thailand means operating under a strict regulatory framework. From time to time, companies may receive unexpected administrative orders from government authorities that restrict their operations, impose new compliance obligations, or levy fines and penalties. When this happens, a business may challenge the order under Thailand’s administrative law system. The primary concern in pursuing administrative litigation is timing, as strict statutory deadlines apply and missing them can permanently affect a company’s rights. First Step: Administrative Appeal Many companies assume the first step is to immediately bring the matter before the Administrative Court to seek revocation or suspension of the order. Some even attempt to request an interim injunction to stop the order from taking effect. However, Thai law generally requires that the company first challenge the order through an administrative appeal with the same agency that issued it. Only after this process is complete can the matter be taken to court. Seeking an interim injunction at this stage is also not possible. This is because Thai law does not allow a standalone application for an interim injunction; an injunction can only be requested together with the underlying complaint filed with the Administrative Court. Since a court complaint cannot be filed until the administrative appeal process has been exhausted, an injunction is usually not available at the early stage. What Are the Timeframes for Administrative Appeal? Thailand applies a two-stage administrative appeal process. The appeal must first be submitted to the same authority that issued the order, which will review its own decision. If that authority affirms its decision, the appeal is then escalated to the relevant higher authority for further review. In most cases, both stages must be completed before a company is allowed to proceed to court. The timeframe for filing an administrative appeal is very strict. Generally, an appeal must

On December 30, 2025, Thailand’s Electronic Transactions Development Agency (ETDA) notified digital marketplace operators of a consolidated list of “high‑risk products” that are subject to strict monitoring on digital platforms. The list was jointly prepared by the Thai Industrial Standards Institute (TISI) and the Food and Drug Administration (FDA) to guide platform compliance in the initial phase of implementation of the Electronic Transaction Committee’s Notification on Other Measures for Marketplace for Goods with Specific Characteristics under Section 18(2) of the 2022 Royal Decree on Digital Platform Businesses Requiring Notification B.E.2568 (2025). The notice is addressed to operators of digital platform services that function as product marketplaces with specific characteristics laid out in the notification. The ETDA states that the TISI and the FDA are closely monitoring the high‑risk product categories on digital platforms, and the published list serves as the baseline reference for platform screening during the initial phase of the notification’s implementation. High‑Risk Product List The list aggregates categories of products that are illegal to sell online or are otherwise tightly regulated under Thai law, with an emphasis on health-related products, controlled substances, medical devices, and a wide range of industrial products that require certification or compliance with specified Thai Industrial Standards, as detailed below. Prohibited and tightly controlled health products. This includes all categories of modern medicines subject to control other than general household remedies; all categories of controlled herbal products except for over-the-counter herbal products; narcotics; psychotropic substances; and medical devices requiring use in medical facilities or a physician’s prescription. Selected industrial products requiring heightened controls. The list highlights dozens of TISI-regulated items commonly sold online. Examples include pacifiers, rice cookers, electrical wire, food wrap film, crayons, washing machines and dryers, air conditioners, electric cookers and air fryers, water heaters, microwave ovens, LED luminaires, hair dryers and gel nail lamps, and residual

Among the eight implementing decrees issued on December 18, 2025, to provide the legal framework for Vietnam’s new International Financial Centers (IFC), Decree No. 323/2025/ND‑CP serves the core function of officially establishing the IFC as a unified entity in two locations—Ho Chi Minh City and Da Nang—and setting out a plan for its development and governance. The key contents of the decree are summarized below. Location and Focus of IFCs The Vietnam International Financial Center in Ho Chi Minh City (VIFC‑HCMC) and the Vietnam International Financial Center in Da Nang (VIFC‑DN) are designed to attract capital, fintech, and international market participants under a dedicated regulatory framework. The IFCs will host functional zones for financial trading, banking, securities and commodities exchanges, offices, dispute resolution (via specialized court and international arbitration center), and related activities as set by the executive authority of each IFC. VIFC-HCMC, with a total area of 898 hectares in central Ho Chi Minh City, is oriented to develop a comprehensive and diverse financial ecosystem, providing traditional and specialized financial services, and leveraging synergies between financial services such as capital mobilization, investment, payment services, issuance and trading of financial products, asset management, fintech, and green financial services. VIFC-DN, with a total area of 300 hectares, is oriented to develop as a modern IFC, closely integrated with the innovation ecosystem, digital technology, and sustainable finance. VIFC-DN will establish a controlled testing platform for new financial models, taking the lead in the deployment and scaling of digital-asset products, digital payments, and specialized trading platforms and exchanges, while promoting supply chain finance, third-party services, and non-bank financial intermediaries to complement and support the traditional financial market, developing specialized, flexible, and innovative financial products. Near‑Term Priorities and Review Timeline In 2026, the government will prioritize completing the essential infrastructure and ensuring adequate human and other resources for the operation of

Thailand is developing new legislation on responsible business conduct that would impose statutory obligations on large enterprises to manage human rights and environmental risks throughout their operations and supply chains. The Draft Act on the Promotion of Responsible Business Conduct, commonly referred to as the Human Rights and Environmental Due Diligence (HRDD) Bill, has been developed through extensive consultation involving a wide range of stakeholders, with the Ministry of Justice playing a leading role. If enacted, the HRDD bill would reshape how certain large businesses operate and manage their supply chains, reflecting a recognition of international standards and global concerns regarding human rights and environmental protection. By introducing legally binding due diligence obligations, the draft aims to ensure that businesses operating in Thailand are held accountable for adverse impacts throughout their operations and supply chains, in line with emerging global legal frameworks. Who Will Have to Comply? The HRDD bill primarily targets large enterprises based on their annual revenue thresholds: Manufacturing businesses with annual revenue exceeding THB 500 million Wholesale, retail, or service businesses with annual revenue exceeding THB 300 million The draft would also cover state-owned enterprises and foreign businesses operating in Thailand if their operations meet the applicable revenue thresholds. What Does Human Rights and Environmental Due Diligence Involve? Under the HRDD bill, due diligence is not a one-time checklist but an ongoing process with several key requirements: Adopt and publicly disclose a sustainability policy. Businesses must commit publicly to respecting human rights and protecting the environment, and must integrate this policy into corporate governance and risk management systems. Identify and assess risks. Companies must identify and assess risks of human rights violations and environmental harm across their operations and value chains. Prevent or reduce risks. Businesses must implement effective and proportionate measures to prevent or mitigate identified risks, rather than simply cutting ties with suppliers as a

On December 31, 2025, Vietnam’s Ministry of Health (MOH) issued Circular No. 57/2025/TT-BYT providing guidance on the classification of medical devices according to technical standards and quality requirements (Circular 57), applicable to procurement activities for medical devices in Vietnam. According to the MOH, the purpose of the classification is to establish a principle-based legal framework and regulations that enable purchasers to easily identify groups of medical devices aligned with their professional requirements and financial capacity. Some of the key stipulations of Circular 57 are outlined below. Basis for Determining Technical Standards and Quality Under Circular 57, the technical standards of medical devices are determined in accordance with Vietnamese laws on standards and technical regulations, through the following means: Certification of conformity with standards in accordance with Vietnamese laws on standards and technical regulations; Results of conformity assessment conducted by an internationally recognized conformity assessment organization or a legally established domestic or foreign conformity assessment organization operating in Vietnam; and Documentation evidencing compliance provided by the medical device owner. The quality of medical devices is determined based on whether the device has been approved for circulation by the relevant marketing authority of one or more jurisdictions. Classification of Medical Devices Circular 57 classifies medical devices into six groups (from Group 1 to Group 6) based on technical standards and quality. Medical devices subject to classification must simultaneously meet technical standards and quality requirements in accordance with professional specifications and user needs, and must be lawfully marketed in Vietnam. Medical devices manufactured in Vietnam may participate in all corresponding groups, provided they meet the technical standards required by the user and are lawfully marketed in Vietnam. Outlook Circular No. 57 will take effect on February 15, 2026, while the classification requirements will become effective on January 1, 2027. Holders of medical device registration numbers are advised to proactively prepare documentation demonstrating compliance with technical standards and

On December 31, 2025, the government of Vietnam promulgated Decree No. 356/2025/ND-CP detailing and guiding the implementation of the new Personal Data Protection Law (PDPL) that was issued in June 2025. The new decree, like the PDPL, entered into force on January 1, 2026, with the previous Decree No. 13/2023/ND-CP on personal data protection ceasing effect on the same day. Some key points of the new decree include the following: Comprehensive lists of basic and sensitive personal data are provided, which will require companies to review again their existing documents and data type classification to ensure compliance. New timelines are established for responding to specific data subject requests. These timelines are more reasonable and longer than the previous 72-hour requirements. Additional consent guidelines are provided, prohibiting default consent or ambiguous instructions that confuse data subjects about giving or withholding consent. Mandatory content for data transfer agreements/clauses in particular cases is provided. This covers, among other things, (i) the legal basis for the transfer of personal data; (ii) responsibilities for personal data protection during the transfer and processing of personal data; (iii) responsibilities for ensuring the exercise of the rights of personal data subjects; and (iv) responsibilities for coordination and compliance of the parties in cases where violations of personal data protection regulations are detected. The qualifications and responsibilities of data protection officers (DPOs) and data protection departments include, among others, having been trained and fostered in legal knowledge and professional skills regarding personal data protection. There are no specific provisions governing the qualifications or requirements for organizations that provide data protection training or education. New mandatory templates and requirements are provided in relation to data processing impact assessment and data transfer impact assessment, and for cases in which companies need to re-submit assessments to the regulator. Stricter requirements are applied to enterprises providing data processing services, including

Resolution No. 222/2025/QH15 dated June 27, 2025, of the National Assembly of Vietnam (the “IFC Resolution” – see our previous article) set out the foundational legal framework for the establishment and development of Vietnam’s first-ever International Financial Centers (IFC). In furtherance of this framework, on December 18, 2025, the government of Vietnam issued eight implementing decrees to provide detailed regulatory guidance and to operationalize the IFC Resolution in practice. The Eight Implementing Decrees: An Integrated Regulatory Ecosystem The new decrees governing the IFC include the following: Decree No. 323/2025/ND-CP on the establishment of the IFC. Decree No. 324/2025/ND-CP on financial policies applicable within the IFC. Decree No. 325/2025/ND-CP on labor, employment, and social security within the IFC. Decree No. 326/2025/ND-CP on land and environmental matters within the IFC. Decree No. 327/2025/ND-CP on entry, exit, and residence of foreign nationals in the IFC. Decree No. 328/2025/ND-CP on the International Arbitration Center of the IFC. Decree No. 329/2025/ND-CP on banking licensing, foreign exchange management, and anti-money laundering and combating the financing of terrorism (AML/CFT) within the IFC. Decree No. 330/2025/ND-CP on the establishment and operation of commodity exchanges within the IFC. Taken as a whole, these eight decrees translate the IFC Resolution into a coherent and fully operational legal regime governing the establishment, organization, and functioning of Vietnam’s IFC. Collectively, they demonstrate that Vietnam’s IFC framework is best understood not as a collection of isolated incentives, but as a deliberately designed and integrated regulatory system. The Legal Architecture of the IFC: Four Interlocking Pillars Read together, the decrees seem to be designed to address four core regulatory questions from the outset: (i) what the IFC is, from a legal and institutional perspective; (ii) who may participate in the IFC and what activities are permitted; (iii) how people, capital, and projects operate on a day-to-day basis within the IFC; and (iv) how disputes are resolved,