As part of its membership in Lex Mundi, Tilleke & Gibbins has released the latest edition of its Guide to Doing Business in Thailand, providing an overview of the legal, regulatory, and commercial considerations for companies establishing or expanding operations in Thailand. The 2026 edition offers practical insight into the country’s business environment, investment framework, and operational requirements. The guide covers a wide range of topics relevant to foreign and domestic investors, including: Investment incentives and promotion schemes Financial facilities and banking regulations Exchange controls and money transfers Import and export regulations Business structures and incorporation options Requirements for establishing a business Operational and compliance considerations Business cessation and insolvency procedures Employment and labor laws Taxation Immigration and visa requirements Prepared by Tilleke & Gibbins lawyers across multiple practice areas, the publication outlines key aspects of doing business in Thailand, including foreign investment restrictions, regulatory compliance obligations, corporate structures, employment requirements, and recent legal and economic developments affecting investors. The publication forms part of Lex Mundi’s Country Guides series, a global collection of jurisdiction-specific reference materials prepared by member firms around the world. Together, these guides help companies evaluate opportunities, compare regulatory environments, and plan international business activities across multiple markets. The full Guide to Doing Business in Thailand 2026 is available through the button below.

Thailand’s Office of the Personal Data Protection Committee (PDPC) recently released draft guidance on records of processing activities (ROPA) for personal data controllers and processors under the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The draft guidance, which was presented to the public on July 7, 2026, addresses both controller records of collection, use, and disclosure of personal data and processor records of processing activities carried out on behalf of controllers. If implemented, the guidance will significantly expand organizational expectations for ROPA preparation, maintenance, and use across all sectors. Key Takeaways The draft guidance contains several important implications for organizations subject to the PDPA: ROPA reframed as a core accountability tool. The guidance elevates ROPA from an administrative record to a central accountability mechanism, connecting controller duties with recordkeeping obligations. ROPA as a source for privacy notices and governance documents. ROPA should serve as the primary source for privacy notices and align with consent management, retention schedules, DPIAs, incident response plans, and vendor contracts. Expanded scope across all activities. ROPA must cover all processing activities across the organization—including security, finance, HR, and external contractors—with correct controller or processor classification for each. Ongoing maintenance and auditability. ROPA must be updated for any change to systems, purposes, or processors, reviewed at least annually, and maintained with version control and a designated owner. Enhanced vendor, processor, and cross-border transfer requirements. Organizations must document all processors, external recipients, and cross-border transfers, specifying purposes, access scope, and destination countries. Linkage with risk assessment, DPIAs, and LIAs. ROPA should assign risk levels to each activity and identify when data protection impact assessments (DPIAs) or legitimate interests assessments (LIAs) are required, functioning as a risk-management tool. ROPA and data breach readiness. Incomplete ROPA can delay breach response and notification. Organizations should map data flows, vendors,

Thailand’s Personal Data Protection Act B.E. 2562 (2019) (PDPA) could soon see some important changes, as a draft bill to amend the PDPA has been introduced in the House of Representatives. The draft amendment is currently in the public consultation phase, with comments accepted from July 16 to August 15, 2026. If enacted in its current form, the amendment would make three key changes: expanding the government exemption to cover anticorruption operations, introducing a statutory definition of “government agency,” and restructuring the lawful bases for personal data processing to align with international standards. Background The PDPA has encountered several enforcement challenges since its implementation, including three core problems identified by the bill’s sponsors: (1) the current exemptions for government agencies do not cover anticorruption and misconduct-prevention operations; (2) the PDPA lacks a clear statutory definition of “government agency,” causing legal uncertainty as to which entities are covered; and (3) the existing framework for lawful bases of data processing does not align with international standards—particularly the multiple-lawful-bases system in the EU’s General Data Protection Regulation (GDPR)—making compliance inflexible for both government and private sector entities. Expanded Government Exemption The current PDPA exempts government agencies performing duties related to national security (including fiscal security), public safety, anti-money laundering, forensic science, and cybersecurity. The proposed amendment adds “prevention and suppression of corruption and misconduct” to this list of exempted functions. This would allow anticorruption bodies—most notably the National Anti-Corruption Commission (NACC), which is identified as a directly affected party—to collect, use, and disclose personal data without being subject to PDPA requirements when carrying out their duties. New Statutory Definition of “Government Agency” Notably, while the current PDPA use the term “government agency” in several provisions, the term is not comprehensively defined, creating potential uncertainty as to its scope. The draft bill therefore

Data protection officers (DPOs) have become a fixture of Thailand’s privacy compliance landscape since the Personal Data Protection Act B.E. 2562 (2019) (PDPA) took full effect and the Office of the Personal Data Protection Committee (PDPC) began requiring certain organizations to appoint them. On July 7, 2026, the Office of the PDPC presented draft guidance on DPOs as part of a public consultation on a series of draft personal data protection manuals and recommendations. The draft offers the clearest indication yet of how the regulator expects the DPO role to work in practice, addressing recurring implementation issues under the PDPA—including when an organization must appoint a DPO, how the DPO should operate independently, how to manage conflicts of interest, and how data subjects and regulators should be able to contact the DPO. Because it remains in draft, organizations have an opportunity to weigh the practical implications now before the guidance is finalized. When a DPO Must Be Appointed The draft guidance clarifies the triggers for mandatory DPO appointment, including: Regular and systematic monitoring of personal data or systems on a large scale, such as tracking, analyzing, or predicting behavior, attitudes, or individual characteristics. Core activities involving large-scale processing of sensitive personal data, such as health data, biometric data, or criminal records. Certain foreign-organization representative arrangements. Public-sector coverage under relevant notifications identifying government entities that must appoint a DPO. Processing involving 100,000 or more data subjects may be considered large-scale. The guidance also contemplates voluntary DPO appointment for organizations that wish to raise their privacy governance standards, and such organizations should still comply with the standards applicable to DPOs under the law. Independence and Reporting Lines The draft guidance identifies lack of DPO independence as a core risk because an ineffective or constrained DPO may be unable to raise deficiencies