Thailand

YEAR IN REVIEW

(1 July 2024 to 30 June 2025)

Significant developments in Thailand’s ESG landscape which reflect a clear shift toward harmonisation with global standards and greater transparency in sustainability reporting.
Issuance of a roapmap to integrate the ISSB Standards into existing ESG disclosure requirements. The goal is to phase-in mandatory reporting rules fully-aligned with the ISSB Standards, starting with climate disclosures of larger listed companies from 2026.
Regulatory frameworks for a mandatory ETS and carbon tax system are in progress.
A draft framework on a mandatory human rights and environmental due diligence law is under discussion.

Scroll down or click below for further information on each key theme.

PODCAST OVERVIEW

Please click on the podcast above for a snapshot of the three key themes of ESG reporting, transition planning and greenwashing risks in respect of Thailand.

KEY CONTACTS

	V. Joseph Tisuthiwongse Partner, Chandler MHM
	Sooksun Popun-Ngarm Counsel, Chandler MHM

A. ESG Reporting

1. Are there legal or regulatory requirements for companies to make ESG disclosures in your jurisdiction?

Yes.

2. What are the key legislative and regulatory sources for ESG disclosure requirements and to whom do they apply?

ESG-related disclosures are mandatorily required for listed companies and sustainable and responsible investing funds (SRI Funds).

The Security Exchange Commission (SEC) has issued the following guidelines:

reporting guidelines which include the disclosure of ESG aspects (SEC Reporting Guide) to be reported annually (in Form 56-1 (One Report)) by Thai listed companies;^[1] and
disclosure guidelines for asset managers of SRI Funds as a measure to prevent greenwashing. The disclosure requirements apply to mutual funds which invest in sustainable and responsible projects in accordance with international standards, such as the United Nations Global Compact, the United Nations Sustainable Development Goals, the TCFD, and the International Capital Market Association’s Green Bond Principles.

[1] The SEC also advises that securities-issuing companies and financial advisors can use this guideline as a reference for preparing a Registration Statement for Securities Offering (Form 69-1) as well.

3. Are the requirements mandatory or do they apply on a comply-or-explain basis?

Pursuant to the SEC Reporting Guide, environmental aspects are on a “comply-or-explain” basis. If a listed company does not disclose their GHG emissions, the company must clarify their reasoning for not making this disclosure. Further, in the event a listed company may be in material breach of environmental laws, it must clarify the relevant facts, reasons, impacts and measures taken to remedy the breach.

The disclosure guidelines for SRI Funds contain mandatory disclosures in relation to ESG.

4. Which aspects of ESG do the requirements focus upon?

Under the SEC Reporting Guide, environmental, social and governance aspects are covered for listed companies.

The disclosure guidelines for SRI Funds focus on the disclosures of investment objectives, goals that the fund aims to achieve, and types and characteristics of securities that the fund focuses on investing in, which prioritise globally recognised sustainability and ESG aspects such as climate change, environmental protection, low carbon footprint or reducing inequality.

5. Are the disclosure requirements based on international standards? If so, which one(s)?

According to the SEC Reporting Guide, listed companies are encouraged (but not required) to align with international standards. For social aspects, companies are encouraged to implement international standards in their internal policies, such as the UN Guiding Principles on Business and Human Rights, or the OECD Guidelines for Multinational Enterprises. Listed companies may also disclose their social and environmental aspects based on the guidelines provided by the GRI.

The disclosure guidelines for SRI Funds are based on IOSCO’s Recommendations for Sustainability-Related Practices, Policies, Procedures and Disclosures in Asset Management (Final Report).

Under a policy introduced by the Bank of Thailand (BOT) on the business operations of financial institutions in consideration of environmental perspectives and climate change (BOT Policy), financial institutions are encouraged to disclose their sustainability activities in accordance with acceptable or international standards, such as the TCFD or ISSB Standards. Please see section A.12 below for more detail.

6. How do the disclosure requirements approach materiality (e.g. single or double materiality)?

The disclosure requirements under the SEC Reporting Guide adhere to a double materiality approach, while the disclosure guidelines for SRI Funds focuses on impact materiality.

7. Are there requirements for the disclosure of GHG emissions? If so, please specify the scope (e.g. Scope 1, Scope 2 and/or Scope 3), to whom they apply and whether there are requirements on the measurement methodology.

Yes. The SEC Reporting Guide requires disclosure of direct and indirect GHG emissions with a measurement standard that is internationally recognised (e.g., ISO 14064-1:2018). At present, the disclosure requirements only apply to Scope 1 and Scope 2 GHG emissions.

8. Are there requirements to obtain independent assurance of any ESG disclosures? If so, what is the scope of such requirements? If not, are there plans to introduce such requirements?

There are currently no mandatory assurance requirements.

However, the SEC is moving toward introducing such requirements, particularly for GHG emissions data. As part of the SEC’s proposed ISSB Roadmap (see section A.11 below), companies will be required to obtain ‘limited assurance’ for their GHG emissions disclosures. The assurance must be provided either by verifiers registered with the Thailand Greenhouse Gas Management Organisation or by entities that adhere to internationally recognised verification standards.

This planned requirement is designed to enhance the reliability and comparability of GHG-related data, aligning Thailand’s ESG disclosure practices with international best practices and the ISSB Standards.

9. For companies not subject to mandatory or comply-or-explain ESG reporting, are voluntary ESG disclosures customary?

In recent years, there has been an increasing trend in ESG disclosures, where many private companies acknowledge the significance of being transparent and accountable with respect to their ESG impacts and standards.

Listed companies are influenced to adopt ESG policies by the Stock Exchange of Thailand’s mandatory reporting requirements. As there are no penalties for not having such policies, each company's progress depends on institutional and stakeholder pressure.

The SEC is preparing to introduce mandatory ESG reporting requirements under its proposed ISSB Roadmap. These new rules will apply to listed companies and certain specified entities (see section A.11 below for further detail).

10. Has your jurisdiction issued or adopted a taxonomy on sustainable activities? Is it mandatory and what is its scope of application?

Thailand Taxonomy, Phase 1 and Thailand Taxonomy, Phase 2 (together, the Thailand Taxonomy) were officially announced on 30 June 2023 and 27 May 2025, respectively. While Phase 1 focused primarily on the energy and transportation sectors, Phase 2 significantly expanded the taxonomy’s scope to include agriculture, manufacturing, real estate and construction, and waste management sectors.

The Thailand Taxonomy serves as a voluntary reference framework and is not currently mandatory. It is intended to provide guidance for financial institutions and businesses in identifying and classifying environmentally sustainable economic activities, in alignment with international standards.

11. Are there plans to adopt or incorporate any (other) international ESG reporting framework (e.g. the ISSB Standards and/or the TNFD)? If so, please give details.

The SEC has proposed the adoption of the IFRS S1 and IFRS S2 as part of its ESG disclosure reform initiative, known as the ‘ISSB Roadmap’.

The objective is to fully align Thailand’s ESG disclosure requirements with the ISSB Standards, transitioning from the current ‘comply or explain’ model to a mandatory disclosure regime. The proposed requirements will apply to the following entities:

listed companies in Thailand, whether they are Thai or foreign companies and/or companies offering securities to the public (IPOs);^[1]
Real Estate Investment Trusts (REITs);
Infrastructure Trusts;
Property Funds; and
Infrastructure Funds.

The SEC has proposed a phased-in approach for the adoption of the ISSB Standards (IFRS S1 and IFRS S2). The proposed implementation timeline is as follows:

2026 (reporting in 2027): SET50 companies^[2];
2027 (reporting in 2028): SET100 companies^[3];
2028 (reporting in 2029): All SET-listed companies and new IPOs on SET; and
2029 (reporting in 2030): All mai-listed companies^[4], new IPOs on mai, REITs, Infrastructure Trusts, Property Funds, and Infrastructure Funds.

The SEC’s proposal underwent public consultation, which concluded on 19 December 2024. The SEC is expected to conduct a further public hearing on the draft implementing regulations by the third quarter of 2025, with formal adoption to follow.[5]

To facilitate a smooth transition, the SEC has proposed a number of transitional relief measures, including:

exemption from comparative reporting in the first year of disclosure;
allowing companies to report only climate-related information (IFRS S2 and relevant parts of IFRS S1) for the first five years, before expanding to full sustainability disclosures;
flexibility in the timing of sustainability reporting, allowing a different timeline from financial reporting for the first five years;
permitting the use of various GHG accounting standards (such as GHG Protocol 2004 or equivalent) for the first five years, after which only GHG Protocol 2004 will be accepted; and
allowing companies to report only Scope 1 and Scope 2 GHG emissions for the first five years, with Scope 3 reporting required thereafter.

[1] This does not include companies offering securities and companies listed on the LiVEx (Live Exchange).

[2] The 50 largest and most liquid companies on the Stock Exchange of Thailand (SET).

[3] The 100 largest and most liquid companies on the SET.

[4] Market for Alternative Investment.

[5] According to our discussion with the SEC officer, on a no-name basis.

12. Other upcoming developments / direction of travel

The BOT Policy seeks to raise the standard of governance, strategy, risk management, and disclosures of financial institutions to be in line with international standards, such as the UN’s Principles for Responsible Banking, Principles for Responsible Investment and the Equator Principles. To support implementation, the BOT has released an industry handbook designed to assist financial institutions in integrating environmental and climate risk considerations into their internal processes.

The initial phase of the policy rollout, which began in early 2024, required financial institutions to conduct a self-assessment in accordance with the BOT Policy and the guidance set out in the industry handbook.

At present, the BOT has indicated that ESG-related disclosures will not be made mandatory. Instead, the BOT Policy will continue to serve as a voluntary, principle-based framework designed to guide institutions in their sustainability initiatives.

There is growing momentum towards the development of mandatory human rights and environmental due diligence (mHREDD) legislation in Thailand. On 13 February 2025, the Ministry of Justice convened a multi-stakeholder consultation to initiate discussions on the potential drafting of an mHREDD law. This initiative is aligned with Thailand’s international commitments under the UN Guiding Principles on Business and Human Rights and the Universal Periodic Review. An initial draft law, prepared with technical support from the European Union and Thammasat University, seeks to align Thailand’s domestic legal framework with international standards on responsible business conduct. As of now, an official draft has not been released for public consultation.

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B. Transition Planning

1. Has your jurisdiction set decarbonisation targets and strategies?

Yes – Thailand has taken many steps towards becoming a carbon-neutral country by 2050 and achieving net-zero emissions by 2065 in accordance with its updated NDCs to the Paris Agreement.

Energy transition policies have been implemented primarily by Thailand's Ministry of Energy and its departments, as well as the state electricity utilities. Under the current Power Development Plan (PDP) and Alternative Energy Development Plan, renewable energy is targeted to increase to 30% of total energy consumption by 2037. However, in light of Thailand’s most recent NDCs, it is likely that the mid-term renewable energy projections will need to increase significantly.

The latest draft of the PDP, covering the period 2024 to 2037, proposes an increase in the share of renewable energy in Thailand’s power generation mix to 51% by 2037, reflecting a more ambitious decarbonisation trajectory.

2. Are businesses subject to any mandatory carbon pricing or other “polluter pays” instruments (such as ETS, carbon taxes or EPR schemes)? If so, please give details. If not, are there plans to do so?

There are currently no such mandatory mechanisms in Thailand. However, significant regulatory developments are underway in both areas:

Ministerial Regulation Prescribing Excise Tax Rates (No. 41) under the Excise Act, B.E. 2560 (2017) - this regulation took effect on 28 March 2025 and introduces a carbon pricing component into the excise tax regime for oil and oil products, setting a carbon price at THB 200 per ton of CO₂ equivalent. The objective is twofold: (i) to increase public awareness of carbon pricing mechanisms, particularly in light of the EU’s CBAM and (ii) to serve as a preliminary step towards the implementation of a broader carbon tax system anticipated under the forthcoming climate change legislation (discussed in (ii) below).
Draft climate change bill - the second draft of this bill has completed its public consultation phase. It aims to provide legal certainty for stakeholders regarding GHG mitigation and adaptation through:

(i) the establishment of a national GHG inventory;

(ii) mandatory reporting obligations for designated state agencies and private entities on the amount of greenhouse gas emissions generated from their business operations, facilities, or related activities; and

(iii) a framework for the trading and verification of carbon credits.

The bill also proposes two principal carbon pricing mechanisms:

(i) A mandatory ETS - managed by the Department of Climate Change and Environment (Ministry of Natural Resources and Environment), which will issue emission allocation plans and facilitate trading of allowances in accordance with Thailand’s securities and exchange regulations applicable to the regulated entities (to be prescribed in a separate ministerial regulation); and

(ii) Carbon Tax System - this would impose a tax on industrial manufacturers, producers and importers based on the lifecycle GHG emissions of their goods.

The Department of Climate Change and Environment is expected to submit the bill to the Cabinet within 2025. Upon Cabinet approval, the draft will enter the formal legislative process.

c. Draft legislation to introduce mandatory EPR schemes – draft laws applying mandatory EPR in respect of packaging, industrial waste and e-waste are under development. The goal is to enact the EPR law on packaging (the Sustainable Packaging Management Act) by 2027.

3. Are there mandatory requirements for companies to have in place and/or disclose climate-related transition plans? If so, please give details. If not, are there plans for such requirements?

It is not mandatory to have a transition plan.

However, the SEC Reporting Guide contains a requirement for listed companies to disclose plans (if any) to achieve any environmental targets (including GHG emission targets) and social targets they have set. This disclosure requirement is voluntary.

Looking ahead, if Thailand adopts the ISSB Standards under the proposed ISSB Roadmap, the reporting framework will shift significantly. Companies subject to the new disclosure obligations will be required to provide detailed disclosures on their climate transition plans, including:

strategies to achieve climate-related targets;
implementation timelines and key milestones;
governance and risk management associated with the transition; and
financial impacts and resource allocations.

Furthermore, listed companies may voluntarily align with the Thailand taxonomy to demonstrate their commitment to sustainability and to access sustainable finance. Therefore, companies may include their transition plans, including the ESG aspects, which align with the Thailand Taxonomy in their annual reports.

4. Are there mandatory requirements to set, meet and/or disclose climate-related targets? If so, please give details. If not, are there plans for such requirements?

The SEC Reporting Guide does not require listed companies to set or meet climate-related targets, except that listed companies are recommended to disclose their GHG emission targets.

As mentioned above, the BOT Policy encourages financial institutions to disclose their sustainability efforts in accordance with acceptable or international standards, such as the TCFD or ISSB, with such standards incorporating the disclosure of any climate-related targets set by the reporting entity.

Thailand is in the process of adopting the ISSB Standards through the SEC’s ISSB Roadmap. Once implemented, these will mandate disclosure of climate-related targets and associated transition plans for companies subject to the new regime. Under IFRS S2, companies will be required to disclose:

climate-related targets that they have set or are required to meet, including GHG emissions reduction targets;
timelines and milestones for achieving those targets;
quantitative and qualitative metrics used to measure progress; and
how these targets are embedded into the entity’s broader risk management and strategic planning processes.

5. Other upcoming developments / direction of travel

Thailand is actively preparing for its transition to a decarbonised economy, as reflected in ongoing efforts to modernise its regulatory framework in alignment with global climate goals. Notably, the BOT, in collaboration with the Thai Bankers' Association, is developing a comprehensive transition plan aimed at addressing GHG emissions linked to the business activities of financial institutions, with particular emphasis on Scope 3 (financed) emissions.

This initiative seeks to establish a standardised framework to guide financial institutions in formulating and implementing their own transition strategies. The overarching objective is to support the broader business sector in adapting to climate-related risks and opportunities in a practical and effective manner, balancing international best practices with the unique characteristics and development pathway of Thailand’s economy.

These efforts underscore Thailand’s commitment to facilitating an orderly and inclusive transition toward a low-carbon economy, while ensuring that the financial sector plays a central role in mobilising sustainable finance and managing climate-related risks.

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C. Greenwashing Risks

1. Are there any recent examples of legal proceedings, regulatory actions or investigations against or into greenwashing in your jurisdiction?

We are not aware of any recent legal proceedings, regulatory actions or investigations against or into greenwashing.

2. Are there any laws or regulations specifically dealing with greenwashing?

There are currently no specific laws or regulations in Thailand that directly address greenwashing.

3. What are the likely grounds on which such proceedings, actions or investigations can be instigated?

Likely grounds would include:

disclosure liabilities under the SEC's laws and regulations, e.g. providing materially false or misleading information in the annual report or disclosure documents;
breaches of directors’ duties; and/or
claims in tort for misrepresentation.

4. Other upcoming developments / direction of travel

The upcoming adoption of ESG disclosure standards aligned with the ISSB Standards by the SEC is expected to significantly enhance the detection and prevention of greenwashing. By implementing a globally consistent ESG reporting framework, investors and stakeholders will be better equipped to verify and compare ESG information in a reliable and consistent manner across companies. The use of a universal standard will require all reporting entities to disclose ESG data based on the same criteria and structure, thereby minimising the risk of arbitrary, selective, or misleading disclosures. This harmonisation will promote greater transparency, comparability, and credibility of ESG reporting, making it more difficult for companies to exaggerate or misrepresent their sustainability performance. In essence, a single global standard will ensure that all companies are ‘speaking the same language,’ thereby strengthening market confidence and accountability in ESG reporting.

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