Thailand

Yes.

Listed companies and Sustainable and Responsible Investing funds (SRI Funds) are required to make ESG-related disclosures.

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

1. 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; and
2. 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 UN Global Compact, the UN Sustainable Development Goals (SDGs), the TCFD, and the International Capital Market Association’s Green Bond Principles.

Pursuant to the SEC Reporting Guide, environmental aspects are on a “comply-or-explain” basis. If a listed company does not disclose its GHG emissions, the company must clarify its 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.

Thailand is, however, transitioning towards a mandatory sustainability disclosure regime for listed entities. The SEC has introduced amendments to align the country’s sustainability reporting framework with IFRS S1 and IFRS S2, under which sustainability-related financial disclosures will become mandatory on a phased basis, with implementation determined according to the size and category of listed companies.

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

Under the SEC Reporting Guide, environmental, social and governance aspects are covered for listed companies. As Thailand transitions towards the IFRS S1 and IFRS S2 sustainability disclosure framework, the initial phase of mandatory reporting focuses on climate-related financial disclosures. These include climate-related disclosures relating to governance, strategy, risk management, metrics and targets, as well as Scope 1 and Scope 2 GHG emissions, with additional sustainability-related disclosures to be introduced in subsequent phases.

The disclosure guidelines for SRI Funds focus on disclosure 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. During the reporting period, the SEC enhanced the regulatory framework applicable to SRI Funds by introducing more comprehensive disclosure requirements, standardised SRI fund labels and enhanced supervisory measures.

According to the SEC Reporting Guide, listed companies are encouraged (but not required under the current framework) 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 Standards.

Following a public consultation, the SEC has resolved to align Thailand's sustainability disclosure framework with both IFRS S1 and IFRS S2. The new framework will be implemented on a phased basis, beginning with a climate-first approach. 

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 Recommendations or ISSB Standards. Please see section A.12 below for more detail.

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

The upcoming sustainability disclosure regime for listed entities adopts a single materiality approach in line with the ISSB Standards.

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.

As part of Thailand’s transition to an ISSB-aligned sustainability disclosure regime, the SEC has adopted a phased implementation of IFRS S1 and IFRS S2. The initial phase focuses on climate-related disclosures, including Scope 1 and Scope 2 GHG emissions, and applies first to larger listed companies before being progressively extended to other listed companies. The framework also provides transition reliefs, including a climate-first approach and the deferral of mandatory Scope 3 GHG emissions disclosures during the initial implementation period.

There are currently no mandatory assurance requirements.

However, Thailand is moving towards the introduction of mandatory assurance requirements as part of the SEC’s implementation of an ISSB-aligned sustainability disclosure framework. Mandatory assurance requirements will apply to listed entities according to the phased implementation timeline outlined in section A.11 below. The SEC has indicated that assurance providers may include verifiers registered with the Thailand Greenhouse Gas Management Organization or other providers applying internationally accepted assurance standards.

This 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.

Listed companies may voluntarily publish sustainability reports or climate-related disclosures based on internationally recognised frameworks, including the UN SDGs, the GRI Standards, IFRS S1 and IFRS S2 and the TCFD Recommendations. Such voluntary reporting is commonly adopted by large companies to meet investor, lender and stakeholder expectations and to demonstrate alignment with international ESG best practices. However, the SEC will be phasing in mandatory ESG reporting requirements for listed entities as noted in section A.11 below.

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

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.

During the current reporting period, the Draft Climate Change Act was approved in principle by the Cabinet. If enacted, the legislation is expected to establish Thailand’s overarching climate governance framework, including mechanisms relating to greenhouse gas reporting, a national greenhouse gas registry, emissions trading and other climate-related measures. Although the draft legislation may further support the use of the Thailand Taxonomy within Thailand’s sustainable finance ecosystem, the taxonomy itself is expected to remain voluntary unless mandatory implementation measures are introduced under future legislation or subordinate regulations.

The SEC has decided to apply IFRS S1 and IFRS S2 to listed entities on a full-alignment basis and transition from the current ‘comply or explain’ model to a mandatory disclosure regime.

The SEC has decided it will phase in the ISSB Standards for companies, REITs, infrastructure trusts, property funds and infrastructure funds listed on The Stock Exchange of Thailand (SET) based on the following implementation timeline:

1. 2027 (reporting in 2028): SET50 companies;
2. 2028 (reporting in 2029): SET100 companies;
3. 2029 (reporting in 2030): all SET-listed companies and new IPOs on SET; and
4. 2030 (reporting in 2031): all mai^[1]-listed companies, new IPOs on mai, SET-listed REITs, infrastructure trusts, property funds and infrastructure funds, and new IPOs of such entities.

The timeline has been pushed back by one year compared to the originally proposed timeline in the SEC’s initial consultation which concluded on 19 December 2024.

There will be transitional relief measures allowing entities to disclose only climate-related information during the first five years of the reporting requirement and exempting them from disclosing Scope 3 GHG emissions during the same transitional period. 

The BOT Policy continues 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 Principles for Responsible Banking, the Equator Principles, the TCFD Recommendations and the ISSB Standards. 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.

At present, the BOT has indicated that ESG-related disclosures and risk management 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.

The SET has continued to strengthen ESG reporting capabilities through initiatives such as the ESG Data Platform and SET Carbon. The ESG Data Platform provides listed companies with a centralised source of ESG indicators and reporting data, while SET Carbon assists companies, particularly small and medium-sized listed companies, in measuring and calculating their GHG emissions to support sustainability reporting.

Yes. Thailand has taken multiple steps towards becoming a carbon-neutral country by 2050 and achieving net-zero GHG 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 Ministry of Energy is currently preparing a new Power Development Plan (PDP 2026), which is expected to form part of the new National Energy Plan and provide an updated roadmap for Thailand's energy transition. The new PDP is anticipated to place greater emphasis on renewable energy deployment, electricity market reform, energy storage, transmission infrastructure and other measures necessary to support Thailand's carbon neutrality and net-zero commitments. According to current government plans, the new PDP is expected to be released in September 2026.

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

1. 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 (b) below).
2. Draft climate change bill – following its approval in principle by the Cabinet, the Draft Climate Change Act is expected to establish Thailand’s overarching climate governance framework. Once enacted and supplemented by subordinate legislation, it is anticipated to introduce a comprehensive regulatory package that includes a mandatory ETS, CBAM, legal entity-level GHG reporting obligations, a national GHG registry, and other carbon pricing and market mechanisms. There is currently no concrete timeline for its enactment.
   
   In more detail, the climate change bill aims to provide a legal framework for GHG mitigation and adaptation through:

(i) a national GHG reduction plan;

(ii) a national GHG inventory;

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

(iv) a framework for the trading and verification of carbon credits;

(v) 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);

(vi) Carbon Tax System - to impose a tax on industrial manufacturers, producers and importers based on the lifecycle GHG emissions of their goods;

(vii) CBAM - to address carbon leakage and GHG emissions associated with imported goods prescribed by ministerial regulations.

Key details including covered sectors and entities, allocation rules, tax rates, CBAM methodology, registry procedures and penalties, are expected to be set out in subordinate legislation. Businesses in emissions-intensive sectors and importers should therefore monitor the legislative process and begin preparing emissions data systems.

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. 

Under the ISSB-aligned framework developed by the SEC noted in section A.11 above, entities within scope of the phased implementation will be required to disclose information on any climate-related transition plans they have adopted, where such plans are material, including:

1. strategies to achieve climate-related targets;
2. implementation timelines and key milestones;
3. governance and risk management associated with the transition; and
4. 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.

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.

As Thailand implements the phased adoption of the ISSB-aligned disclosure framework, entities within the scope of the phased implementation will be required to disclose climate-related targets and, where applicable, information about any climate-related transition plans they have adopted. Under IFRS S2, companies will be required to disclose:

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

At present, Thailand does not impose any general mandatory circular-economy or eco-design requirements on businesses. Instead, circular economy initiatives are primarily driven through government policy, including the Bio-Circular-Green (BCG) Economy Action Plan and the National Waste Management Action Plan, which promote resource efficiency, waste reduction and recycling on a voluntary and sector-specific basis.

However, a Draft Sustainable Packaging Management Act is under development to introduce mandatory EPR schemes in respect of packaging. The goal is to enact this by 2028. It would introduce Thailand’s first comprehensive EPR regime for packaging whereby producers, importers and certain distributors of products using regulated packaging would become responsible for the collection, reuse, recycling or environmentally sound disposal of post-consumer packaging. The proposed regime is expected to apply to a wide range of packaging materials, including glass, metal, paper, plastic and composite packaging.

In parallel, the government is continuing to develop policy and legislative measures relating to industrial waste and electronic waste.

Thailand does not currently have an economy-wide corporate sustainability due diligence regime comparable to the EU's CSDDD.

However, a significant development in this area is the Ministry of Justice's ongoing work on the Draft Act on the Promotion of Responsible Business Conduct. Based on publicly available draft proposals, the legislation would initially apply to Thai large enterprises with annual revenue exceeding THB 500 million in the manufacturing sector, or THB 300 million in the wholesale, retail or service sectors and would require them to identify, assess, prevent, mitigate and account for actual and potential adverse human rights and environmental impacts arising from their own operations, subsidiaries and business relationships throughout their value chains. The proposed framework would also require appropriate governance, risk management and public reporting. The draft Act provides for administrative fines of up to THB 5 million for non-compliance with key due diligence obligations, up to THB 1 million for failure to adopt the required policy, and up to THB 500,000 for failure to submit the required report or comply with regulatory orders. The imposition of such administrative penalties would be without prejudice to any civil or criminal liability that may arise under other applicable laws.

The Ministry of Justice issued the first draft of the bill in July 2025. Although the draft legislation remains under development, it signals a clear policy direction towards the introduction of mandatory corporate sustainability due diligence requirements broadly aligned with international standards, including the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.

The draft is currently at the public consultation and policy development stage. The Ministry of Justice continues to consult with stakeholders and refine the draft before it proceeds through the formal legislative process. While it is difficult to predict the legislative timeline, we expect the bill to continue progressing as part of Thailand’s efforts to align its legal framework with OECD standards in support of its accession process.

Thailand has introduced a range of policy initiatives to mobilise capital towards sustainable investment and support the transition to a low-carbon economy. These initiatives combine regulatory reforms, sustainable finance frameworks, investment incentives and public-private partnerships.

Key measures include:

• Sustainable finance frameworks. Thailand has developed the Thailand Taxonomy, which is intended to provide a common reference for financial institutions, investors and businesses and to facilitate sustainable financing. In parallel, the SEC has introduced a phased roadmap for mandatory sustainability-related disclosures aligned with IFRS S1 and IFRS S2, while the SET continues to support listed companies through the SET ESG Ratings and the ESG Data Platform, which facilitate ESG reporting and improve the availability and comparability of sustainability data.
• Financial incentives. Thailand offers a range of fiscal and non-fiscal incentives to encourage investment in sustainable projects. Through the Board of Investment, eligible projects in priority sectors, including renewable energy, solar power generation, energy efficiency, electric vehicles, battery technologies and other green industries, may qualify for corporate income tax exemptions, import duty exemptions and other investment incentives.
• Public-private initiatives. The Thai government continues to promote sustainable finance and the circular economy through collaborative initiatives involving the public and private sectors. For example, the PPP Plastics initiative brings together government agencies, businesses and civil society organisations to support Thailand’s Roadmap on Plastic Waste Management through investment, innovation and capacity-building. Similar partnerships have been established to promote sustainable finance, biodiversity conservation and climate resilience.

These policy initiatives have contributed to continued growth in Thailand’s sustainable finance market. By the end of 2025, Thailand had 242 ESG and corporate governance funds with assets under management exceeding THB 93 billion, while companies included in the SET ESG Ratings represented approximately 82% of the SET's total market capitalisation.

Thailand's ESG regulatory landscape is expected to continue evolving as outlined above, with increasing emphasis on mandatory sustainability reporting regulations, carbon pricing and circular economy measures, sustainability due diligence, transition finance, and alignment with international standards.

Once enacted, the Draft Climate Change Act will represent a significant milestone in establishing the legal framework for mandatory measures to support Thailand’s low-carbon transition.   

We are not aware of any such recent legal proceedings, regulatory actions or investigations.

Nevertheless, Thai regulators have continued to strengthen the regulatory framework with a view to preventing greenwashing and improving the credibility of sustainability-related disclosures. During the reporting period, the SEC enhanced the regulatory framework applicable to SRI Funds by introducing more comprehensive disclosure requirements, standardised SRI fund labels and enhanced supervisory measures. The revised framework is intended to improve transparency, promote consistency in sustainability-related disclosures and reduce the risk of greenwashing by ensuring that funds marketed as sustainable accurately reflect their stated investment objectives and strategies.

Although these regulatory developments demonstrate increased scrutiny of sustainability-related claims, they are preventive and supervisory in nature and, to date, do not appear to have been prompted by any publicly reported enforcement action or investigation concerning greenwashing.

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

Likely grounds would include:

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

The 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. 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.