Here is a sentence most Thai listed companies have never read, from a regulation that has been in force since 9 October 2017. It sits in the Stock Exchange of Thailand’s rulebook on electronic disclosure, and it quietly explains why so many SET-listed companies are invisible to the people scoring them.
Every piece of information a listed company discloses to SET must go out in Thai with an English translation, simultaneously. Board resolutions, material events, connected transactions, capital increases, dividend announcements — all of it, in both languages, at the same time. With one exception.
The Listed Company shall disclose such information in the Thai language with the English translation to the Exchange through such system, except the Company Information Statement and annual report which shall be disclosed by the Listed Company in the Thai language.
SET Regulation Bor.Jor./Or. 01-00, Clause 4 — SET’s own official English translationThe exception is the 56-1 One Report. The single document that carries your sustainability chapter, your climate governance, your emissions numbers and your board oversight disclosures is the one document Thailand’s English-translation rule expressly leaves out.
The clause: English for everything, except the annual report
The rule is Bor.Jor./Or. 01-00 — SET’s regulation on the disclosure of information and submission of documents through the electronic system. Clause 4 creates a genuine, unphased, market-wide English obligation: no SET50/SET100 tiering, no transitional relief, applicable to every listed company since 2017. On the SETLink channel, Thai companies are already a fully bilingual market.
Then it carves out “the Company Information Statement and annual report” — in Thai, แบบแสดงรายการข้อมูลและรายงานประจำปี. That is the 56-1 One Report.
The SEC takes the same position from the other direction. Notification TorJor. 44/2556 Clause 37 makes Thai the default language for reports filed with the Office. Clause 38 then says an issuer may also file in English — permissive, never mandatory. The SEC’s own published FAQ on the One Report puts the drafters’ intent on the record: the clause “was not intended to compel” companies to file an English translation of Form 56-1.
So a Thai listed company can be 100% compliant with every SET and SEC rule and still have no English version of its sustainability disclosure whatsoever. That is not a loophole anyone is exploiting. It is simply how the rules are written.
| SETLink disclosures | 56-1 One Report | |
|---|---|---|
| English translation | Required, simultaneously | Not required |
| Governing rule | SET Bor.Jor./Or. 01-00 cl.4 | Exempted by the same clause |
| SEC position | n/a | TorJor. 44/2556 cl.38 — optional |
| Carries your ESG chapter | No | Yes |
| What raters read | Rarely | This is the document |
The exempt document is the one that gets scored
FTSE Russell does not send a questionnaire. It states plainly that its ESG company research “relies on publicly disclosed information only.” Your annual report, your sustainability report and your corporate website are the assessment. There is no separate submission in which you can explain what the report meant to say.
That makes the exemption consequential in a way it simply was not a decade ago. Thailand’s ESG assessment moved onto FTSE Russell methodology from 2026, and the FTSE4Good Thailand Index launched with SET on 6 July 2026. Its Ground Rules (v1.0, June 2026) set entry at an ESG Score of 2.9 or above, with 2.4 required for continued inclusion, drawn from the FTSE SET All-Share and reviewed semi-annually in June and December.
Two hard mechanics compound the language question. First, the cut-off: only disclosures published by 30 September are considered for the December review, and 31 March for the June review. Second, lateness cannot be repaired — FTSE Russell’s recalculation guidance is explicit that information provided after the company feedback window closes is considered at the next update, not the current one. Publishing your English edition in November does not fix a December score. This is why the English edition is a score-earning asset →
What each rating body actually says about language
This is where a lot of marketing gets sloppy, so here is what the rating bodies actually publish — including where it cuts against us.
FAQ v1.5 (Dec 2025) §1.8 names its key research languages: English, French, Spanish, German, Japanese and Chinese. Thai is not among them. The same clause says provision has been made for other languages — so read this as a discoverability risk, not a stated exclusion.
The hardest rule of the four: “responses will be scored if they are submitted in English, Japanese, Chinese, Spanish and Portuguese… Responses not submitted in these languages will not be eligible for scoring.” CDP also does not score attachments or weblinks.
English is the official CSA language, but non-English public documents are accepted — and S&P machine-translates them, warning that images and graphs may translate poorly and disclaiming responsibility for “errors, ambiguities, or omissions.”
Publishes no language policy at all. We checked the March 2026 methodology and the issuer FAQs. Anyone claiming MSCI requires English filings cannot cite MSCI for it.
The honest version of this argument
We would rather you trusted the next thing we tell you, so we will state the limits of this argument clearly.
It is not true that Thai companies do not disclose in English — on the SETLink channel they overwhelmingly do, because they must. It is not true that FTSE Russell refuses to read Thai; it publishes a full Thai-language indicator methodology and says provision has been made for other languages. And there is no published study showing that an English edition raises a Thai company’s ESG score. Anyone who tells you there is has not read the literature.
What is well evidenced is the capital consequence. In JPX’s survey of overseas institutional investors, 35% said inadequate English disclosure had caused them to exclude Japanese stocks from their investment universe, 41% discounted them in valuation, and 28% reduced weights — findings material enough that the Tokyo Stock Exchange made simultaneous English disclosure mandatory for its Prime Market from April 2025. Peer-reviewed work points the same way: Jeanjean, Stolowy, Erkens & Yohn (Journal of International Business Studies, 2015) found adopting English as an external reporting language is associated with increased foreign ownership, decreased information asymmetry and increased analyst following.
The ASEAN comparison is sharper still. The ASEAN Corporate Governance Scorecard states that to be assessed and ranked, most of a company’s available documents must be in English — and records that fewer than 100 Vietnamese companies could be assessed “given the limited availability of company disclosures in English.” Vietnam has since mandated English disclosure for listed issuers, phased from January 2025. Indonesia already requires most listed issuers to publish the annual report in Indonesian and at least English. Thailand mandates English everywhere except the annual report. Compare how the raters differ →
What to do before 30 September
The December 2026 review is the first in which Thai companies are scored on FTSE Russell methodology with the FTSE4Good Thailand Index live. The publication cut-off is 30 September. That is the operative deadline, and it is close.
- Confirm whether your 56-1 One Report and sustainability chapter exist in English at all — the rules do not require it, so nobody may have asked.
- Publish the English edition before 30 September. After the cut-off it waits a full review cycle; it cannot be added retroactively.
- Treat terminology as scoring infrastructure: “carbon neutral” and “net zero” are not synonyms, and a theme that reads as vague in English reads as thin.
- Get data out of images and into text — S&P warns its own machine translation handles images and graphs badly, and automated extraction cannot read a chart.
- Make your carbon numbers TGO-certified and assurance-ready so the English edition has verified figures to carry.
See what your English edition is actually disclosing
FTSE Russell scores SET-listed companies from public disclosure — no questionnaire, with a hard 30 September cut-off. Run the free Gap Audit and see, theme by theme, what an analyst can and cannot find in English.
Run the free Gap AuditNone of this is a compliance failure. Thailand’s rules are clear, and companies are following them. But the rules were written for a market that reported to its regulator, and the audience has changed: the 56-1 One Report is now read by index methodologists and global allocators who never receive a questionnaire and never call. The exemption that was harmless in 2017 is the gap in 2026 — and closing it is an editorial job, not a regulatory one. See how a clause-mapped bilingual One Report works → or read more on where ESG translation risk actually bites.
Sources: SET Regulation Bor.Jor./Or. 01-00 cl.4 (SET rulebook, Thai original and SET’s official English translation); SEC Thailand TorJor. 44/2556 cl.37–38 and the SEC 56-1 One Report FAQ; FTSE Russell ESG Scores and Indices FAQ v1.5 (Dec 2025) §1.6, §1.8; FTSE4Good Thailand Index Ground Rules v1.0 (Jun 2026); FTSE Russell ESG Data Recalculation Policy; CDP Full Corporate Scoring Introduction 2026; S&P Global CSA Language Policy (Feb 2026); MSCI ESG Ratings Methodology (Mar 2026); JPX Survey of Overseas Investors on English Disclosure; ASEAN Corporate Governance Scorecard country reports; Jeanjean, Stolowy, Erkens & Yohn, Journal of International Business Studies 46(2), 2015.
See where your English edition is losing FTSE points.
A free Gap Audit maps your published English disclosure against FTSE Russell’s 14 themes — and shows exactly which gaps are quietly costing you points, index inclusion and investor attention.
