On 3 November 2026, the Securities and Exchange Commission of Thailand announced revised disclosure rules for sustainable (SRI) mutual funds in News No. 239/2569. The rules took effect on 1 November 2026 and make two changes. First, Thai ESG and Thai ESGX funds that hold shares in companies in SET’s JUMP+ programme must now report, in the factsheet’s Sustainability Corner, how much of the fund sits in those companies, how far those companies have got with their published plans, and how many of them the fund manager has engaged with. Second, SRI funds will disclose their sustainability reference index in the prospectus and factsheet rather than in the fund project, so a manager can change the index without amending the project.
For JUMP+ companies, this widens the audience. Until now, a JUMP+ progress report was read by SET, by analysts at roadshows and by anyone who went looking. From now on, asset managers must sort their holdings into progress categories and print the result in a document that retail investors receive. Whether a company delivered on its published plan becomes something investors can see.
What the SEC changed on 1 November
The release adds three items to the Sustainability Corner of a Thai ESG or Thai ESGX fund that holds JUMP+ stocks:
- the share of the fund invested in JUMP+ companies;
- the number of JUMP+ companies held, and their share of the fund, broken down by progress against their JUMP+ plans; and
- the share of JUMP+ companies the asset manager has engaged with.
Holdings and progress data must be updated at least every six months, and engagement data at least once a year. The SEC consulted twice, from 30 April to 5 June 2026 and from 7 August to 6 September 2026, and says most respondents supported the changes. The legal basis is two notifications: SorNor. 24/2569 on fund project details and SorNor. 25/2569 on the prospectus and the Form 123-1 factsheet.
JUMP+ is SET’s programme for raising the value of listed companies. Each company publishes a three-year plan covering business growth, governance and, if it chooses, climate action, and reports progress every six months. When registration closed on 31 March 2026, 143 companies had signed up, about 16% of the 868 companies then listed.
The three categories your company can land in
The August hearing document, Or.Nor.Jor. 49/2569, included a draft factsheet table showing how the progress breakdown is meant to work. It sorts JUMP+ holdings into three categories and gives, for each, the number of companies and their share of the fund’s NAV, as at a stated date. The draft describes each category without naming it, so the names below are our own.
The company has carried out all the key items in its JUMP+ plan, meaning its business plan, its governance plan and its climate plan if it has one.
The company has carried out some of the key items and has stated how it will improve or correct the rest.
The company has carried out some of the key items but has not stated any corrective measures. No board wants to be in this row of a retail factsheet.
N is the number of JUMP+ companies the manager engaged with in the past year; M is the number of JUMP+ companies the fund holds. The draft’s example is 6 of 10, or 60%. Direct meetings, joint engagement with other investors and public forums such as Opportunity Day all count, and each company counts once.
What separates categories 2 and 3 is not performance but disclosure. A company that missed a milestone and wrote down how it will recover lands in a better category than one that missed the same milestone and said nothing. The company makes that choice in its own progress report.
Missing a milestone is one thing. Missing it and saying nothing about how you will recover puts you in a different category, and that category now appears in a fund factsheet.
Othello International, on SEC News 239/2569Why the benchmark change matters more than it looks
The second change looks administrative. Today an SRI fund states its sustainability reference index in the fund project, and amending a fund project is slow. The SEC says that moving the index to the prospectus and factsheet lets managers change it more easily as fund objectives and international standards evolve, while investors can still see which index is used.
The timing matters. SET has said that 2025 was the final cycle of SET ESG Ratings and that from 2026 it will publish FTSE Russell ESG Scores instead. In July 2026, FTSE Russell and SET launched the FTSE4Good Thailand Index, which had 119 constituents at the end of July. When the yardstick for “sustainable” Thai equities changes, managers need to be able to change their reference index too, and the new rule makes that easier. The SEC release does not name any index, and we have not verified any particular fund’s switch, so we make no claim about which index a given fund will adopt.
What we can say is this. FTSE Russell scores companies on public disclosure only; there is no questionnaire. Its ESG Scores FAQ (v1.5, §1.8) names six key research languages: English, French, Spanish, German, Japanese and Chinese. Thai is not one of them. If reference indices move toward FTSE-based measures, the English edition of a company’s disclosure is more likely to be the version a global analyst reads. Its accuracy is therefore worth controlling, not leaving to chance.
Old rule and new rule, side by side
| Before 1 November 2026 | From 1 November 2026 | |
|---|---|---|
| JUMP+ in the factsheet | Not required | % of fund in JUMP+ stocks, holdings by progress category, engagement ratio |
| Update frequency | n/a | Holdings and progress at least every 6 months; engagement at least yearly |
| Sustainability reference index | Stated in the fund project | Stated in the prospectus and factsheet, so easier to change |
| Who reads it | Mainly SET, analysts and roadshow audiences | Also retail investors in Thai ESG and Thai ESGX funds |
| What decides a company’s category | n/a | Delivery of key plan items, and whether a remediation plan is disclosed |
What this means for a JUMP+ company
The commercial point is simple. A JUMP+ plan was a public promise. Under this rule a fund manager has to judge whether you kept it and print that judgement twice a year. Clear, specific, verifiable progress reports make that judgement easy for the manager. Vague ones leave the judgement entirely to the manager.
Where the evidence runs out
- We read the SEC’s Thai-language release and the August hearing document with its draft factsheet table. We have not read the final gazetted texts of SorNor. 24/2569 and 25/2569, so the three progress categories come from the draft and may have been reworded in the final rules.
- The draft does not say what evidence a manager must use to place a company in a category, or how “key plan items” are defined. Managers may judge differently.
- Nothing in the release ties the factsheet rule to any language. Thai ESG fund factsheets are Thai-language retail documents. Our point about English concerns FTSE Russell’s research process, not this rule.
- We have not verified any asset manager’s change of reference index, nor an exact date for the first public FTSE Russell ESG Scores for Thai companies. Thai companies also already score reasonably well: SET reports an average FTSE ESG Score of 3.6 across 222 companies in the 2025 round. This is about visibility and control, not a penalty.
What to do before the first factsheet
- Re-read your last JUMP+ progress report as a fund manager would. For each key item, is it clear whether it was delivered?
- For any milestone that slipped, publish the remediation plan. That is what separates category 2 from category 3.
- Put verified numbers behind climate items. A TGO CFO certification gives a target a verified baseline.
- Check that the English summary says the same as the Thai. A FTSE disclosure gap audit shows where it does not.
- Follow the final notifications and any index changes on our ESG regulatory tracker.
Make your JUMP+ progress easy to grade
Othello is a registered firm in SET’s JUMP+ Advisory Pool. We help you write progress disclosure a fund manager can assess, build the TGO-certified carbon numbers behind your climate items, and produce an ISO 17100 English edition that matches the Thai.
See bilingual One ReportFor background, see our analysis of all 142 published JUMP+ plans, our comparison of the six main raters in ESG ratings compared, and why FTSE Russell’s research languages matter in FTSE and English disclosure. If the English edition is where the gap is, our technical translation team works to ISO 17100.
Sources: SEC Thailand, News No. 239/2569 (3 November 2026) on revised SRI fund disclosure rules, Notifications SorNor. 24/2569 and 25/2569; SEC Thailand, public hearing Or.Nor.Jor. 49/2569 (7 August – 6 September 2026) and its draft factsheet table; SET, close of JUMP+ registration (143 companies, 31 March 2026), as reported by ASEAN Exchanges and Daily News; FTSE Russell ESG Scores and Indices FAQ v1.5 (December 2025), §1.8; LSEG FTSE4Good Thailand Index factsheet (data as at 31 July 2026); SET × FTSE Russell 2568 results infographic.
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