Thailand’s Rewritten Net Zero Rules Took Effect in July — and the Register Is Still Empty

Thailand’s Greenhouse Gas Management Organization (TGO / อบก.) has rewritten the rulebook for its Net Zero certification. The revised document — ข้อกำหนดและแนวทางการรับรองการปล่อยก๊าซเรือนกระจกสุทธิเป็นศูนย์, edition 1, revision 1 — realigns the scheme to ISO 14068-1:2023 and the SBTi Corporate Net Zero Standard, sets a hard 90% internal-reduction bar, and requires a base year covering Scopes 1, 2 and 3.

Two things about it have been widely misreported, and both are checkable in under five minutes. The first is when it starts. The second is how many Thai organisations have actually been certified under it. We read the 32-page Thai original and TGO’s own registers to establish both.

All four figures read directly from TGO’s public registers on 23 September 2026. TGO publishes no “as at” stamp on these counters, so any figure taken from them should be dated to the day it was read.

The effective date in the document is not the one the press reported

Thai coverage in early August reported that the revised criteria would take effect on 1 October 2026. That date does not appear in the document.

Page 27 of the revised criteria carries a revision-control table with four columns: ฉบับที่ (edition), แก้ไขครั้งที่ (revision number), วันที่บังคับใช้ — effective date, and รายการแก้ไข (list of changes). The single row reads: edition 1, revision 1, “1 กรกฎาคม 2569 เป็นต้นไป” — 1 July 2026 onwards. TGO’s download page dates the file itself to 2 July 2026, the day after. We could not find any TGO announcement, circular or regulation setting an October commencement date on either tgo.or.th or thaicarbonlabel.tgo.or.th.

The practical consequence is the opposite of what the October reporting implies. These are not rules arriving next week that you can still get ahead of. On the document’s own face they have been in force since the start of July — which means anyone who filed an intent letter, set a base year, or built a pathway plan over the northern summer was already working to the new text.

Zero certified organisations — and 132 in the queue

TGO’s Net Zero register has four tiers. We queried each one directly on 23 September 2026:

Not one Thai organisation holds TGO Net Zero or Net Zero Pathway certification. That is worth saying plainly, and it is worth saying fairly: a count of zero reflects a scheme still being revised as much as it reflects weak demand. The comparison that matters is the neighbouring one — 1,280 organisations hold a live TGO CFO licence today, against 4,367 that have held one at some point, so roughly seven in ten have lapsed. Organisational carbon accounting in Thailand is mainstream practice. Certified corporate Net Zero is not yet a thing that exists.

The base year is the new gate, and it runs through CFO

This is the change with immediate commercial consequences, and it sits in §7.1. Setting a Net Zero base year is an organisation-level exercise only — product, event and individual certifications are expressly out of scope. In listing what the base year requires, §7.1(1) states that direct and indirect emission and removal data must be complete, accurate, and must have been granted permission to use TGO’s Carbon Footprint for Organization certification mark.

The superseded edition asked only that the same data be complete, accurate and verifiable. The new text replaces verifiability with a licensed CFO mark. In plain terms: the Net Zero base year now runs through TGO CFO certification. You cannot start the clock on a Net Zero pathway from an internal inventory, however good it is.

One honest caveat, because a careful reader will find it: the list containing that requirement is introduced by ควรพิจารณา — “the following should be considered” — while the sub-item itself uses ต้อง, “must”. That is mixed drafting, and a company arguing the point has a textual foothold. We would not advise relying on it.

Ninety per cent internal, ten per cent residual

§5.4 sets the bar for the Net Zero certificate itself: a reduction of at least 90% against the base year. Whatever remains can be settled with the organisation’s own permanent removals, or with removal-type carbon credits — and §9.3.1(4) caps that residual at 10% of base-year emissions, not of current-year emissions. Reduction-type credits do not close the gap.

That last distinction is where Thai supply gets thin. §9.2 admits T-VER and Premium T-VER credits, and within them the GHG Removal Enhancement category — forestry, carbon capture and storage, direct air capture. Thailand’s issued volume in those categories is a small fraction of T-VER issuance to date, and Premium T-VER has issued a negligible volume across the life of the programme. Thailand also still has no carbon exchange and no published spot price, so a company modelling its final 10% today is modelling against a market that does not yet quote.

What this does — and does not — do for your disclosure

Here is the part that gets oversold elsewhere, so we will be blunt about it. TGO Net Zero certification is a voluntary Thai label. Nothing in the 32 pages connects it to the SET, the SEC, or the 56-1 One Report, and the ultimate sanction for non-compliance is removal from a list on TGO’s own website. We searched FTSE Russell’s published ESG indicator set and found no reference to TGO, T-VER or ISO 14068 — and we found no primary text in which IFRS S2, CBAM or CDP recognises TGO Net Zero certification as such. Anyone telling you this certificate feeds a rating is ahead of the evidence.

What it does produce is a verified organisational carbon number, built to a documented boundary and signed off by one of 24 registered verifier bodies. That number is the raw material for everything that is assessed. FTSE Russell scores Thai companies from public disclosure only, with no questionnaire — so a verified inventory sitting inside a Thai certificate does nothing for you until it appears in what you publish. Getting TGO-certified carbon into disclosure an analyst actually reads is a separate piece of work from getting it certified.

The same applies with more force where English is not optional. CBAM requires the emissions report in English as a matter of EU law, and the SET50 cohort heading into IFRS S1 and S2 reporting will need its Scope 1 and 2 figures assured and legible to readers who do not work in Thai. A carbon number that exists only in a Thai certificate is a number your global readership cannot use. That is a control problem rather than a scoring penalty — but it is still your problem.

Where the evidence runs out

Four limits on what we have written above, stated so you can weigh them:

What to do before 28 September

TGO’s registration review calendar — which covers all of its carbon labels — puts the next document deadline at 28 September 2026, with review meetings on 14 and 21 October and results on 11 November. One trap worth flagging: for this round the fee deadline falls before the document deadline, on Friday 25 September. That inversion is not a typo — the calendar labels the day of the week correctly and repeats the same pattern in the September 2027 round, which is consistent with Thailand’s 30 September fiscal year-end. For round 5, you pay before you file.

If you miss it, the next round closes 20 November 2026. That is roughly seven weeks, not a year — there are six rounds annually, and any “last chance” framing would be wrong.

The story here is not that Thailand has tightened a rule everyone must now meet. It is that TGO has built a demanding Net Zero standard which, so far, nobody has completed — and that the one requirement in it that bites today is the CFO mark on your base year. That is a carbon-accounting job with a queue in front of it: 1,280 live CFO holders against 24 verifier bodies. If Net Zero is on your board’s slide deck for 2027, the base year is the thing to fix in 2026. And the disclosure that carries it has to be readable by the people you are trying to convince →

Sources, all read 23 September 2026: TGO, ข้อกำหนดและแนวทางการรับรองการปล่อยก๊าซเรือนกระจกสุทธิเป็นศูนย์ (ฉบับปรับปรุงครั้งที่ 1, กรกฎาคม 2569) — §§5.3, 5.4, 7.1, 7.3, 8.5, 9.2, 9.3 and the revision-control table at p.27; TGO Net Zero organisation register; TGO CFO register; TGO registered-verifier list; TGO carbon-label registration review calendar. The register figures are live database counters carrying no “as at” stamp and should be re-read before reuse.