Thailand’s Climate Bill Has Worked Through Its ETS and Carbon Tax Chapters. Who Must Report Is Still Blank

ส่งมอบ 16 October 2026, Thailand’s Department of Climate Change and Environment (DCCE) posted its Week 23 bulletin on the draft Climate Change Act. The Office of the Council of State is now working through Chapter 11, on carbon credits. Since late August, the same review has finished the chapter on an emissions trading system, opened the chapter on a Thai border carbon adjustment, and spent two weeks on a carbon tax, with the Excise and Customs Departments named as the collectors.

The headlines will focus on the carbon tax. For sustainability, finance and IR teams at Thai companies, the more useful news is less dramatic. Every pricing chapter now under review draws on one input: the company-level greenhouse gas report in Chapter 6. And the government still has not said who has to file it.

Where the bill actually is

The facts are short and come from DCCE itself. Cabinet approved the bill in principle on 2 December 2025. DCCE described it then as 14 chapters and 205 sections plus transitional provisions, covering an ETS, a border carbon adjustment, a carbon tax, carbon credits and a climate fund. It went to the Office of the Council of State for legal drafting review. DCCE’s own timeline, published on 11 October 2026, says that in 2026 the bill is under that review “before going to the Cabinet and the legislative process”. So a second Cabinet decision and the whole of Parliament are still ahead.

On 15 October, DCCE described the bill as one it “plans to enforce in 2027”, in a release about roughly 81.6 million baht in World Bank grants signed on 14 October. Around 68 million baht of that goes to the Partnership for Market Implementation, which studies the design of carbon pricing instruments. A 2027 start would need the Council of State, Cabinet and Parliament to finish within about fourteen months. That is possible. It is not yet scheduled.

Six weeks, four chapters: what the Council of State has reviewed

DCCE has posted a bulletin for most review weeks since the series resumed on 28 August. Weeks 19 and 20 were not posted. Read in sequence, the bulletins show the committee moving steadily through the carbon-pricing heart of the bill.

Two details stand out. First, the ETS chapter repeatedly refers to นิติบุคคลควบคุม, “controlled legal entities”, and gives officials power to inspect their emissions. The ETS is designed around a defined list of companies, not the whole economy. Second, the capital-market regulators were in the room for the trading sections, so allowances are being treated as tradable instruments, not just compliance paperwork.

The question nobody can answer yet: who must report

The reporting system already exists. DCCE has built it as software and piloted it with companies, as we covered in August. On 7 October 2026 DCCE ran its first training on the system for legal entities, with 100 participants including companies, verification bodies and TGO. The training covered user registration, reporting, verification and certification of reports under Chapter 6, Part 2. DCCE says the data will feed an ETS “or other carbon pricing mechanisms”.

What the system cannot yet tell anyone is who has to use it. At the project steering committee on 6 October, members asked DCCE to “clearly define which legal entities must report, in Phase 1, Phase 2 or later phases, so that they can prepare”. That request is the clearest public sign that the covered list has not been set. On 19 October DCCE announced the winning bidder for a consultancy to prepare for implementation of the bill and to draft its secondary legislation. That is where thresholds, sectors and deadlines are most likely to appear, after the Act itself passes.

Three reporting regimes, one set of numbers

The same 6 October meeting raised a point every listed company should note. Members asked DCCE to align the reporting formats of the สำนักงานคณะกรรมการกำกับหลักทรัพย์และตลาดหลักทรัพย์ (SEC) and of หน่วยงานแห่งชาติ TGO with reporting under the law, to reduce companies’ costs. Today a large Thai listed company can face three separate greenhouse gas reporting streams:

None of these is designed to replace the others, and the committee’s request is for formats to be aligned, not merged. The practical answer for a company is not to wait for the government to reconcile them. Build one inventory, with one boundary, one set of activity data and the current TGO emission factors, and produce each report from it. A company that already holds a verified TGO CFO has most of the evidence trail a Chapter 6 report will need. For how that same inventory feeds a rater, see from TGO carbon numbers to FTSE disclosure.

Where English comes in, and where it does not

A report filed into a Thai government system under a Thai statute will be in Thai. That is compliance, and it does not need an English edition. English matters for the readers outside that system.

The bill’s Chapter 9 is a ไทย border adjustment, aimed at imports. It does not change what Thai exporters owe Europe. Under the EU’s CBAM, Commission Implementing Regulation (EU) 2025/2547, Article 10(4), “the operator’s emissions report shall be submitted in English.” If your installation exports CBAM goods, the numbers in your Thai filing and in your English CBAM report have to match line for line. See CBAM for Thai exporters.

The same applies to investors. FTSE Russell scores Thai listed companies from their public disclosure, without a questionnaire, and Thai is not among the research languages its ESG Scores FAQ names (v1.5, §1.8). SET itself recommends that listed companies disclose in English, because FTSE Russell assesses primarily from English (SET Q&A, question 16). It does not require it. Once a carbon tax or ETS exists, the cost exposure it creates becomes a climate risk that global analysts will read about in your English One Report. The English edition is the version they actually read, so it is worth making it exactly right. Our bilingual TSRS disclosure work starts from that point.

Where the evidence runs out

Three caveats keep this honest.

The bulletins are DCCE’s own summaries. The Council of State does not publish its working drafts, and DCCE did not post a bulletin for every week. We know which topics were discussed, not the wording agreed. Any section numbers or rates quoted elsewhere for the carbon tax or ETS should be treated with suspicion until the bill text is published.

2027 is a plan. No Cabinet resolution on the final draft, no submission to Parliament and no Royal Gazette item exists as of 23 October 2026. The minister has also stressed protecting SMEs and not adding burdens on the public, which points to a phased start rather than a fast one.

Covered companies are unknown. The Phase 1 list may be narrow. Many readers of this post may not be required to report under the Act for years. The case for preparing now rests on the SEC’s FY2027 timetable for SET50 and on export customers, which are already fixed, not on the Act.

What to do before the thresholds land

The Council of State has now reviewed most of the carbon-pricing chapters. The rest of Chapter 11 and three more chapters remain, then Cabinet and Parliament. The rules for who reports will come later still. That gives companies time, but not much of it. We track every step on the ESG regulatory tracker. For the SET50 disclosure timeline, see SET50’s first climate disclosure, and for the Thai carbon-credit market the bill will regulate, see why Thailand’s carbon price is not 84 baht. Our ISO 17100 technical translation service covers the English edition.

Sources: Department of Climate Change and Environment (dcce.go.th) releases of 2 Dec 2025 (Cabinet in-principle approval, 14 chapters / 205 sections), 25 Jul 2026 (Week 12), 28 Aug (Week 16), 5 Sep (Week 17), 12 Sep (Week 18), 3 Oct (Week 21), 6 Oct (reporting-system steering committee 2/2569), 7 Oct (first training for legal entities), 9 Oct (Week 22), 11 Oct (drafting timeline), 15 Oct (World Bank grants; planned enforcement 2027), 16 Oct (Week 23) and 19 Oct 2026 (secondary-legislation consultancy award); TGO Carbon Footprint for Organization registry counter (thaicarbonlabel.tgo.or.th, read 23 Oct 2026); SEC Thailand News 298/2025 (28 Nov 2025); Commission Implementing Regulation (EU) 2025/2547, Art. 10(4); FTSE Russell ESG Scores and Indices FAQ v1.5, §1.8; SET, FTSE Russell ESG Scores — Questions from Q&A sessions, question 16. Quotations from Thai sources are our translations.