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Othello International · Issue 1 · Q3 2026

Thailand ESG
Regulation Radar

Every ESG, climate and disclosure rule that touches a Thai listed company or exporter — SET and the SEC, TFRS S1/S2, TGO, and the EU rules that reach Thailand — on one dated timeline, updated quarterly. Answer four questions to see exactly which apply to you.

Updated 12 July 2026

Which rules apply to you?

Four questions — answered in your browser, nothing sent anywhere.

1 · Listing status
SET50
SET51–100
SET (other)
mai
Not listed
2 · Do you export CBAM-covered goods to the EU? (steel, aluminium, cement, fertiliser, hydrogen, electricity)
Yes
No
3 · Do you sell EUDR commodities into the EU? (palm, rubber, wood, coffee, cocoa, soy, cattle)
Yes
No
4 · Do you market products or green claims to EU consumers?
Yes
No
The Radar

The timeline

Thirteen dated obligations and milestones, flagged In force Dated or Expected. Compiled from SET, Thai SEC, TGO and EU primary sources; informational, not legal advice.

FY2021
SET / SEC
In force

56-1 One Report — ESG disclosure mandatory

Sustainability disclosure (incl. GHG on comply-or-explain) became part of the single 56-1 One Report filing for every Thai listed company.

Dec 2025
Ratings
In force

Final SET ESG Ratings published — 265 companies

The last year of SET’s own AAA–BBB framework (102 AAA / 80 AA / 67 A / 16 BBB). These ratings still define the ThaiESG-fund universe through Dec 2026.

Jan 2026
EU exposure
In force

CBAM definitive regime begins

EU importers now buy certificates against the embedded carbon of covered goods (steel, aluminium, cement, fertiliser, hydrogen, electricity). ~THB 28bn of Thai exports exposed; steel hit hardest. Thai exporters must supply verified emissions data or lose customers to defaults.

2026
Ratings
In force

FTSE Russell ESG Scores replace SET ratings

SET publishes FTSE Russell scores (continuous 0.0–5.0) for every assessed company — non-disclosure becomes a visible low score, not a blank. 3 pillars, 14 themes, ~125 indicators per Thai issuer.

FY2026
TFRS / ISSB
Dated

SET50: IFRS S1/S2-aligned disclosure mandatory

First reports filed 2027. Climate-first sequencing, Scope 3 relief — and limited assurance required on Scope 1 & 2 (the TGO CFO method is accepted for the first five years). The assurance clock is the real deadline.

⚠ SEC final notification: adoption confirmed in the roadmap/consultation; final gazetted text should be verified before relying on details.

Aug–Dec 2026
TGO
Dated

TGO CFO approval rounds: 11 Aug · 14 Oct · 8 Dec

The remaining certification rounds of 2569 — the Q4 rounds are the last chance to hold a current verified footprint before the March 56-1 filing crunch.

Sep 2026
EU exposure
Dated

EU greenwashing regime bites (Empowering Consumers)

Generic environmental claims (“eco-friendly”, “climate neutral” via offsets) become actionable against anyone selling into the EU. Your English claims are in scope even if the Thai original was hedged.

Dec 2026
Funds
Dated

ThaiESG window: 2025 ratings expire as fund criteria

The 2025 SET ESG Ratings stop defining the ThaiESG tax-fund investable universe after December 2026 — eligibility logic shifts to the new scoring regime.

Dec 2025 / Jun 2026
EU exposure
In force

EUDR — deforestation due diligence

EU buyers of palm oil, rubber, wood, coffee, cocoa, soy and cattle products must prove deforestation-free origin (large operators from 30 Dec 2025; smaller from 30 Jun 2026). Thai agro exporters need geolocation-level traceability.

FY2027
TFRS / ISSB
Dated

Wave 2: SET100 joins mandatory disclosure

The second phase pulls the next 50 companies in — with the same climate-first structure and assurance path.

2027
Thai law
Expected

Climate Change Act expected in force

Cabinet-approved Dec 2025. As drafted: mandatory GHG reporting into a national registry for ~3,000–4,000 organisations and a carbon-pricing mechanism (figures around THB 200/tCO2e reported). Would extend carbon accounting far beyond listed companies.

⚠ Timing and final mechanics not yet enacted — expected, not law.

FY2029
TFRS / ISSB
Dated

Wave 3: all remaining SET companies

Mandatory sustainability disclosure reaches the whole main board.

FY2030
TFRS / ISSB
Dated

Wave 4: mai companies

The junior board joins — by which point today’s voluntary disclosure gap (9% of mai rated) becomes a compliance gap.

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Method: compiled by Othello International from SET and Thai SEC publications, TGO announcements and EU regulation texts, current to 12 July 2026. Items marked “Expected” are not yet enacted. This page is general information for Thai issuers and exporters — not legal or investment advice; confirm obligations against the gazetted texts or with counsel. Related: the disclosure benchmark · sector playbooks · CFO Handbook.

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