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.
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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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Wave 2: SET100 joins mandatory disclosure
The second phase pulls the next 50 companies in — with the same climate-first structure and assurance path.
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.
Wave 3: all remaining SET companies
Mandatory sustainability disclosure reaches the whole main board.
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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