On September 22, 2026, the Trade Competition Commission of Thailand (TCCT) opened a one-month public consultation period on proposed amendments to three key competition regulations, covering (1) the criteria for determining market dominance, (2) the definition of “monopoly” under Thailand’s premerger approval regime, and (3) the definition of a merger that may substantially lessen competition under Thailand’s postmerger notification regime. The public hearing period closes on October 21, 2026. The proposed changes could significantly affect merger filing obligations and the assessment of market dominance under the Trade Competition Act B.E. 2560 (2017) (TCA). The scope of the consultation and the proposed changes are outlined below. Market Dominance Criteria The draft notification on market dominance criteria proposes changes to the tests for both single-firm dominance and collective dominance, which would be measured using concentration ratios, as follows: Single-firm dominance: The proposed changes would lower the market-share threshold from 50% to 33% and the sales-turnover threshold from THB 1 billion to THB 500 million for the preceding year. Collective dominance: The three-firm concentration ratio (CR3) currently being used would be replaced by a two-firm concentration ratio (CR2). Under the new regime, the two largest operators in a relevant market would be considered dominant if their combined market share reached at least 75% in the preceding year. However, any business operator with sales turnover below THB 500 million or a market share below 10% would be excluded from this assessment. In addition to static or numerical thresholds, the proposed notification introduces a dynamic threshold or alternative criteria for assessing dominance in markets that change rapidly, experience short-term fluctuations in demand or supply, or use technology as a platform for conducting business, such as digital markets. Premerger and Postmerger Filing Thresholds Under the TCA, a premerger filing is required if a merger transaction

Vietnam is implementing and developing a broad package of regulatory reforms that could reshape how IP, data, digital platforms, and product authenticity are regulated and enforced. Several of the key measures have been led by the Ministry of Public Security in its legislative and administrative capacity, as part of a broader government effort. The core reform package consists of four key legal instruments: proposed amendments to the Criminal Code, a proposed new Data Security Law, a draft Decree on Product Identification, Authentication and Traceability, and the newly enacted Decree No. 330/2026/ND-CP. These instruments include rules on criminal enforcement, data security, electronic identification, product identification and traceability, administrative violations, and cybersecurity sanctions. Combined, these measures will affect copyright enforcement, industrial property rights, trade secrets, AI training data, product provenance, online takedowns, valuation of counterfeit goods and electronic evidence. It is worth noting that, in addition to strengthening criminal penalties for IP crimes, Vietnam’s emerging regulatory framework increasingly treats infringement, data misuse, product authentication, and platform-enabled violations as interconnected regulatory and enforcement challenges. For rights holders and foreign investors, this could mean stronger tools against counterfeiting and online infringement, but also more compliance obligations around data, traceability, AI, platform controls and government-facing reporting. Expansion of Criminal IP Enforcement Proposed amendments to Article 225 of the Criminal Code would expand criminal copyright exposure beyond reproduction and distribution to cover large-scale commercial public performance and online communication of works, phonograms and video recordings. This is important because piracy is increasingly about streaming, unauthorized communication, and platform access models rather than physical copying. Aggravated copyright infringement could be subject to up to 10 years in prison for individuals and fines of up to VND 6 billion (about USD 228,300) for commercial legal entities. The amended Article 226 would expand criminal industrial property liability beyond

On September 15, 2026, Thailand’s Office of Insurance Commission (OIC) issued two notifications—one for life insurance and one for non-life insurance—amending the 2020 regulatory framework governing policy issuance and offering, agent and broker conduct, premium collection, and advertising. The amendments take effect on January 1, 2027. Electronic Policy Delivery and OIC Reporting Insurers must now deliver policies electronically by default, with printed copies required only where the policyholder opts out of electronic delivery. For life insurance, this requirement extends to coverage summaries and exclusion documents. Insurers must also electronically submit issued policies to the OIC immediately upon issuance. This is a significant new data-reporting obligation that requires system integration with the OIC’s platform. Risk Management, Sales Conduct, and License Misuse The notifications introduce several amendments and additional requirements in the areas of risk management, sales conduct, and license misuse: Internal risk management must now expressly cover advertising, policy offering, and sales agent information, including market conduct risk and reputational risk. Sales conducted through employees, agents, or brokers are subject to enhanced requirements, including verification of the seller’s identity and authority, disclosure of the purpose of contacting the customer, provision of complete and accurate policy information, customer assistance with application forms, and notification of the expected timing for policy delivery or insurer follow-up. For life insurance, customers must also be informed of their right to cancel the policy. For life insurance specifically, employees, agents, and brokers must submit insurance applications to the insurer at the earliest opportunity, and no later than the next business day. Using another person’s name or license, or allowing another person to use one’s own name or license, for the purpose of offering insurance for sale, listing in sales-related documents, or recording in the insurance policy is now expressly prohibited for both life and non-life insurance.

Many multinational companies are familiar with the concept of “time off in lieu” (TOIL), under which employees receive compensatory time off instead of overtime pay for additional hours worked. While TOIL is common in many jurisdictions, employers in Thailand should be cautious, as Thai labor law does not expressly recognize TOIL as a substitute for statutory overtime-related compensation. Under the Labor Protection Act B.E. 2541 (1998) (LPA), employees who work overtime or perform work on holidays are generally entitled to statutory overtime, holiday, or holiday overtime compensation, including: Overtime Pay: 1.5 times the employee’s normal wage rate for work performed beyond normal working hours on a regular working day. Holiday Pay: 1 or 2 times the employee’s normal wage rate for work performed during normal working hours on a holiday, depending on category of employee. Holiday Overtime Pay: 3 times the employee’s normal wage rate for overtime work performed on a holiday. Importantly, the LPA does not contain any provision expressly permitting employers to substitute overtime-related compensation with compensatory leave, as such compensation is treated as a payment obligation rather than additional time off. Why TOIL Can Be Risky in Thailand Thai labor law is protective in nature, and statutory entitlements to overtime, holiday, and holiday overtime pay are generally regarded as minimum employee rights. As a result, these rights cannot be waived, even with the employee’s consent. Therefore, an employer who grants TOIL instead of paying statutory overtime-related compensation may still be exposed to claims for unpaid amounts, notwithstanding that compensatory leave has already been provided. Thai courts have affirmed this principle, holding that employers remain liable for statutory payments for work performed beyond normal working hours even where substitute time off has been granted. Are There Any Exceptions? Certain categories of employees are exempt from overtime-related compensation,