Looking Back: 2025 and Gazing Into: 2026
Looking Back: 2025
2025 brought with it a steady stream of challenges in the form of increased United States (“US“) tariffs and a tougher global trade environment, an earthquake in Bangkok and resulting building collapse, the eruption of border tensions, and the appointment of a new Prime Minster, Anutin Charnvirakul, after the removal of Paetongtarn Shinawatra from this position by the Constitutional Court.
Despite the challenges, Thai exports recorded robust growth in 2025, particularly in electronics and electrical products, which account for almost ¼ of Thailand’s total exports. According to the Ministry of Commerce’ Trade Report, in 2025, the top 5 exports by product category were: automatic data processing machines and parts; motor cars, parts and accessories; precious stones and jewellery; rubber products; and machinery and parts.
Thailand’s No.1 destination for exports remained the US, followed by China, Japan, India and Malaysia. The No.1 source of imports remained China, followed by Japan, Taiwan, the US and the United Arab Emirates (UAE).
From 2018 through November 2025, Thailand’s electrical and electronics sector led all industries in investment promotion, receiving THB1.17 trillion (around US$37 billion) for 1,748 projects, representing 19% of the total Board of Investment (“BOI“) promoted investment. This growth was fueled mainly by investments in printed circuit boards, semiconductor assembly and testing, hard disk drives and their parts, as well as electronic components for automotive, medical, telecommunications, and smart electronics applications.
BOI also approved a total of 36 data centre projects in 2025, with a collective investment surpassing US$23.1 billion (THB728 billion). These data centres are situated in major provinces such as Bangkok, Chachoengsao, Chonburi, Pathum Thani, Rayong, and Samut Prakan.
2024 and early-2025 saw significant focus on the enactment of the Entertainment Complex Bill, which appeared to have a green light for enactment until later in 2025, when it became clear that there was no prospect of enactment in the near future.
The Government also introduced measures aimed at strengthening the enforcement powers of relevant authorities to effectively combat technology-related crimes.
In 2025, the Personal Data Protection Committee (“PDPC“) announced proactive enforcement actions under the Personal Data Protection Act B.E. 2562 (2019).
Gazing Into: 2026
The Bank of Thailand projects gross domestic product (GDP) growth to slow to 1.6% in 2026 from around 2.2% in 2025, reflecting subdued global demand and continuing headwinds from the impact of US trade policy and a strong baht. The International Monetary Fund has issued an identical 1.6% forecast, while the World Bank anticipates approximately 1.7% growth. SCB Economic Intelligence Center (EIC) projects Thailand’s economy to expand by only 1.5% in 2026, down from 2% in 2025, marking the lowest growth in three decades outside crisis periods.
Private investment is projected to see moderate growth in 2026, driven primarily by foreign capital entering emerging industries that benefit from BOI incentives. The primary sectors comprise electrical appliances and electronics, data centres, as well as the automotive industry.
Thailand has announced a national strategy to develop its semiconductor industry, focusing on power semiconductors, sensors, photonics, discrete components, and analogue chips. Aimed at establishing complete value chains, the plan was outlined at the 7 January 2026 meeting of the National Semiconductor and Advanced Electronics Policy Committee meeting.
The commitment to enhancing the nation’s digital infrastructure and positioning Thailand as a premier Digital Innovation Hub in the Association of Southeast Asian Nations (ASEAN) was evident at the first 2026 board meeting of BOI on 6 January 2026, with the official approval of seven significant data centre and data hosting projects.
With the Cabinet’s approval of the main principles of the draft Climate Change Act in December 2025, the next phase involves drafting secondary legislation and coordinating with relevant agencies and industries. Pending details include carbon tax rates, Emissions Trading System (ETS) allocation rules, Carbon Adjustment Mechanism (CBAM) implementation, and Climate Fund mechanisms. High-emission industries should prepare for the increasing financial liabilities tied to environmental costs under the polluter-pays principle.
It is likely that 2026 will see heightened examination of shareholding arrangements suspected of violating the nominee provisions under the Foreign Business Act. With effect from 1 January 2026, newly incorporated companies where a foreigner is an authorised director in a wholly Thai-owned company, or where foreign shareholding is less than 50%, are required to submit a three-month bank statement for all Thai shareholders evidencing the withdrawal or transfer of funds consistent with the investment amount and the date of payment for shares.
In 2026, PDPC is expected to continue the ramp-up of its personal data protection enforcement activities, and organisations should anticipate deeper scrutiny as the PDPC increases proactive monitoring, and moves closer to achieving its stated goal of higher accountability and stronger nationwide compliance standards.
It is expected that the Trade Competition Commission of Thailand will advance both its enforcement of Draft Guidelines on unfair trade practices for multi-sided digital platforms and amendment of the Trade Competition Act, signalling a firmer and more structured enforcement environment for online marketplaces as regulators work toward clearer rules, broader investigative powers, and heightened scrutiny of platform practices.
With the cancellation of the de minimis exemption waiving import duties on goods valued at THB1,500 or less, with effect from 1 January 2026, further efforts will be made to address the impact of cross-border e-commerce in low-cost and tax-free goods on small to medium sized enterprises in Thailand.
It is also possible that 2026 will see efforts to soften the 2024 rule that taxed all foreign-sourced income when remitted into Thailand, regardless of when earned, in an effort to encourage Thai tax residents to bring back foreign funds to stimulate the local economy.
Full Report
Click on the link below for the full report which provides summaries of the key legal developments related to the above areas.
- Regional Round-Up 2025: Thailand
Please note that whilst the information in this Update is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as a substitute for specific professional advice