Your Thai customer has sent you an ESG questionnaire. Here is what the law requires of them — and what they need from you.
Thailand has introduced mandatory sustainability reporting for listed companies through the Securities and Exchange Commission (SEC Thailand) and the Stock Exchange of Thailand (SET). The SET ESG Disclosure Guidelines and the SEC's Corporate Governance Code require ESG disclosure from listed companies. Thailand is a major supplier to EU, US, Japanese, and Australian markets — particularly in electronics, automotive, food processing, and textiles — and Thai suppliers face ESG questionnaires from international buyers subject to CSRD, CSDDD, and California SB 253. Thailand's role as a major manufacturing hub in ASEAN makes ESG compliance increasingly important for maintaining access to international supply chains. If you supply goods or services to a Thai buyer, or if your Thai buyer supplies international markets, ESG compliance evidence is increasingly a regulatory and procurement requirement.
Key regulations in Thailand — ESG & Sustainability Reporting Supplier Guide
SET ESG Disclosure Guidelines
The Stock Exchange of Thailand (SET) requires all listed companies to publish annual sustainability reports aligned with GRI Standards. The SET ESG Disclosure Guidelines provide a comprehensive framework for environmental, social, and governance disclosure, including supply chain sustainability. SET-listed companies are required to disclose their supplier assessment processes and supply chain sustainability data.
SEC Thailand Corporate Governance Code 2017
Thailand's Securities and Exchange Commission (SEC) Corporate Governance Code requires companies to integrate sustainability into their governance frameworks. The SEC CG Code includes requirements for environmental and social risk management, stakeholder engagement, and supply chain oversight. The SEC has progressively strengthened ESG disclosure requirements in line with international standards.
EU CSRD & CSDDD — Reach into Thai Suppliers
Thai companies that supply European buyers — particularly in electronics, automotive, food, and textiles — are subject to ESG questionnaires driven by EU CSRD and the incoming CSDDD. Thailand is a major electronics and automotive supplier to European manufacturers. EU food companies importing Thai seafood, rice, and processed foods face CSRD supply chain disclosure requirements.
Japanese ESG Supply Chain Requirements
Japan is Thailand's largest foreign investor and a major buyer of Thai manufactured goods. Japanese companies subject to TSE Prime Market sustainability disclosure requirements must disclose supply chain ESG data — including data from their Thai suppliers. Thai automotive and electronics suppliers to Japanese manufacturers face increasing ESG questionnaire pressure.
Thailand PDPA & NCSA Cyber Obligations
Thailand's Personal Data Protection Act B.E. 2562 (2019) (PDPA) requires data controllers to notify the Office of the Personal Data Protection Committee (OPDPC) within 72 hours of becoming aware of a personal data breach likely to result in risk to the rights and freedoms of individuals. Affected individuals must also be notified without undue delay. Thailand's National Cyber Security Agency (NCSA) coordinates national cybersecurity under the Cybersecurity Act B.E. 2562 (2019). The NCSA mandates cybersecurity incident reporting for critical information infrastructure operators. Suppliers processing Thai customer data must align incident response to the OPDPC 72-hour notification window and NCSA reporting requirements.
What this means for you as a supplier
You may not be directly regulated by all of these frameworks. But your Thai buyer is — and so are the international buyers in your supply chain. SET-listed companies must disclose supply chain sustainability data. EU buyers must assess Thai suppliers under CSRD and CSDDD. Japanese buyers must assess Thai suppliers under TSE sustainability requirements. A non-response or a weak response increases your buyer's regulatory risk and makes you a liability in their supply chain.
Key dates
2017 onwards
SEC Thailand CG Code — mandatory sustainability governance for listed companies and regulated entities
Active now
SET ESG Disclosure Guidelines — all listed companies must publish annual sustainability reports
Active now
EU CSRD — large EU companies must disclose supply chain sustainability data including Thai suppliers
Active now
Japanese TSE sustainability requirements — Japanese companies must disclose supply chain ESG data including Thai suppliers
2026
California SB 253 mandatory Scope 3 reporting — US buyers must disclose supply chain emissions including Thai suppliers
July 2029
EU CSDDD Phase 1 — large EU companies must conduct active supply chain due diligence; Thai suppliers will receive structured questionnaires
Thailand's sustainability reporting framework and ASEAN leadership
Thailand has one of the most developed sustainability reporting frameworks in ASEAN. The SET ESG Disclosure Guidelines and the SEC CG Code together create a comprehensive mandatory ESG framework for listed companies. Thailand is also a significant recipient of Japanese and European foreign direct investment — both investor groups require ESG compliance from their Thai operations and supply chains. For suppliers to Thai listed companies and international manufacturers, ESG compliance evidence is increasingly a baseline procurement requirement.
Electronics and automotive — Japanese and EU supply chain pressure
Thailand is one of Asia's largest automotive and electronics manufacturing hubs. Japanese automotive manufacturers — Toyota, Honda, Mitsubishi — have major Thai operations and supply chains. European electronics and automotive companies subject to CSRD must disclose supply chain ESG data including their Thai suppliers. Thai automotive and electronics suppliers face ESG questionnaire pressure from both Japanese and European buyers, making ESG compliance a competitive necessity for maintaining supply chain access.
What your Thai buyer's questionnaire will ask
Environmental management
Environmental management systems (ISO 14001 increasingly expected), waste management, water usage, and compliance with Thai environmental law. EU and Japanese buyers require evidence of environmental compliance.
GHG emissions and climate data
Scope 1 and Scope 2 emissions data, and increasingly Scope 3 (supply chain) emissions. SET-listed companies and EU CSRD buyers require supply chain emissions data. Thailand has a net-zero target of 2065.
Labour rights and working conditions
Compliance with Thai Labour Protection Act, minimum wage, working hours, health and safety, and freedom of association. Migrant worker rights are a specific focus for Thai manufacturing suppliers. EU and Australian buyers will reference ILO conventions and CSDDD.
Human rights due diligence
A written policy covering forced labour, child labour, and non-discrimination. Evidence that you assess your own supply chain for human rights risks. Migrant worker management is a specific area of scrutiny for Thai manufacturing suppliers.
Supply chain traceability
Evidence of your own supplier assessment processes. EU and Japanese buyers require traceability through the supply chain. Seafood and food processing suppliers face specific traceability requirements.
Governance and anti-corruption
Anti-bribery and anti-corruption policies aligned with Thai law. Board oversight of ESG matters. Japanese and EU buyers will reference their own jurisdiction's anti-corruption laws and the UN Global Compact.
What happens if your response is inadequate
- →Your SET-listed buyer must disclose supply chain sustainability data — a non-response creates a gap in their mandatory sustainability report
- →Japanese automotive and electronics buyers must disclose supply chain ESG data — weak responses create compliance gaps for your buyer
- →EU buyers subject to CSDDD may be required to source from suppliers who can demonstrate compliance — a non-response puts your contract at risk from July 2029
- →Australian buyers must assess Thai suppliers under the Modern Slavery Act — weak responses create reputational risk for your buyer and procurement risk for you
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
Received an ESG questionnaire from your buyer?
ESG Stress Free guides Thai suppliers through ESG and supply chain compliance requirements from international buyers.