27/11/2025
Converging Climate Obligations: What Thailand’s Next Regulatory Phase Means for Business
On November 25, the Thai Cabinet instructed the Ministry of Natural Resources and Environment to fast-track the development of the Climate Change Act — a comprehensive climate law that will introduce Thailand’s first statutory system for Measurement-Reporting-Verification (MRV), a national carbon market, and formal climate-risk and adaptation requirements.
This legislative move comes as the European Union has finalized the operational rules for CBAM’s compliance phase, scheduled to begin in 2026. With the October amendment now in force, EU importers face clearly defined obligations concerning embedded emissions — including the need for product-level emissions information, authorized declarant status, and, from 2026 onward, the phased introduction of certificate surrender. Non-EU producers unable to provide MRV-grade emissions data to their European counterparts will be at a structural disadvantage in carbon-priced global value chains.
In parallel, the SEC Thailand is advancing its ISSB roadmap for listed companies, built around a proposed climate-first sequencing: initially emphasizing climate-related disclosures consistent with IFRS S2 and the climate-relevant portions of IFRS S1, supported by transitional reliefs, before broadening to the full ISSB scope after a defined period. Even at this roadmap stage, the direction is clear: listed entities are being guided toward stronger climate governance, more structured climate-related data practices, and assurance-ready information flows within the 56-1 One Report framework.
Although the Climate Change Act, ISSB-aligned reporting, and CBAM emerge from different regulatory arenas, they converge on the same internal capability requirements: coherent climate governance, reliable emissions data at facility and product level, and controlled, audit-ready disclosure processes.
Together with our partner The Keystone Group Global (KSG), we support organizations in strengthening the underlying governance and reporting capabilities required across all three regimes — focusing on governance design, reporting frameworks, readiness assessments, and the conceptual alignment of emissions-related information for both domestic MRV expectations and CBAM’s product-level reporting requirements. KSG’s climate- and carbon-related analytical expertise complements this work where more detailed emissions-related insight is needed.
Organizations seeking structured guidance, scenario-based orientation, or an initial readiness review in this evolving environment are welcome to contact our team.