Thai law for Mobility, delivery and the sharing economy

The rules mobility and sharing platforms most often have to examine are: Digital platform notification (ETDA); Personal Data Protection Act; Payment Systems Act (Bank of Thailand); Foreign Business Act. Which apply depends on the actual model.

If the service connects businesses, consumers or users for electronic transactions and passes THB 50 million a year platform revenue in Thailand (juristic person) or 5,000 monthly Thai users; platforms below the thresholds give a shorter notification. Platforms outside Thailand serving Thai users are covered. (Royal Decree on Digital Platform Services B.E. 2565, ss. 3, 8, 9, 10).

If the business offers goods or services to people in Thailand, paid or free, or monitors their behaviour there, even from outside Thailand. An offshore controller generally needs a representative in Thailand. (PDPA B.E. 2562, ss. 5, 37(5), 38).

If the business issues e-money or e-wallets, or accepts payments electronically on behalf of merchants, it may need a licence or registration; only a limited or public limited company may hold one, subject to exemptions such as accepting payments for its own business. (Payment Systems Act B.E. 2560, ss. 16, 17; Ministry of Finance notification of 17 April 2018, cl. 2.2, 2.3).