Thailand — One Report ESG disclosure, CBAM and EUDR

Thailand requires listed companies to disclose ESG information, including greenhouse gas emissions, in the SEC’s Form 56-1 One Report, and is phasing that disclosure towards the ISSB Standards. Thai exporters of steel, aluminium, cement and fertilisers, and of rubber, palm oil and wood products, additionally face two EU regulations that bind them through their EU customers: the EU Carbon Border Adjustment Mechanism (CBAM) and the EU Deforestation Regulation (EUDR).

What is in force

On 1 September 2020 the SEC amended its regulations to consolidate the annual registration statement (Form 56-1) and the annual report (Form 56-2) into a single Form 56-1 One Report.¹ Form 56-1 One Report became effective from the financial period ending 31 December 2021 and is due within three months of the end of the financial period. It is used for registration-statement filings from 1 January 2022, and disclosure of greenhouse gas emissions became compulsory in registration-statement filings from 1 January 2021.¹ The SEC describes the One Report as presenting how a business is operated under ESG principles, including policies, goals and ESG performance, greenhouse gas emissions and respect for human rights.¹

The SEC’s One Report page identifies Capital Market Supervisory Board Notification No. TorJor. 44/2556 as the governing rule, most recently amended by Notification No. TorJor. 48/2568 (No. 30), with the current Form 56-1 One Report annexed to that amendment.² The same page publishes a greenhouse-gas reporting manual for listed companies alongside the form, a completeness checklist, FAQs and ISSB training material.²

For exporters, the CBAM definitive regime is already running. CBAM applies to goods listed in Annex I — cement, electricity, fertilisers, iron and steel, aluminium and hydrogen — originating in a third country and imported into the customs territory of the Union, and such goods may be imported only by an authorised CBAM declarant.³ During the CBAM transitional period from 1 October 2023 until 31 December 2025 the importer’s obligations were limited to reporting. Applications for authorised CBAM declarant status opened on 31 December 2024, and from 1 January 2026 the authorised-declarant requirement applies, along with the annual declaration, certificate and penalty articles. The quarterly certificate-holding requirement in Article 22(2) applies from 1 January 2027.⁴ Under the consolidated Regulation, an importer is exempt where the net mass of imported goods in a calendar year does not cumulatively exceed 50 tonnes. The first CBAM declaration and certificate surrender are due by 30 September 2027 for goods imported in 2026, and thereafter by 30 September of each year.⁴ Regulation (EU) 2025/2083 entered into force on 20 October 2025 and excludes electricity and hydrogen from the de minimis exemption.⁵

What is coming

On 28 November 2025 the SEC announced that, following a public hearing, it had decided to maintain sustainability disclosure principles aligned with the ISSB Standards, requiring listed companies to apply IFRS S1 and IFRS S2.⁶ In the initial phase the SEC will implement a climate-first approach focusing on disclosure of Scope 1 and Scope 2 GHG emissions accompanied by standardised assurance, with a phased-in application and transition relief measures.⁶ The SEC’s published timeline gives effective timelines and first reporting periods of 2027 and 2028 for SET50 companies, 2028 and 2029 for SET100 companies, and 2029 and 2030 for all companies on SET including IPOs. For all companies on mai, and for REITs, infrastructure funds, infrastructure trusts and property funds including IPOs, it gives 2030 and 2031.⁶ SET50 companies are those classified as SET50 constituents in the December 2026 Index Review, and SET100 companies those classified as SET100 constituents in the December 2027 Index Review.⁶ The revised scope of reporting entities and effective timelines were approved by the Capital Market Supervisory Board in November 2025, and the SEC stated it was in the process of amending the relevant regulations.⁶ Until that amendment is published, the timeline is an announced principle rather than an enacted rule.

EUDR is the second incoming rule. It covers relevant products listed in Annex I that contain, have been fed with or have been made using cattle, cocoa, coffee, oil palm, rubber, soya or wood. Such products may not be placed on the Union market or exported unless they are deforestation-free, produced in accordance with the relevant legislation of the country of production, and covered by a due diligence statement.⁷ Regulation (EU) 2025/2650 replaced Article 38 so that the core EUDR obligations apply from 30 December 2026 for all other operators and traders, and from 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024. That timing carries an exception for the products covered by the Annex to Regulation (EU) No 995/2010 (the EU Timber Regulation), which matters for Thai wood exporters, since wood is among the commodities named.⁸

Who it binds

The One Report obligation sits with the securities issuers governed by Capital Market Supervisory Board Notification No. TorJor. 44/2556, which the SEC’s One Report page identifies as the governing rule for the form.² For the ISSB phase-in, the reporting mandate covers listed companies of Thai or foreign incorporation and IPO applicants (excluding non-listed companies, issuers and companies listed on LiVEx), together with listed REITs, infrastructure trusts, property funds and infrastructure funds.⁶

CBAM binds the EU importer — the authorised CBAM declarant — not the Thai producer directly.³ A Thai steel, aluminium, cement or fertiliser producer is drawn in because the declarant needs its installation-level emissions data. EUDR binds the EU operator or trader that places rubber, palm-oil or wood products on the Union market; the Thai grower, processor or exporter is drawn in through the operator’s due diligence, which needs geolocation and legality evidence from the producing plot.⁷

Verification requirements

For the ISSB phase, listed companies are required to engage assurance providers, which may be verifiers registered with the Thailand Greenhouse Gas Management Organization (TGO) or other verifiers that conduct assurance in accordance with internationally accepted assurance standards.⁶

Under CBAM, where embedded emissions are determined on the basis of actual emissions, the declared emissions must be verified by a verifier accredited under Article 18 following the verification principles of Annex VI. A third-country operator may have its installation registered in the CBAM registry, determine embedded emissions under Annex IV, have them verified by an accredited verifier and keep the verification report for four years. A carbon price effectively paid in a third country may reduce the certificates to be surrendered.⁴

Under EUDR, deforestation-free means produced on land not subject to deforestation after 31 December 2020; operators must exercise due diligence — information collection, risk assessment and risk mitigation — before placing products on the market and keep the information for five years.⁷ The Regulation mandates no third-party verifier; the operator’s due diligence statement is the compliance instrument.

What an organisation on ESGOS can do

A Thai organisation can find its listing in the directory and claim it from its profile page, or get listed and attach evidence: a One Report or GHG inventory, an assurance statement, or a CBAM verification report. Producers of Annex I CBAM goods can add a compliance profile that records installation registration and verified embedded emissions. The verifiers directory lists accredited verification bodies drawn from national accreditation registers, including verifiers registered with TGO; verifiers accredited for CBAM under Article 18 are not yet published by the Commission, so the directory does not hold them. Exporters of steel, aluminium, cement, fertiliser, rubber, palm oil or wood can see which EU rule reaches them in the exposure check.

Footnotes

1. SEC prepares listed companies for disclosure of annual registration statement via Form 56-1 One Report (News No. 30/2021), The Securities and Exchange Commission, Thailand. ↩ ↩² ↩³

2. แบบ 56-1 One Report — regulations, form and manuals page, The Securities and Exchange Commission, Thailand. ↩ ↩² ↩³

3. Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, EUR-Lex. ↩ ↩²

4. Regulation (EU) 2023/956 — consolidated text 02023R0956-20251020, as amended by Regulation (EU) 2025/2083, EUR-Lex. ↩ ↩² ↩³

5. Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 as regards simplifying and strengthening the carbon border adjustment mechanism, EUR-Lex. ↩

6. SEC revises sustainability-related disclosure principles to align with ISSB standards (News No. 298/2025), The Securities and Exchange Commission, Thailand. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

7. Regulation (EU) 2023/1115 on commodities and products associated with deforestation and forest degradation, EUR-Lex. ↩ ↩² ↩³

8. Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 as regards certain obligations of operators and traders, EUR-Lex. ↩