The minute
- Thailand’s Securities and Exchange Commission published rules requiring listed companies to report sustainability and climate information aligned with the ISSB standards (IFRS S1 and IFRS S2).
- The SET50, the 50 largest companies on the Stock Exchange of Thailand, report first, in 2028 on 2027 data. SET100 follows in 2029, other SET-listed companies in 2030, and the schedule runs through 2031 for the remaining listed companies and investment entities, including the secondary mai exchange.
- GHG emissions disclosure must be verified by assurance providers under internationally accepted standards. Transition reliefs include no comparative figures in the first year, flexibility in the reporting timeframe, use of equivalent GHG calculation standards, and an initial exemption from Scope 3 disclosure.
Why it matters: Thailand is leaving a system where companies picked their own framework (GRI or TCFD were accepted) for a single baseline. For anyone who buys from, invests in or operates in Thailand, the data will eventually become comparable. But the Scope 3 exemption and the assurance requirement pull in opposite directions. I think putting verification first is the right call, yet it leaves a hole in the early years, and that hole decides what information anyone can actually use.
What the schedule fixes and what it leaves open
The fixed part is the order. Size decides who goes first, and the first reports arrive in 2028, so the 2027 fiscal year is the one companies must already be measuring. Anyone in the SET50 has little time to build data collection, since the numbers for 2027 have to exist before the rule produces its first report.
The open part is larger than the headline suggests. The material available does not say how long the “initial period” of the Scope 3 exemption lasts. It does not name the assurance standard beyond “internationally accepted”, and it does not say what level of assurance applies. Nor does it give a year-by-year breakdown for the entities in the last tiers beyond the 2031 end date. Until the SEC or the exchange clarifies these points, any model that counts on Thai Scope 3 data by a specific year is guessing.
Order matters here too. Verified Scope 1 and 2 data will come before any Scope 3 data. A foreign buyer should expect Thai suppliers to hand over audited operational emissions well before they can say anything about their own value chain.
Brazil: same direction, and a gap in this article
Brazil’s securities regulator, the CVM, has also moved listed companies toward reporting based on the ISSB standards, so Thai and Brazilian issuers are converging on the same technical baseline. That is the useful part for comparison. A Brazilian company and its Thai counterpart will, in time, answer the same S1 and S2 questions.
What this article cannot give you is the Brazilian schedule, the Brazilian assurance level or how the CVM treats Scope 3. Those figures are not in the source material, and we do not estimate them. Readers who need the comparison should check the current CVM norm directly. The point that can be stated safely is structural: Thailand set a tiered calendar by company size and wrote the reliefs into the rule itself, and any comparison with Brazil should start from those two features.
Who gains and who loses
Assurance providers get a new, regulated line of work, because verification of GHG data becomes mandatory for every company that falls under the rule. Investors in Thai equities get comparability, which GRI and TCFD-based reports could not offer, since they were hard to line up. The SET50 companies carry the heaviest burden. They go first and have the shortest runway. Smaller listed companies and investment entities get time, but they will be reporting after the larger ones have set the market’s expectations.
Companies that depended on voluntary flexibility lose it. Under the 2022 requirement, a Thai company could choose its framework. Under the new rule, that choice ends for those in scope.
What it means for Brazilian companies
For Brazilian exporters and groups with Thai suppliers or subsidiaries, three points follow from the material. First, a Thai subsidiary that is itself listed, or that belongs to a listed Thai group, will face the 2028 to 2031 calendar. A Brazilian parent that consolidates it should ask when its first ISSB-aligned figures will arrive and in which tier it sits.
Second, Scope 3 requests to Thai suppliers will meet an exempted reporting population for some time. Procurement teams that need supplier emissions for their own reports should not assume the Thai side will have a ready answer in 2028. Asking suppliers directly and tolerating estimates remains the practical route until the exemption period ends.
Third, the assurance requirement helps buyers. Verified Scope 1 and 2 figures from Thai counterparties will come with third-party checking, which cuts the work of validating them. Whether a given Thai supplier is covered depends on its listing status and tier, so the first step is to map which suppliers are in scope and in which year. Brazilian companies that already follow the CVM’s ISSB-based requirements will find the Thai format familiar, though the calendar and reliefs differ and need to be confirmed against the Brazilian text.
Primary source: Securities and Exchange Commission, Thailand: News No. 231/2026 (28 Oct 2026)
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