In more detail

Background

Over the past decade, there has been a clear legislative trend toward the adoption of mandatory HREDD frameworks. Certain jurisdictions, such as the European Union (EU), have enacted laws requiring companies to conduct HREDD across their entire value chain. This shift is in line with international standards, such as the United Nations Guiding Principles on Business and Human Rights, and the Guidelines for Multinational Enterprises on Responsible Business Conduct issued by the Organisation for Economic Co-operation and Development.

Thailand has demonstrated its commitment to these international standards by adopting the National Action Plan on Business and Human Rights (NAP) in 2019. Although the NAP is not a legally binding instrument, it emphasizes the need for regulatory reform to address business-related human rights risks. In July 2025, the MOJ prepared the HREDD Bill, which, if enacted, will introduce a comprehensive legal framework on mandatory HREDD in Thailand.

The HREDD Bill

Applicable entities

The first draft of the HREDD Bill imposes HREDD obligations on large enterprises – defined as business entities with an annual total revenue exceeding THB 500 million (where the entity engages in the manufacturing sector) or exceeding THB 300 million (where the entity engages in the wholesale, retail or service sector). The HREDD Bill also applies to Thai state-owned enterprises and non-Thai entities carrying out activities in Thailand that fall into the abovementioned criteria.

Major obligations under the HREDD Bill

Under the HREDD Bill, the applicable enterprise is required to conduct HREDD across its entire value chain by identifying, assessing and evaluating potential and actual human rights violations and environmental harm it has caused or contributed to; implement effective measures to prevent or mitigate such violations or harms; and provide the appropriate remediation and communicating such implementations. Some other key specific obligations under the HREDD Bill include:

• Making a public announcement about the HREDD policy and integrating it into the enterprise’s management policy or risk management policy.
• Monitoring the effectiveness of the measures implemented to prevent or mitigate human rights violations and environmental harm.
• Reporting the HREDD implementation to the relevant authorities on an annual basis.
• Establishing grievance mechanisms through which stakeholders may submit a complaint concerning potential and actual human rights violations and environmental harms caused by the enterprise’s own business operations, the operation of any of its subsidiaries, or its business partners in the value chain.

Penalties for violations of the above obligations include administrative fines ranging from THB 500,000 up to THB 5 million. Note that the penalties under the HREDD Bill would not exempt non-compliant enterprises from their other civil and criminal liabilities under other laws.

Relevant authorities

The implementation and enforcement of the HREDD Bill are to be coordinated among several key government agencies, including the Ministry of Justice, the Ministry of Labour, the Ministry of Commerce, and the Ministry of Natural Resources and Environment. A cross-ministerial committee will be established to implement and enforce the HREDD Bill.

Implications for businesses

Thailand’s move toward mandatory HREDD mirrors a regional and global transition from voluntary to mandatory corporate responsibility standards. Companies will need to prepare for this new compliance regime, which would entail supply chain mapping and conducting effective stakeholder engagement.

The HREDD Bill, once enacted, will also influence small and medium enterprises throughout the value chain, as large enterprises will need to engage them to push forward for higher human rights and environmental standards across the board. International investors and trading partners may view Thailand’s progress favorably, as compliance with global due diligence standards becomes a key requirement in responsible investment and procurement decisions.

While it may take more time until the HREDD Bill becomes effective, businesses are advised to begin their preparations for HREDD now, to maintain access to markets with high sustainability regulatory standards, such as the EU. Companies may begin with reviewing existing policies, identifying potential and actual human rights violations and environmental harms in their own operations and value chain, and fostering a culture of transparency.

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Chanata Kengradomying Chaivaivid, Sustainability Knowledge Management Lead, has contributed to this legal update.