In more detail
What is changing?
ABCA No.2 updates and tightens Thailand's alcohol regulatory regime in several key areas. Among the most notable changes are:
- Revised advertising and marketing rules
- Stricter sales and consumption controls
- Extended liability to sellers
What business operators should look out for?
- Revised advertising and marketing rules
The revised law elaborates limits on how alcoholic beverages can be promoted while easing some restrictions to address some practical issues. Manufacturers, importers, and sellers should pay close attention to these restrictions, which may impact current common industry practices.
For example, it is now expressly prohibited to use the logo or an altered version of the logo of a non-alcoholic product in a way that could be interpreted as advertising alcohol. CSR activities that could be seen as encouraging alcohol consumption (as defined in forthcoming subordinate laws) are also banned, along with the promotion or publication of those activities.
These restrictions will require companies to carefully review their advertisements, marketing strategies and community initiatives.
- More stringent sales and consumption restrictions (including age verification) and extended liability
Sellers (including retailers, convenience stores, restaurants, and hotels) are now required to verify both the age and sobriety of customers before making a sale. Subordinate laws will set out the verification methods. Sales to anyone under 20 or to an intoxicated person are strictly prohibited. More importantly, sellers who ignore these rules could be held liable for damages caused by underage or intoxicated consumers. This significantly increases compliance risk for operators at the point of sale.
- New business opportunity for vending machines
In a notable departure from the previous regime, ABCA No.2 permits the sale of alcoholic beverages through automatic vending machines, provided they can verify the consumer's identity in line with criteria to be set out under subordinate laws. This change could create new opportunities in the vending machine and retail sectors.
What's next?
While ABCA No.2 establishes the new framework, much of the practical detail will depend on the subordinate laws expected to be announced in November 2025. These will determine how the new restrictions and opportunities play out in practice. We recommend that businesses monitor these developments closely and prepare to adjust compliance and commercial strategies accordingly. Our team of legal specialists in Thailand's alcohol regulatory regime are also closely following these subordinate laws and are ready to assist relevant business operators with both compliance planning and identifying opportunities.