This article provides general information and does not constitute legal advice. Specific advice should be obtained for your circumstances.
Late payment has long been a sore point for Thai SMEs supplying large retailers and manufacturers. A new notification from the Trade Competition Commission keeps the familiar 45-day ceiling, but moves the burden of compliance squarely onto the buyer.
At a glance
- Issued by the Trade Competition Commission of Thailand (TCCT) on 2 October 2026; effective 2 November 2026.
- Applies to buyers with revenue from operations in Thailand of THB 500 million or more in the previous financial year, counting the whole corporate group.
- Maximum credit terms: 45 days generally, 30 days for agricultural and simply processed agricultural products.
Who is caught
The rules bite when an SME sells goods or services on credit to a large business, including large wholesale and retail chains such as hypermarkets, department stores, supermarkets and convenience stores. The THB 500 million revenue test is applied to the group as a whole: companies under common policy or control are treated as a single economic entity.
A supplier counts as an SME only if it meets both tests for its sector:
- Manufacturing: no more than 200 employees and annual revenue of no more than THB 500 million.
- Services, wholesale or retail: no more than 100 employees and annual revenue of no more than THB 300 million.
What changes for buyers
The 45-day and 30-day ceilings are not new. What is new is who carries the load. Under the earlier guidelines, the SME had to prove its status. Now the large buyer must tell its SME suppliers that they are entitled to payment within the applicable term, and explain how payment works.
The ceiling hasn’t moved. The burden has.
The clock starts when the SME has delivered the agreed goods or services, to the agreed standard, with complete and correct documents. For consignment arrangements, it starts when the goods have been sold in the agreed quantity. A shorter agreed term still applies, and a different term may be agreed where there are reasonable business grounds consistent with the contract.
Conduct that may be treated as unfair
- Paying late without reasonable justification.
- Changing credit terms or other conditions without good reason, or without at least 60 days’ notice.
- Imposing the same unfair credit-term conditions on all SMEs through standard-form contracts, or adding special conditions that create unnecessary burdens.
Standard-form contracts as such remain lawful. It is unfair credit terms within them that are targeted.
The stakes are significant: an unfair trade practice under section 57 of the Trade Competition Act can attract an administrative fine of up to 10% of the business’s revenue in the year of the breach.
Before 2 November
- Buyers: check whether your Thai group revenue reaches THB 500 million, then classify suppliers by SME status.
- Buyers: review supplier templates and payment communications, and prepare the required notice to SME suppliers.
- SME suppliers: keep delivery and invoice documents complete, because the payment clock starts only when they are.
Speak with our legal team
SBC reviews supply, distribution and procurement contracts for compliance with the Trade Competition Act and the TCCT’s guidelines. To discuss how these changes affect your business, get in touch.
Discuss this topicLegal references
- Notification of the Trade Competition Commission on fair trade practices relating to credit terms between large businesses and SMEs – Royal Gazette Vol. 143, Special Part 239 Ngor, 2 October 2026
- Trade Competition Act B.E. 2560 (2017), sections 17, 57 and 82
Legal information in this article is general and is not legal advice. It reflects publicly reported developments as at October 2026; please confirm the position against the official Thai texts and seek advice on your specific circumstances.
Corporate practiceBangkok-based legal counsel providing Thailand-focused advice for local and international clients.
Learn about SBC Law OfficeThe information on this website is general in nature and is not legal advice. It may not reflect the latest legal developments and should not be relied on for any specific situation. Using this website does not create a lawyer–client relationship. For advice on your own circumstances, please send us an enquiry at info@sbcinterlaw.com. Read the full disclaimer.