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ARTICLE · 24 DECEMBER 2025

Thailand Drafts Reforms To Cut Administrative Inaction

Tilleke & Gibbins
Tilleke & Gibbins
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Tilleke & Gibbins

Tilleke & Gibbins

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Prior to the dissolution of the House of Representatives, Thailand's cabinet approved a draft amendment to the Administrative Procedure Act, following review by the Council of State.

ThailandCorporate/Commercial Law

Prior to the dissolution of the House of Representatives, Thailand's cabinet approved a draft amendment to the Administrative Procedure Act, following review by the Council of State. If enacted, this reform will fundamentally change how state agencies process business applications and appeals by imposing enforceable timelines and legal consequences for inaction. The draft directly targets a longstanding commercial frustration: applications and appeals that vanish into administrative silence, stalling investment and foreclosing judicial review across sectors ranging from real estate and manufacturing to healthcare and finance.

The "Silence Means Yes" Rule for Applications

At the core of the reform is a new automatic "approval by implication" for applications subject to statutory processing deadlines. If an official fails to notify an applicant of a decision within the legally prescribed period, the application will be deemed approved as a matter of law. This

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