Thailand's competition regulator is building a fee-oversight regime for ride-hailing, delivery and e-commerce platforms. It is a more restrained approach than the ex-ante rulebooks of the EU's Digital Markets Act, and it deserves a fair reading. The weak point is a 180-day approval step. If that step turns into de facto price control, the restraint will not matter.
What the TCCT actually proposed
On 19 October 2026 the Trade Competition Commission of Thailand (TCCT) endorsed a draft notification on service-fee structures for ride-hailing and on-demand delivery apps, The Nation reported. Under the draft, operators with 10% to 33% market share are treated as having market power. Those above 33% are treated as dominant. The Nation reports that Grab, LINE MAN and Bolt are among the major platforms that would have to give the regulator details of their commission (GP) charges. The same report states that the rules would not set GP rates.
Tilleke & Gibbins' 2 November summary says fees must rest on necessary ("used and useful") costs and appropriate consideration. Platforms with market power would notify users and the TCCT at least 90 days before a change. Dominant platforms would apply for TCCT approval at least 180 days beforehand. The same summary says the TCCT could order a platform to suspend, cease or modify a fee increase within 120 days, citing section 60 of the Trade Competition Act.
The consultation then widened. On 6 November Tilleke & Gibbins reported two further drafts, with comments due 3 December. One is a non-binding conduct code for ride-hailing and delivery. The other is a binding e-commerce fee notification applying to platforms with at least 10% share. It carries the same 90-day and 180-day tiers.
One caveat about the record: the sources disagree on when the first consultation closes. Tilleke and Digital Policy Alert say 19 November. The Nation says 20 November. I could not find an official TCCT notice that settles the point. Anyone planning to file should treat 19 November as the safe date.
The strongest case for intervening
Regulators have a real grievance. The Nation's 26 October report says about 90% of complaints from riders and restaurants concerned fees. It also says the regulator identified eight rounds of fee increases between April and August 2026. For e-commerce, it reports that Shopee's GP-related charges rose ten times from 2022, a cumulative 433%, and that Lazada's rose seven times, a cumulative 367%.
Merchants and drivers on these platforms often have no practical alternative. Fee changes can arrive with little warning, and a restaurant that depends on one delivery app cannot negotiate. A notice-and-explain rule addresses a real information and bargaining gap. It does so without telling anyone what to charge.
Where the design is right
Three features make this approach better than most platform regulation elsewhere.
- No rate-setting. The TCCT says it will not fix GP rates. Fee caps tend to push platforms to cut quality, add side charges or exit thin markets.
- Scaling by market power. Platforms below 10% share fall outside the scope. Those between 10% and 33% face only notification. That protects challengers such as Bolt from obligations built for incumbents, and keeps entry attractive.
- Cost-based justification in place of bans. A "used and useful" test asks platforms to explain their fees. It does not forbid particular business models.
It is also a narrower tool than the DMA. It does not impose interoperability duties or gatekeeper-style conduct bans, and it does not require product redesign.
Where the risk lies
The 180-day prior-approval requirement for dominant platforms is the sharpest part of the proposal. Six months is a long time in a market where fuel costs, rider incentives and merchant mix shift quickly. A platform that cannot adjust fees in response to costs may adjust elsewhere. It could cut driver incentives, reduce coverage in low-margin districts or raise consumer prices through other channels.
The approval step also gives the regulator discretion over what counts as "used and useful" cost. Without published methodology, approval could become a negotiation over outcomes. That would amount to price regulation without the label. The 120-day suspension power adds uncertainty, because a fee already announced could be unwound after the fact.
Some safeguards should be written into the final text:
- Publish the cost-allocation method the TCCT will use to assess "necessary" costs.
- Set a firm decision deadline, with deemed approval if the regulator misses it.
- Define objective triggers for the 120-day order, and require written reasons.
- Keep the conduct code non-binding, as drafted, so that guidance does not harden into obligation without a hearing.
- Review market-share thresholds per business line, since a platform may be dominant in food delivery and marginal in ride-hailing.
What to watch
The Nation reports the ride-hailing draft returning to the commission on 23 November, with signature expected by 4 December and a target of 18 December for entry into force after gazetting. That timeline leaves little room to absorb consultation comments. If the TCCT compresses it, the 3 December deadline for the two newer drafts will arrive after the first notification is nearly final. That sequencing would undercut the purpose of consulting.
Thailand has a chance to show that platform fee transparency can be achieved without price controls. The test is whether the approval and suspension powers are used sparingly and with published reasoning. If they are, the drafts will look like proportionate oversight. If they are not, the 'no rate-setting' promise will have been only a label.