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Compliance Deadline Looms: Thailand’s New Regulation for Beauty Service Contracts (Thailand)

Author
Supasit Boonsanong, Kobchai Nitungkorn (Co-author)
Publisher
Nagashima Ohno & Tsunematsu
Journal /
Book
NO&T Thailand Legal Update No.39(November, 2025)
Reference
Practice Areas

*Please note that this newsletter is for informational purposes only and does not constitute legal advice. In addition, it is based on information as of its date of publication and does not reflect information after such date. In particular, please also note that preliminary reports in this newsletter may differ from current interpretations and practice depending on the nature of the report.

Introduction

Thailand’s Office of the Consumer Protection Board (OCPB) has introduced a major regulatory overhaul for the beauty service sector. The classification of the Beauty Service Business as a “Contract-Controlled Business” mandates the use of essential terms and strictly prohibits unfair clauses to enhance consumer protection. The deadline for full compliance is 24 January 2026.

The Scope

The Notification on Prescribing the Beauty Service Business as a Contract-Controlled Business B.E. 2568 (2025) (the “Notification”) applies to any Beauty Service Business that provides certain services under a contract for continuous service, a fixed number of sessions, or a defined period.

These services encompass:

  • Massages, spas, and other methods for cleanliness or aesthetics.
  • Facial, skin, and body care.
  • Weight control and body contouring.

Applicable Channels: The regulation is comprehensive, applying to operators across all in-person and online service channels, including via digital platforms. Examples of affected businesses include spas, massage centers and weight management and slimming centers.

Exclusions: The Notification explicitly excludes plastic surgery, liposuction rehabilitation as a therapeutic treatment performed by medical professionals under the Medical Profession Act and the treatment of diseases or illnesses performed by a medical practitioner under the Medical Practice Act.

Details of Mandatory Contract Requirements

The Notification specifies key protections that must be included in every contract with a client:

I. Mandatory Contractual Terms

  1. Essential Terms: Businesses must use the contract containing all required terms and conditions issued by the OCPB.
  2. Mandatory Refund Timelines: The contract must clearly state the mandatory processing timelines for refunds (for unused services) via cash and credit card.
  3. Contract Execution and Readability:

    • The business must produce two copies with identical content and provide one copy to the consumer immediately upon signing.
    • The text must be legible, with a font size no smaller than 2 millimeters (and no more than 11 characters per inch).
    • Electronic contracts must contain the same mandatory terms, written in clear and legible Thai language, which must comply with the Electronic Transactions Act B.E. 2544 (2001).

II. Prohibited Unfair Clauses

The regulation expressly prohibits clauses that are deemed unfair to the consumer, for instance:

  • Limitation of Liability:

    • Any clause that seeks to limit or exempt liability for harm or damage caused to life, body, health, mind, or property as a result of the service.
    • Any clause limiting liability for proprietary loss occurring within the business location.
  • Consumer Rights & Cancellation:

    • Any clause that prohibits the consumer from cancelling the contract or demanding a refund for unused services.
    • Any clause imposing a blanket “no-refund” policy.
  • Unilateral Changes & Control:

    • Any clause that allows the business to unilaterally change the services, fees, or contractual terms.
    • Any clause that binds the consumer to the business operator’s rules or policies without the consumer’s express and voluntary consent.
  • Contract Extension & Termination:

    • Any clause that automatically extends or renews the service period or contract upon expiration without the consumer’s express and voluntary consent.
    • Any clause that permits the business to terminate the contract without notice or cause and allows the business to forfeit prepayments upon termination.

Penalties for Non-Compliance

Failure to comply with the mandated contract terms and standard form requirements applicable to a “Contract-Controlled Business” under the Consumer Protection Act B.E. 2522 (1979) is a serious offense carrying criminal penalties, including both imprisonment and monetary penalties.

If the offender is a juristic person (company), the director, manager, or person responsible for the business’s operation may also be subject to the criminal penalties under certain circumstances.

Therefore, businesses must ensure their controlled contracts strictly comply with the requirements.

Actionable Steps for Your Business

Compliance is mandatory and non-negotiable. Your business should immediately take the following actionable steps:

  • Legal Review and Redrafting: Conduct a comprehensive audit of all existing service contracts, membership forms, and course sales contracts. All documents must be redrafted to align with the OCPB’s standard contract form and ensure all prohibited clauses are removed.
  • Operational Readiness: Update internal accounting and operations systems to ensure strict adherence to the new, mandatory refund deadlines.
  • Employee Training: Implement mandatory training for all sales, marketing, and customer service teams to ensure they understand the new consumer rights and proper cancellation procedures.

Conclusion and Next Steps

The deadline of 24 January 2026 for full compliance marks a significant shift in consumer protection standards for the Thai beauty service industry. Compliance with these new regulations is essential not only to avoid substantial criminal penalties imposed on both your business and management, but also to demonstrate a commitment to best practices and consumer trust. We strongly recommend initiating your compliance audit immediately.

Should you require assistance with the legal review, redrafting of contracts, or compliance training, please do not hesitate to contact Kobchai Nitungkorn at kobchai.n@nagashima.com.

This newsletter is given as general information for reference purposes only and therefore does not constitute our firm’s legal advice. Any opinion stated in this newsletter is a personal view of the author(s) and not our firm’s official view. For any specific matter or legal issue, please do not rely on this newsletter but make sure to consult a legal adviser. We would be delighted to answer your questions, if any.

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