The Thai Institute of Directors (IOD) criteria for CGR 2570 (the 2027 assessment) contain 174 items — just one more than the 2025 round — but include 14 new criteria, merge overlapping items, and for the first time clearly classify every item as Norm, Bonus or Penalty. Company secretaries should start a gap analysis against the new criteria now, because many items require real action during the year before there is anything to disclose.
Based on IOD’s CGR 2570 survey criteria, data as of 20 November 2025.
Key points
- CGR 2570 has 174 items in the same four categories (the 2025 round had 173)
- 14 new criteria: 5 Norm, 3 Bonus and 6 Penalty items
- In total: 143 Norm, 8 Bonus and 23 Penalty items; some penalties lower the result by one level
- Notable new themes: ESG and climate change, greenwashing, employee provident funds, interim MD&A, and role-specific training for the chair and audit committee
What is CGR 2570 and what data does it use?
The Corporate Governance Report of Thai Listed Companies (CGR) is IOD’s governance survey of Thai listed companies, run since 2001 and covering every company listed on the SET and mai. “CGR 2570” refers to the criteria IOD will use in its 2027 (B.E. 2570) assessment.
The criteria draw on the OECD Principles of Corporate Governance, the SEC’s 2017 Corporate Governance Code for listed companies, the Form 56-1 One Report, the ASEAN CG Scorecard and IOD’s Boardroom Guidelines.
CGR is an outside-in assessment, so it relies only on information the company makes public:
- Form 56-1 One Report
- Shareholder-meeting notices and minutes
- Information published through the SET and the SEC
- Other public information, such as the company website
In previous rounds IOD used the 2023 criteria to assess disclosures about 2022 operations. If the same approach applies, what companies do and disclose during 2026 will shape the 2027 assessment. Check IOD’s announcements for the confirmed timetable.
How many categories and items does CGR 2570 have?
IOD states that this revision keeps the same four-category structure but revises the criteria within each category, taking the total from 173 to 174 items.
| Category | 2025 | 2027 | Norm | Bonus | Penalty |
|---|---|---|---|---|---|
| 1. Rights and equitable treatment of shareholders | 42 | 41 | 29 | 2 | 10 |
| 2. Role of stakeholders and sustainable business development | 43 | 43 | 37 | 3 | 3 |
| 3. Disclosure and transparency | 27 | 28 | 22 | 1 | 5 |
| 4. Board responsibilities | 61 | 62 | 55 | 2 | 5 |
| Total | 173 | 174 | 143 | 8 | 23 |
Norm, Bonus and Penalty counts per category are tallied from IOD’s CGR 2570 criteria document (data as of 20 Nov 2025; category codes A–D).
Only one item was added overall, yet there are 14 new criteria, because IOD merged items covering the same topic. For example, A12 on explaining voting procedures and recording resolutions in AGM minutes combines A11 and A13 from the 2025 round — so an old checklist cannot be compared item-for-item.
What are the 14 new criteria in CGR 2570?
IOD marks the following 14 items as new criteria in CGR 2570:
| Code | Topic | Type |
|---|---|---|
| A05 | Disclose practices that engage shareholders beyond the AGM, such as company visits, investor roadshows or Opportunity Day | Norm |
| A23 | Send the latest shareholder-meeting documents electronically (link or QR code) instead of on paper, including the annual report and AGM documents | Norm |
| A(P)08 | No case in the past 10 years of directors or executives being sanctioned for bad-faith acts, gross negligence or publishing false information | Penalty |
| B10 | Share of eligible employees enrolled in the provident fund (PVD) — 80% or more earns the top level | Norm |
| B(B)02 | Encourage customers, key suppliers and partners to adopt anti-corruption controls, and be named a CAC Change Agent | Bonus |
| B(B)03 | Disclose climate-change performance: board role, risk assessment and business impact | Bonus |
| B(P)02 | No regulatory investigation or sanction for greenwashing | Penalty |
| B(P)03 | No finding by an authority in the past 10 years linking the company to fraud or corruption (lowers the result by one level) | Penalty |
| C03 | Prepare and disclose a quarterly interim MD&A covering all six checklist topics, including sustainability developments | Norm |
| C(B)01 | Sustainability data or report assured by an independent external party (beyond Scope 1 and 2) | Bonus |
| C(P)03 | Auditor issues a qualified, adverse or disclaimer opinion | Penalty |
| C(P)04 | Public reprimand by a regulator | Penalty |
| C(P)05 | Regulator issues an alert to shareholders and investors about the company | Penalty |
| D55 | Chair and the entire audit committee complete role-specific director programs (e.g. RCP, AACP) beyond general director training | Norm |
Together they point in three directions: verifiable ESG (climate change, assured sustainability reporting, greenwashing), responsibility to employees and business partners (provident funds, CAC Change Agent) and better communication with investors (interim MD&A, shareholder engagement beyond the AGM).
How do Norm, Bonus and Penalty items differ?
CGR 2570 is the first round to classify criteria within each category explicitly.
- Norm — baseline practices, scored Yes/No (Poor or Excellent) or by level (Poor, Good, Excellent)
- Bonus — practices beyond the standard; meeting them adds points, missing them costs nothing
- Penalty — conduct contrary to good governance; it counts against the result, and some items explicitly lower the overall result by one level
Company secretaries should monitor penalty items with the compliance function, since most relate to events that internal controls can prevent, such as late financial statements or a regulatory reprimand.
Which criteria do company secretaries own directly?
Beyond the new criteria, several items fall squarely to the company secretary to deliver or coordinate:
- D42 Company secretary qualifications — disclose the secretary’s name, skills and experience, role, legal or accounting qualifications or relevant training, and development activities in the past year
- D11 and D12 Nine-year independent-director tenure — a no-exception nine-year limit, counted continuously: nine years, a two-year break and a return counts as year ten
- D06 Board skill matrix — assess and disclose board skills, with at least one non-executive director experienced in the company’s business
- D55 Role-specific training (new) — the chair and the entire audit committee complete programs specific to their roles, from any provider that runs director-level programs
- A23 Electronic meeting documents (new) — send the annual report and AGM documents by link or QR code, while still providing paper on request
- A05 Shareholder engagement beyond the AGM (new) — explicitly invite shareholders to activities such as company visits or Opportunity Day
What should company secretaries prepare, and when?
Start now. Many new criteria cannot be met by adding text to the One Report — they need real action during the year, such as shareholder activities, provident-fund enrolment or sending the chair and audit committee to training. A practical sequence:
- Download the CGR 2570 criteria from IOD and map them to your latest results using the “CGR68” column, which shows each item’s predecessor
- Run an item-by-item gap analysis: done and disclosed, done but not disclosed, or not yet done
- Prioritise items that need action during the year, such as A05, A23, B10, C03 and D55
- Update policies, charters and disclosures in the One Report, website and AGM documents to match each item’s guidance
- Present the results to the board and CEO to set priorities and owners — governance is driven by tone from the top, not by the company secretary alone
- Monitor penalty risks throughout the year with compliance, finance and the auditor
Frequently asked questions about CGR 2570
How many items does CGR 2570 have?
The CGR 2570 criteria contain 174 items in four categories, up from 173 in the 2025 round: 143 Norm, 8 Bonus and 23 Penalty items.
How many new criteria are in CGR 2570?
There are 14 new criteria — 5 Norm items (A05, A23, B10, C03 and D55), 3 Bonus and 6 Penalty items — covering ESG and climate change, greenwashing, provident funds, interim MD&A and role-specific training for directors.
Do companies need to apply for the CGR assessment?
No. IOD assesses all SET- and mai-listed companies using information they disclose publicly, such as the Form 56-1 One Report, shareholder-meeting documents and the company website.
When should company secretaries start preparing for CGR 2570?
Immediately, because several new criteria require action during the year before they can be disclosed — for example shareholder engagement beyond the AGM, electronic AGM documents and role-specific training for the chair and audit committee.
Need a CGR 2570 gap analysis?
The CS Academy team compares your current practices and disclosures with each CGR 2570 item and builds a realistic plan to close the gaps.