Advancing Public Integrity in Thailand

5. Ensuring a fair, effective and coherent disciplinary system for public officials in Thailand

Abstract

This chapter reviews the disciplinary system for public officials in Thailand, including the types and classification of disciplinary breaches as well as a more coherent approach to disciplinary and criminal investigations. The chapter delves into the existing challenges and reforms since the last review and considers the role of each stakeholder through the system, as well as the available sanctioning system. In particular, this chapter reiterates that OCSC is the natural system owner for monitoring, standards, training, and data, while NACC and PACC retain investigative roles but require clearer co-ordination rules. Furthermore, whilst long-term reforms require Civil Service Act amendments and cross-regime legal clarity, Thailand could move forward with short- and medium-term administrative reforms, allowing progress without waiting for legislative amendments.

Implementation gaps, persistent trends and structural constraints

Thailand’s disciplinary framework for public officials is comprehensive and largely aligned with international standards. The legal architecture clearly defines misconduct, sanctions, procedural safeguards and avenues for appeal, and it has remained broadly stable since the 2021 Integrity Review. However, this stability masks a more persistent challenge, namely, the gap between formal compliance and effective implementation, as well as speediness in enacting the necessary legal reforms. Despite repeated recommendations and incremental adjustments, the disciplinary system continues to face challenges in terms of consistency, timeliness, professionalisation and transparency. This chapter examines Thailand’s efforts to implement recommendations from the 2021 Integrity Review, while noting that out of 12 Recommendations, only 1 has been fully implemented. Overall, compared to previous chapters, this chapter reflects the least progress. As a result, it focuses primarily on reiterating that the previous 2021 recommendations remain largely relevant.

Thailand has taken some steps to address challenges in its disciplinary system, often through incremental initiatives rather than formal legal reform, that seek to strengthen the practical functioning of the system. For example, expanded training and workshops on disciplinary investigations and ethics, particularly in major administrative centres such as Bangkok, aimed at improving investigative skills, fairness, transparency, and timeliness. In 2025, the Cabinet approved targeted anti-corruption and recruitment measures to prevent the re-employment of former civil servants dismissed for serious disciplinary or corruption-related offences, reinforcing the lasting effect of sanctions. In parallel, broader public service and governance bills under parliamentary review introduce transparency and service standards that may trigger disciplinary consequences for non-compliance. These initiatives, alongside wider civil service modernisation and regulatory reform efforts, signal a gradual shift toward embedding integrity and accountability within the administrative culture, even if at times scattered.

However, more structural challenges remain. A recurring trend emerging from this review is that reforms have focused on legal and procedural refinement rather than on improving systemic capacity, incentives and institutional design. The system remains heavily legalistic and fragmented across sectors, with multiple regimes operating in parallel and limited central steering, which, while not uncommon in other countries, also generates confusion among officials, uneven enforcement across agencies, and significant reliance on individual supervising officials, whose integrity, autonomy, and protection remain insufficiently safeguarded in practice.

As noted in the 2021 Integrity Review, Thailand lacks institutionalised ownership of the disciplinary function. Disciplinary investigations are still largely treated as an ancillary task rather than a professional specialisation, relying on rotating committees and ad hoc expertise. This structural feature undermines investigative quality, creates reluctance among officials to participate, and contributes to delays. Training initiatives conducted by NACC and PACC represent progress, but they have not yet translated into a sustainable, professional disciplinary workforce or a shared service model, as originally recommended.

Implementation gaps are also evident in areas repeatedly identified since 2021: lack of binding timelines for investigative stages, limited use of digital tools, weak data collection and publication, and incomplete coordination between disciplinary and criminal regimes. In several instances, recommendations have been reported as “ongoing” or “implemented” based on partial or informal practices, while their core intent –system-wide consistency, predictability, and accountability– remains unfulfilled.

Finally, progress has been constrained by institutional overlaps and cautious reform positioning, particularly concerning the respective roles of NACC, PACC, and line agencies. The absence of clear, formalised co-ordination mechanisms, which has been outlined repeatedly in this report, continues to generate duplication, uncertainty, and inefficiencies. Against this backdrop, this chapter assesses not only the formal evolution of Thailand’s disciplinary framework, which is quite similar to the situation presented in the Integrity Review, but also highlights where progress has stalled, where implementation remains uneven, and why several recommendations from the Integrity Review remain relevant today.

Overview of disciplinary proceedings for public officials in Thailand

As stated in the 2021 Integrity Review, public officials in Thailand are subject to different disciplinary regimes depending on their category. Specific procedures apply to police, military, prosecutors and judges, as well as for elected officials. The disciplinary regime for the majority of public officials not falling under these categories is determined in the Civil Service Act B.E. 2551 (2008), which covers officials hired and appointed to government service under its provisions. As far as local government officials are concerned, there is a specific law in place, however the disciplinary process is similar to the one described in the Civil Service Act (herein “CSA”).

The current procedure still follows the same structure as that reflected in the Integrity Review. The disciplinary process takes place within the government entities and follows the provisions of the Civil Service Act, B.E. 2551 (2008) (Box 5.1).

Box ‎5.1. Overview of Disciplinary System in Thailand 2025

The Civil Service Act B.E. 2551 (2008) is the core law for most civil servants. However, the system is fragmented and disciplinary regimes exist for the following categories of officials:

• police

• military

• judges

• prosecutors

• local government officials

Types of misconduct

• minor offenses: negligence, lateness, improper behaviour

• serious offenses: corruption, abuse of power, criminal acts, serious ethical violations

Penalties

• warning

• salary reduction

• suspension

• dismissal

• dismissal without pension rights (for serious misconduct)

Process

• complaint or allegation

• preliminary inquiry

• formal investigation committee

• decision by appointing authority

• right to appeal (e.g. civil service commission or administrative court)

Appeals and judicial review

• administrative court

• sector-specific appeal boards

• criminal offenses are handled separately in criminal courts

Source: Government of Thailand (2008[1]), Civil Service Act, B.E. 2551 (2008).

As explained, disciplinary offences are usually identified through complaints, discovery by the supervising official or investigations carried out by other institutions, such as the NACC and the PACC. Once a complaint is received or a misconduct is otherwise identified, the supervising official launches a preliminary investigation to determine whether the case has merit or not. The supervising official may undertake the preliminary investigation himself/herself or assign a civil servant or relevant state official to undertake the preliminary investigation and file a report for taking into consideration. If there are reasonable grounds to move forward with the investigation of the case, the supervising official classifies the alleged misconduct as a serious or non-serious disciplinary offence, otherwise the case is dismissed. Once the investigation is completed, the commission summarises its findings and gathered evidence and shares it in a report with the supervising official. Then, the supervising official decides whether to proceed with the imposition of a sanction or not. It should be noted that disciplinary sanctions can only be imposed by the respective government agency. Appeals are envisaged with the Merit System Protection Commission (MSPC) (OECD, 2021[2]).

As of 2025, Thailand has a very strong disciplinary system, including determining the types of offences and aggravating actors, different types of penalties and a process that includes the right of defence, appeals and judicial review. However, challenges remain. Interviews conducted for this review showcased that the system remains fragmented and that different rules for different sectors can be confusing for public officials. Moreover, the system is highly legalistic with strong reliance on formal statutes and procedures, while preventive mechanisms remain secondary.

Ensuring fairness, objectivity and timeliness

Thailand has taken preliminary steps to address professionalisation and safeguards of supervising officials, but lacks institutionalised ownership of the disciplinary function and a professional specialisation. It should further strengthen legislation to provide job security, protection from reprisals and autonomy in the selection of cases for the disciplinary function

Original recommendation

Additional safeguards are needed to strengthen the integrity of supervising officials and ensure the fair imposition of sanctions.

The 2021 Integrity Review found that challenges exist in practice in ensuring the integrity of the supervising official and the objectivity of decisions taken (OECD, 2017[3]). Furthermore, it recommended that procedural safeguards should be in place to guarantee that disciplinary actions are free from internal or external influence, as well as any form of conflict of interest (OECD, 2021[2]).

As a minimum, these procedural safeguards should ensure that personnel responsible for disciplinary proceeds:

• Are selected based on objective, merit-based criteria (particularly senior-level positions).

• Enjoy an appropriate level of job security and competitive salaries vis-á-vis their job requirement.

• Are protected from threats and duress so as to not fear reprisal.

• Have autonomy in the selection of cases to take forward.

• Receive timely training on conflict-of interest situations and have clear procedures for managing them (OECD, 2017[4]).

However, as stated in the review, further safeguards are required, especially considering the level of inconsistent enforcement across agencies. Thailand has taken steps to strengthen the integrity of disciplinary officers, albeit not those contemplated in the 2021 Integrity Review. For example, in 2025, the Thai Cabinet approved measures aimed at strengthening disciplinary integrity by preventing re‑employment of former civil servants who were previously removed for serious disciplinary or corruption violations. This proposal would amend relevant laws and regulations to block rehiring or appointment of such individuals in any government agency and impose penalties on officials who improperly rehire them. This targeted reform was designed to ensure disciplinary sanctions have lasting effect and reduce opportunities for repeat misconduct. Furthermore, there have been ongoing efforts to enhance training in disciplinary investigation and ethics for officials, including by conducting special workshops and training (e.g. in Bangkok for disciplinary investigations aiming to improve investigation skills, transparency, fairness, and speed). These efforts reflect practical reform to improve on-the-ground application of disciplinary rules. Finally, many reforms in the 2021-2025 period weren’t strictly disciplinary reforms, but impacted the culture and enforcement of disciplinary systems, including:

• Regulatory reform initiatives (e.g. extending regulatory impact assessments to regulations) that promote transparency, accountability, and consistency in public administration. This help shape the environment in which disciplinary systems operate.

• Civil service capacity development and modernisation efforts with an emphasis on integrity, ethics and transparency across public agencies (not always formalised in law but discussed in policy circles).

However, other strategic actions suggested by the review, such as labour protections and autonomy in the selection of cases have not yet been implemented. Thailand is therefore encouraged to initiate an initial assessment of its disciplinary system, consulting different level of government and those involved in the investigations of disciplinary cases. This could provide the basis for an encompassing legal reform that introduces the necessary safeguards to the system as well as appropriate resources for its implementation. Thailand could consider former recommendations, such as professional specialisation, relying on rotating committees and ad hoc expertise as part of the reform.

In order to continue the trend of professionalising disciplinary investigations, Thailand could consider expanding on the trainings offered at institutional level and eventually move towards establishing registries of trained disciplinary investigators

Original recommendation

Establishing registries of trained disciplinary investigators or piloting “shared” disciplinary services would help improve the quality of disciplinary investigations.

As the 2021 Integrity review states, in Thailand, there is no dedicated staff in government organisations responsible for dealing with disciplinary matters. The members of the commission of inquiry are appointed in rotation and depending on the technical expertise required for each case. Indeed, interviews with representatives of the OCSC have highlighted that public officials are reluctant to participate in commissions of inquiries for various reasons. For example, the role is perceived as high-risk and low reward. Commission members may fear reprisals or negative career consequences, particularly when cases involve senior officials or politically sensitive matters and often lack clear legal protections against personal or professional liability. The work is typically added to existing duties without adequate incentives, recognition, or administrative and legal support, while many officials also feel insufficiently trained in disciplinary law and investigative techniques, increasing the risk of procedural errors and appeals. Interviews conducted for this report, reiterated this feeling, as government agencies lack personnel with appropriate expertise. As stated previously, this is a critical element to ensure the effectiveness of disciplinary proceedings (OECD, 2021[2]).

As stated previously, civil service capacity development and modernisation efforts with an emphasis on integrity, ethics and transparency across public agencies have been conducted. For example, government and civil service bodies have expanded training and workshops on disciplinary investigations and ethics, particularly in major administrative centres such as Bangkok, aimed at improving investigative skills, amongst others. While NACC and PACC have expanded training activities and may intervene in serious cases, these efforts have not translated into a system-wide professional disciplinary service or shared investigative capacity across government. Thailand has also engaged in few efforts by NACC and PACC, who reported a 2024 training conducted in public sectors institutions related to the disciplinary procedure.

However, Thailand does not currently have a centralised, formal registry of trained disciplinary investigators with mandated legal and investigative qualifications that applies across government agencies to professionalise disciplinary processes, as called by the recommendation. Even if Thailand does have some other practices that could potentially complement the limited professionalisation at institutional level, like NACC and PACC being able to investigate some serious disciplinary matters, the recommendation mandated the creation of a centralised disciplinary service covering all public officials under one entity. Thailand could even consider some intermediate steps to address this issue, like expanding on the trainings offered at institutional level, creating e-modules on the current disciplinary procedures that can trickle down into all levels of government or establishing an informal network/platform of officials participating in the ad hoc commissions of inquiry to share experiences and conduct training for other colleagues.

While some efforts have been conducted at the sub-national level, Thailand is encouraged to move towards reforming existing legislation to establishing reasonable timeframes for the conclusion of each step of the disciplinary investigation, including deadlines for initiating investigations, concluding inquiries, and issuing decisions

Original recommendation

Establishing reasonable timeframes for the conclusion of each step of the investigation is needed to ensure timeliness and efficiency.

The period for the conclusion of the disciplinary process under the PACC is two years, starting from the reception of the allegation and including the imposition of sanctions. Without specific timeframes for each step of the investigation, the risk of increased time pressure at the end of the investigative period emerges, jeopardising the quality of the investigation as a whole. In practice, the only clearly defined overall timeframe applies to cases handled under the Public Sector Anti-Corruption Commission (PACC), where the full disciplinary process, from receipt of the allegation to the imposition of sanctions, may take up to two years.

As stated in both the questionnaire and interviews for this report, outside this framework, timelines vary significantly across agencies and cases, depending on institutional capacity, complexity, and the willingness of supervising officials to advance proceedings.

This situation is not unique in Thailand. For this very situation, some OECD and non-OECD countries, have been enacted legal reforms to establish specific timeframes for different stages of the disciplinary process (Box 5.2).

Box ‎5.2. Deadlines for initiating investigations, concluding inquiries, and issuing decisions in Brazil and Portugal

Brazil (Federal Public Service)

Provides detailed timeframes for types of disciplinary procedures under its administrative disciplinary system.

• preliminary investigative disciplinary process: 180 days total

• investigative inquiry (SINVE): 60 days

• asset investigation (enrichment check): 30 days, extendable

• accusatory correctional investigation: 30 days with possible extension equal to original time

• ordinary administrative disciplinary procedure (PAD): 60 days

• summary disciplinary procedures: typically, 30 days, extendable up to 15 days in some cases

These limits apply across federal public servants and aim to ensure disciplinary processes conclude within set maximum durations.

Portugal (General Public Administration)

Portugal’s public service disciplinary rules set limits on both starting proceedings and overall duration:

• right to initiate disciplinary proceedings: 1 year from the date of the offence or 60 days from when the employer became aware of it

• maximum duration of proceedings: if no decision is notified within 18 months of initiating the proceeding, the procedure ends (i.e. it lapses)

• penalty application limits (limits apply from the date the disciplinary record begins; if penalties are not implemented within these limits, they lapse):

  • reprimand – 1 month

  • fine – 3 months

  • suspension – 6 months

  • dismissal – 1 year

Sources: OECD (2025[5]), OECD Integrity Review of Brazil 2025: Consolidating Progress on Public Integrity, https://doi.org/10.1787/cfcce75d-en; DGAEP (2026[6]), “Homepage”, https://www.dgaep.gov.pt/.

In Thailand, some efforts at the sub-national level have actually superseded a much-needed larger legal reform to the system. In March 2025, the Bangkok Metropolitan Administration (BMA) amended disciplinary laws to require disciplinary actions against former officials to be concluded within three years of leaving service, reflecting the amended Civil Service Act’s Section 100. It is notable that local administrations are now reinforcing and operationalising national disciplinary timeframes. However, efforts at the national level, to provide and adjust specific timeframes for the entire procedure are still needed. In the absence of a larger legal reform, as mandated by the previous recommendation, and in order to ensure the timely advancement of the investigation, OCSC could consider alternative steps. For example, enacting internal guidance, to set indicative or fixed maximum timeframes for each step of the investigation process. This is particularly useful when there is no statute of limitations for disciplinary misconduct and public official can be sanctioned even after leaving the government (OECD, 2021[2]). As explained, many jurisdictions set explicit maximum timeframes for disciplinary investigation stages, especially in formal administrative disciplinary systems.

Common elements that Thailand may consider could include:

• how long an investigation itself may continue

• how long the overall disciplinary process can last before a decision must be issued

• limits on starting proceedings from the date misconduct is discovered or occurs

In any case, under the current framework, the situation remains the same as in 2021, where detailed statutory deadlines for each stage of the disciplinary process are non-existing and very much dependant on individual steps taken by certain agencies. Therefore, the recommendation remains not implemented and relevant to the current context.

Promoting co-operation and exchange of information among institutions and entities

The 2021 Integrity review highlighted the need to streamline the mandate for carrying out disciplinary investigations under the PACC to improve the co-ordination of disciplinary enforcement. The proposed model affirms that the PACC should handle all disciplinary proceedings across the executive branch, transferring information to NACC, only where criminal behaviour is identified. This approach reflects established principles of disciplinary governance: accountability should begin within the institution where the alleged misconduct occurred, ensuring that officials and internal systems are properly professionalised, strengthened, and held responsible for their own standards. PACC would then serve as a second-instance body, providing independent oversight, consistency, and due process, while avoiding the over-criminalisation of administrative or professional failures that are more appropriately resolved through disciplinary mechanisms. Therefore, the recommendation focused on how best to avoid potential overlaps and duplication of efforts between NACC and PACC. In particular, assigning the mandate to PACC as the entity in charge of a second instance and providing guidance to institutions on disciplinary matters. In that way, NACC would keep a core mandate for the criminal investigations related to corruption, while all disciplinary investigations would be streamlined through the PACC (OECD, 2021[2]).

Thailand reported this recommendation as on-going. However further research established that NACC still had a role in the investigation of disciplinary offences. In fact, if the NACC finds evidence of corruption or serious misconduct, it can determine that a public official has committed a serious disciplinary offense. In such cases its findings can obligate the official’s commanding authority (e.g. department head or relevant supervisory body) to impose disciplinary sanctions such as dismissal or removal from office. Moreover, answers to the questionnaire indicated that Thailand officials were of the view that such recommendation is not relevant, as NACC should still have a role in the investigation offences that constitute criminal conduct for high level officials. This recommendation is deemed not implemented as originally formulated and updated to existing needs and frameworks. Furthermore, considering the need for legal reform on the area of disciplinary procedures, this chapter provided the following recommendations.

Original recommendation

Enhancing the co-operation between actors involved in the disciplinary enforcement regimes, for example by promoting regular meetings to exchange good practices.

The 2021 Integrity Review stated that co-operation between stakeholders involved in the disciplinary system helps ensure uniform application of integrity standards, address common challenges, as well as promote the exchange of good practices. This can be achieved by organising regular meetings among NACC, PACC and investigators of government agencies to enable dialogue and the exchange of good practices.

In Thailand, the Bureau of Disciplinary Standards offers courses and annual disciplinary procedure training. The Bureau plays a key role in promoting fair, consistent and legally compliant disciplinary processes across all Thai civil service agencies. Its combination of case analysis, standards development, advisory support, and training makes it central to maintaining discipline, ethical conduct, and accountability within Thailand’s public sector. some particular activities conducted by the Bureau have contributed to co‑ordination and exchange of good practices, as stated in the recommendation. For example, the OCSC website lists annual training, conducted in co-operation with other agencies, on disciplinary procedures (albeit few information can be found on participants or sectors targeted). Overall, the trainings aim to enhance co-operation and build understanding of disciplinary rules, investigative processes, and civil service standards among officials. Topics include investigation rules, report writing, accusation procedures, determination of sanctions, and administrative law related to discipline. NACC and PACC also reported dedicated meetings, at least once a year, aimed at co-ordinating institutional responsibilities and training into the disciplinary system. Other collaborative activities included a memorandum of understanding signed in 2025 between NACC and PACC, as well as participation of NACC representatives in PACC-hosted events or panels. As this recommendation relates to enhancing co-operation between stakeholders and exchange of good practices, and considering the multiple activities mentioned above, it can be considered implemented.

Considering steps taken to improve co-ordination and exchange information, Thailand could take steps towards the development of an electronic case management system

Original recommendation

To improve co-ordination and exchange of information, Thailand could consider the development of an electronic case management tool.

In order to achieve greater levels of maturity with regards to co-ordination mechanisms, Thailand could consider the use of electronic tools, which ensure the effective management of each case. Such tools enable the control and following up on information about administrative procedures against public officials. At the same time, they provide a comprehensive mechanism to manage all the steps of cases allowing all relevant actors to follow, access or submit information for the swift advancement of disciplinary cases (OECD, 2021[2]). Several OECD countries have moved in this direction (Table 5.1).

Thailand reported that there is no electronic case management tool for disciplinary investigations. There is, however, a system for receiving complaints of corruption and misconduct by state officials in order to allow all 40 Anti-Corruption Operation Centers to report their performance in cases where they receive complaints of corruption or misconduct by state officials under their supervision (reporting before entering the disciplinary process). Thailand could consider using this information and work towards an electronic case management system that allows tracking of information across agencies (Box 5.3).

Table ‎5.1. Electronic case management tool for disciplinary procedures

Country/organisation	Key practices
Singapore Public Service	eDisciplinary system with workflow automation, audit trails, and central case repository
UK Civil Service	HR case management systems integrated with digital evidence storage and analytics
New Zealand Public Service	Digital case management with supervisory dashboards and mandatory case status updates at key procedural milestones

Box ‎5.3. Core functions of an electronic case management tool

1. Case intake and registration

• logging complaints or allegations

• assigning case numbers

• capturing involved parties and allegations

2. Investigation management

• assigning investigators

• recording statements and evidence

• maintaining timelines and task tracking

3. Workflow and approvals

• automated routing based on policies

• escalations and deadline alerts

• approval chains for decisions

4. Document and evidence management

• secure storage of reports, audio, video, emails

• version control and audit trails

• access control by role

5. Hearings and outcomes

• scheduling disciplinary hearings

• recording findings, sanctions, or dismissals

• tracking corrective actions

6. Appeals and reviews

• managing appeal submissions

• linking appeals to original cases

• final determinations and closure

7. Reporting and analytics

• case duration and backlog tracking

• trends by department or misconduct type

• compliance and audit reporting

Sources: PACER (2026[7]), “Public Access to Court Electronic Records”, https://pacer.uscourts.gov/; DXC Technology (2021[8]), Modernise legacy case management with DXC Justice Case Management Solution eBook, https://dxc.com/content/dam/dxc/projects/dxc-com/au/practices/microsoft-practice/pdfs/DXC-Technology-Modernise-legacy-case-management-with-DXC-Justice-Case-Management-Solution-eBook.pdf; McMillan, J.E. (2024[9]), “The Potential of Computerized Court Case Management to Battle Judicial Corruption”, https://www.cumbrejudicial.org/sites/default/files/2024-01/Using%20CCMS%20to%20Combat%20Judicial%20Corruption%20Book%20Chapter%204.pdf.

Moreover, several functionalities could be included in the system, including the ability of several agencies to review the information as well as a central case repository as well as digital evidence storage and the use of analytics.

Thailand could consider further steps to improve efficiency in disciplinary and criminal investigations, including the usage of clear criteria for information sharing, liaison officers or co-ordination units, joint training, time-bound protocols, and automated data redaction tools (i.e. to protect sensitive personal or classified information before sharing)

Original recommendation

Strengthening the co-ordinating role of the NACC to facilitate the exchange of information between the criminal and disciplinary regime and ensure a coherent approach to investigations.

In Thailand, the disciplinary system works in parallel with the criminal one, as part of the wider framework for the enforcement of integrity standards. Exchange of information is crucial, as authorities under one of those enforcement regimes may become aware of facts or information that are relevant to another regime, and they should swiftly notify them to ensure potential responsibilities are identified, specially, during the investigative phase (OECD, 2021[2]). As previously stated, NACC already has some co-ordinating functions for initiating criminal proceedings given that it is the only agency with the main mandate on criminal investigations (for example letters or requests to consult the relevant agencies).

Answers provided by Thailand pointed to NACC having authority over both criminal and disciplinary cases. When the case is being investigated solely by NACC, the preliminary inspection and inquiry will usually be done in parallel (disciplinary and criminal). However, when the disciplinary investigation is being conducted by any other agency (line ministries, PACC, and others), co-ordination is not assured, and rarely the case. This means that the investigation of the same conduct, facts and evidence gets duplicated in two different institutions.

NACC already has some tools to increase co-ordination, including sending letters or requests to relevant agencies. However, a legal reform could be necessary to establish formal ways of co-operation and exchange of information. This might include formal information sharing and mandatory regular meetings between authorities investigating the same conduct or individual. For example, in the UK, criminal proceedings and disciplinary proceedings are legally distinct, like in Thailand, but there is clarity that the disciplinary action does not have to wait for criminal prosecution to conclude. It is also legally established that information sharing is permitted where it is lawful, proportionate, and necessary. This includes the principle that criminal acquittal does not equal disciplinary exoneration, and that the standard of proof differs in both regimes (criminal: beyond reasonable doubt; disciplinary: balance of probabilities). Furthermore, in the UK, legal protocols on information sharing demonstrate formal information-exchange arrangements between criminal justice entities and related agencies (Box 5.4).

Box ‎5.4. Information sharing for disciplinary investigations in the UK

• Crown Prosecution Service (CPS) protocols — national and inter-agency protocols governing disclosure and cooperation between police and CPS (criminal disclosure, mutual assistance). Crown Prosecution Service+1

• UK government guidance on public-sector data sharing, including legal bases for sharing personal data across agencies, showing statutory and common-law frameworks for lawful information exchange in public-sector contexts.

Source: UK Government (2018[10]), “Supplementary guidance: public sector data sharing for prevention and detection of crime”, https://www.gov.uk/government/publications/identity-document-validation-technology/supplementary-guidance-public-sector-data-sharing-for-prevention-and-detection-of-crime.

Other OECD countries have similar arrangements and distinctions, lacking in the Thai context. The following box exemplifies how different OECD countries have addressed this issue in legislation and practice (Box 5.5).

Box ‎5.5. Disciplinary vs. criminal regimes across OECD countries

Canada

Framework

Criminal justice system and administrative discipline are separate.

How information is exchanged

• provincial freedom of information laws

• regulatory bodies may access criminal records or investigation material

Australia

Framework

Parallel criminal and disciplinary systems are recognised across federal and state levels.

How information is exchanged

• information sharing agreements between:

  • police

  • integrity commissions

  • employers

United States

Framework

There is a strong separation between criminal prosecution and administrative discipline.

How information is exchanged

• internal affairs investigations

• prosecutorial disclosures

• subject of constitutional protections (e.g. Fifth Amendment)

Overall, as previously explained, Thailand does consider the independence of processes and the different standards of proof, but more legal clarity could be considered. Since the 2021 Integrity Review, no steps have been taken towards addressing this issue or amending the legal framework. Therefore, Thailand could consider other intermediate steps, such as organising regular meetings between disciplinary and criminal authorities on high profile cases, informal information sharing agreements and regular meetings to exchange information and standards between authorities investigating the same conduct/individual. At any rate, considering the need for much of these to be codified and clarified in law, Thailand could consider an initial assessment of the challenges in the investigative stage in both regimes and propose synergies to address these issues, aimed at consolidating a draft for reform.

Encouraging transparency about the effectiveness of the disciplinary system and the outcomes of cases

OCSC could develop a framework to measure the efficiency, fairness and quality of the disciplinary system including by publishing selected disciplinary information in an interactive and user-friendly way (open data) enabling its re-use and further analysis

Original recommendation

Strengthening the monitoring role of the OCSC on disciplinary enforcement and developing a framework to measure the efficiency, fairness and quality of the disciplinary system.

The 2021 Integrity Review called for collecting and processing statistical data to the OCSC in order to monitor the efficiency and effectiveness of the disciplinary system, including by making selected disciplinary information publicly accessible in an interactive and user-friendly way (open data). The compilation of statistical data would allow to assess the effectiveness of the disciplinary system as well as inform integrity and anti-corruption policies as part of the broader monitoring and evaluation of the integrity system. (OECD, 2021[2]).

As explained in the previous review in Thailand, there is no standardised process regarding the collection of enforcement data. The OCSC collects several data from government agencies on imposed disciplinary sanctions (and can be organised by offence). However, the data is not shared with the public. NACC may collect some data about disciplinary proceedings which are not publicly accessible, mostly due to confidentiality. Further information provided by Thailand showcased that NACC is in fact collecting and publishing information on certain cases. Disclosed information includes inquiry file; evidence collected in the process and decision. However, since the penalty is decided and finalised by the respective supervisory agency, final decisions are rarely reported/reflected in the NACC system. This is exactly why, the 2021 Integrity Review suggested OCSC be given this role. As is usually the case with a central civil service agency, OCSC can collect information through its representatives at government agencies and design, implement and follow up on disciplinary standards.

As the previous review proposed, Thailand could consider publishing selected disciplinary information in an interactive and user-friendly way (open data) enabling its re-use and further analysis. Through further analysis, the data collected can help identify challenges and areas for further improvements within the disciplinary enforcement regime. The OCSC can make use of this information to enhance its monitoring and oversight activities and the overall effectiveness of disciplinary proceedings. Several OECD countries have developed similar systems or relevant indicators (e.g. share of reported alleged offences taken forward, and average length of proceedings) for the justice system, which can be adapted to the needs and process of the disciplinary system (Box 5.6) (OECD, 2021[2]).

Box ‎5.6. OECD countries publishing disciplinary data

France

In France, disciplinary cases are published and updated in a portal. In 2023, 3 949 state civil servants were sanctioned. In two-thirds of cases, the sanctions are in the form of a reprimand or a warning. In 2023, nearly 25 000 cases were registered in the field of litigation concerning civil servants and public officials, whether before administrative courts, administrative courts of appeal or the Council of State (level close to the average for 2015-2022 which is 25 500).

Similarly, the open data portal (data.gouv.fr) publishes a wide array of public sector datasets, including disciplinary data like sanctions disciplinaires as an open dataset. France also provides open data of judicial decisions (decisions de justice) with structured, machine-readable access via official portals (e.g. opendata.justice-administrative.fr).

For example, it includes:

• police disciplinary sanctions (historical and aggregated)

• court and administrative disciplinary decisions as open data

• data available in csv / machine-readable formats

United Kingdom

The UK pioneered open government data, including data.gov.uk which provides datasets from various agencies on public administration, scandals, ethics, and public spending. Specific disciplinary data isn’t centralized at a national “discipline” portal, but multiple datasets exist through open government and transparency initiatives. It supports search, access, metadata, and reuse of datasets across multiple domains.

Sources: French Government (2024[11]), Les sanctions disciplinaires et les recours – Édition 2024, https://www.fonction-publique.gouv.fr/toutes-les-publications/les-sanctions-disciplinaires-et-les-recours-edition-2024; French Government (2026[12]), "La plateforme des données publiques françaises”, https://www.data.gouv.fr/; UK Government (2026[13]), “Data directory”, www.data.gov.uk.

PACC could also have a role, considering how the data can be used to inform integrity and anti-corruption policies. Moreover, they can help identify areas, sectors and patterns emerging from on-going investigations and sanctions imposed. More generally, data on disciplinary enforcement can be part of the broader monitoring and evaluation of the integrity system or even feed into the Integrity and Transparency Assessment (ITA).

Proposals for action

Strengthening fairness, objectivity and professionalism

• Institutionalise ownership of the disciplinary function, including by moving away from ad hoc arrangements toward clearer institutional responsibility for disciplinary investigations.

• Introduce professional specialisation in disciplinary investigations reducing reliance on rotating, untrained officials by professionalising investigative roles.

• Strengthen safeguards for supervising and disciplinary officials, including by establishing a merit-based selection process (especially for senior roles), adequate job security and competitive remuneration.

Building capacity and investigative expertise

• Expand disciplinary trainings at institutional level by increasing the scale, frequency, and reach of training on disciplinary procedures and investigations.

• Develop e-learning modules on disciplinary procedures whilst ensuring consistent understanding of rules and procedures across all levels of government.

• Establish an informal network or platform of disciplinary investigators that enable exchange of experience, peer learning, and mentoring among members of ad hoc inquiry commissions.

• Create a registry of trained disciplinary investigators and maintain a pool of officials with recognised legal and investigative qualifications.

• Consider piloting shared disciplinary services and provide cross-agency investigative capacity rather than relying solely on individual ministries.

Improving timeliness and efficiency

• Reform legislation to establish reasonable timeframes for disciplinary proceedings, including deadlines to initiate investigations, maximum duration of investigations and time limits for issuing decisions.

• Adopt interim measures pending legal reform, such as internal guidance setting indicative or maximum timelines for each stage of the process.

Enhancing coordination and avoiding duplication

• Clarify and streamline mandates between NACC and PACC to reduce overlap and duplication in disciplinary investigations.

• Promote regular coordination meetings between NACC, PACC, OCSC, and investigators from government agencies with a focus on the exchange of good practices and case-handling challenges.

• Strengthen cooperation between criminal and disciplinary authorities, including by considering information-sharing arrangements and regular meetings on cases involving the same conduct or individuals.

• Consider legal reform to codify cooperation mechanisms and clarify information-sharing rules, standards of proof, and parallel proceedings.

Digitalisation and information management

• Develop an electronic disciplinary case management system, including a central case repository, digital evidence storage, workflow management and deadline tracking and analytics on duration, backlog, and trends.

• Leverage existing complaint-reporting systems as a foundation for a full case-tracking system.

Transparency, monitoring and accountability

• Strengthen OCSC’s monitoring role over disciplinary enforcement and position OCSC as the central body for collecting and analysing disciplinary data.

• Develop a framework to measure efficiency, fairness, and quality, including indicators such as the duration of proceedings, types of sanctions imposed and proportion of allegations taken forward.

• Publish selected disciplinary data as open data in interactive, user-friendly, and reusable formats and protect confidentiality while enabling transparency and analysis.

• Use disciplinary data to inform integrity and anti-corruption policies, including by using findings into broader integrity assessments (e.g. ITA).

References

[6] DGAEP (2026), “Homepage”, Direção-Geral da Administração e do Emprego Público, https://www.dgaep.gov.pt/.

[8] DXC Technology (2021), Modernise legacy case management with DXC Justice Case Management Solution eBook.

[12] French Government (2026), “La plateforme des données publiques françaises”, https://www.data.gouv.fr/.

[11] French Government (2024), Les sanctions disciplinaires et les recours – Édition 2024, https://www.fonction-publique.gouv.fr/toutes-les-publications/les-sanctions-disciplinaires-et-les-recours-edition-2024.

[1] Government of Thailand (2008), Civil Service Act, B.E. 2551 (2008).

[9] McMillan, J. (2024), “The Potential of Computerized Court Case Management to Battle Judicial Corruption”, https://www.cumbrejudicial.org/sites/default/files/2024-01/Using%20CCMS%20to%20Combat%20Judicial%20Corruption%20Book%20Chapter%204.pdf.

[5] OECD (2025), OECD Integrity Review of Brazil 2025: Consolidating Progress on Public Integrity, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/cfcce75d-en.

[2] OECD (2021), OECD Integrity Review of Thailand 2021: Achieving Effective Integrity Policies and Sustained Reform, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/e8949f1b-en.

[4] OECD (2017), “Enforcing integrity: Strengthening Mexico’s administrative disciplinary regime for public officials”, in OECD Integrity Review of Mexico: Taking a Stronger Stance Against Corruption, OECD Publishing, Paris, https://doi.org/10.1787/9789264273207-9-en.

[3] OECD (2017), Recommendation of the Council on Public Integrity, OECD/LEGAL/0435, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.

[7] PACER (2026), “Public Access to Court Electronic Records”, https://pacer.uscourts.gov/.

[13] UK Government (2026), “Data directory”, http://www.data.gov.uk.

[10] UK Government (2018), “Supplementary guidance: public sector data sharing for prevention and detection of crime”, https://www.gov.uk/government/publications/identity-document-validation-technology/supplementary-guidance-public-sector-data-sharing-for-prevention-and-detection-of-crime.