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Author	Prof Hisashi HARATA
Organisation/Institution	The University of Tokyo, Graduate Schools for Law and Politics
Country	JAPAN
Panel	Corporate Law and Governance
Title	From Brussels to Bangkok: Strategic Adaptation of the CSDDD in a Multipolar Corporate Governance Order
Abstract	Geopolitics has always influenced corporate law, but it has now become a first-order force in corporate governance as the Anglo-American-cum-global order unravels under intensifying geopolitical rivalry. Major powers—the United States, the European Union, and China—are advancing sharply divergent views of corporate purpose and the corporation’s role in society. The expectation of global convergence that once guided debates in corporate law has therefore given way to regionalization, where competing regulatory hubs promote rival corporate governance models and contest their reach. States caught between these paradigms increasingly pursue selective alignment that maximizes domestic political and economic advantage. Thailand’s recent experience illustrates this logic with exceptional clarity. In 2024–25, Thailand produced the draft due diligence law modeled directly on the EU’s Corporate Sustainability Due Diligence Directive, marking the first such attempt to transpose the CSDDD beyond the EU. As political uncertainty within Europe slowed the CSDDD, Thai officials questioned the logic of advancing an instrument whose future within the EU itself had become unsettled. The narrative shifted from “EU alignment” to “OECD readiness,” recasting mandatory due diligence as part of Thailand’s long-term accession ambitions rather than an externally imposed European standard. This reframing reduced political sensitivity and aligned the initiative with national strategic goals, revealing a pragmatic motivation to advance the OECD accession bid rather than adopt the EU vision of corporate purpose. If adopted, a bold effort by the EU to extend its Brussels-Effect influence could produce an emerging “Bangkok Effect”: a potential force multiplier that would extend the Thai CSDDD-style regime beyond the EU CSDDD’s narrowed scope. Thailand’s experience shows how corporate governance norms now travel through geopolitical competition rather than convergence. It also demonstrates that regionalization does not produce uniform adoption but strategic adaptation, through which states position themselves within an increasingly fractured corporate governance landscape.
Biography	Hisashi Harata is a Professor at Faculty of Law, The University of Tokyo. He teaches Private International Law. His current research focuses on international corporate law and labor law involving Japanese companies and their subsidiaries in Asia. His research also covers different legal aspects of the global society. He is a member of International Academy of Comparative Law, and the editorial board member of Asian Journal of Comparative law. He joined Harvard IGLP Scholars Workshop as faculty member from 2017 to 2019, held in Bangkok. He was a visiting scholar at University of Naples, Cornell Law School, NUS, SMU and Thammasat University. He often delivers lectures on Japanese law or other topics at foreign law schools like Michigan Law school, Columbia Law School, University of Florence, and KUL. He is very much keen on enhancing legal scholarship in Asia and developing the intellectual network of Asian legal scholars.