When Regulations Meet the Word "Urgent"

The Patterns That Recur

Process bypasses tend to take a small number of shapes, and each one breaks the control at a different point:

• Order first, paperwork later — staff are told to contact the supplier before an approved purchase requisition (PR) or purchase order (PO) exists. What is missing is the budget commitment, because no document has reserved the funds yet.
• Goods into the warehouse before formal inspection — the shipment has arrived, so it is booked into inventory and the inspection committee is convened retroactively. What is missing is evidence of the condition of what was actually delivered, which is exactly what a penalty claim or a rejection has to rely on (see goods receipt versus inspection).
• Skipping an approval level because the approver is away — the authorized person is on leave, the work cannot wait, so the request jumps a level or gets signed after the fact. What is missing is formal delegation of authority.
• Approving without reviewing the detail — the approver signs off on the summary because they trust the requester and have no time. What is missing is the decision information at the point of approval, such as the remaining budget for that programme (a point expanded in what to do when executives will not approve in the system).

All four share one feature: nobody intended to do anything wrong. Everyone was trying to keep work moving, and in several of these cases real damage would have occurred otherwise. What differs is whether the consequence can be recovered — some of these can genuinely be documented after the fact, and some cannot be recovered at all.

The Numbers Say Accommodation Is Not a Minor Issue

The ACFE (Association of Certified Fraud Examiners) report Occupational Fraud 2026: A Report to the Nations analysed 2,402 occupational fraud cases. Several findings speak directly to this topic:

Measure	Figure	How to read it
Most common weakness	Lack of internal controls 32% Override of existing controls 19%	51% of cases combined — controls that existed but were overridden rank second, which makes override a primary failure mode rather than a footnote
Duration before detection	Median 12 months	The loss does not surface in the accounting period in which it occurred, so there is no warning signal to stop the behaviour while it is happening
Value of early detection	Detected within 6 months: median USD 40,000 Running 5+ years: USD 1.1 million	Roughly a 27-fold difference — detection speed is worth more than rule severity
How cases surfaced	Tips accounted for 43% of cases	More than half of those came from employees — insiders see it before any control does
Effect of training	Training both staff and management: USD 84,000 No training at all: USD 150,000	Median losses differ by almost half — training operational staff alone is not enough; management has to be included

The single most relevant finding for urgency is that owners and executives caused losses more than nine times greater than ordinary employees. That is the same group with the authority to instruct a bypass — which is the quantitative reason controls must apply equally at every level, not only at the operational one.

Why This Persists

1. Urgency Is Never Graded

When every request arrives labelled "urgent", the label loses its ability to prioritize anything. The officer receiving it has no criterion for distinguishing a genuine emergency under the regulation from work that was simply started late. Both end up treated identically — bypassed in the same way.

2. The Cost of Saying No Falls on One Person

The officer who insists on the process absorbs all the friction, both from the requester and from the consequences of the delay, while whoever grants the exception bears no short-term cost. That incentive structure makes accommodation the rational choice for the individual even when it is irrational for the organization.

3. Rules Enforced by People Rather Than by the System

If the condition "an approved PO must exist before goods are received" lives in a procedure manual, the enforcer is the warehouse officer, who must exercise judgement every time they are asked. If the same condition lives in the system — where an inspection document can only be created by pulling from an existing purchase order or contract — the enforcer is no longer a person, and the answer changes from "I won't allow it" to "the source document has to exist before the system can create the receipt".

4. Cause and Effect Appear in Different Periods

The bypass happens in one month; the consequence appears at reconciliation, at period close, or when auditors arrive — potentially many months later, and usually to someone other than the person who granted the exception. The organization therefore never connects the two (the same disconnect shows up clearly during financial period close).

What Follows

Area	What happens	Recoverable after the fact?
Budget	An order already placed has not committed the funds, so the balance other approvers see is higher than reality	Partly — but if other requests have already been approved against the inflated balance, it becomes an overspend that has to be resolved (see budget overruns)
Accounting	The recognition date does not match the date the transaction actually occurred, affecting cut-off	Yes, if the period is still open — once closed it requires a prior-period adjustment and disclosure
Inventory	System quantities diverge from physical stock, producing duplicate orders or silent stockouts	Yes, through a count and adjustment — but costs issued in the wrong period are harder to correct (see stock mismatches)
Contracts and penalties	No evidence of condition or actual delivery date	No — the right to claim a penalty or reject delivery depends on evidence recorded at that moment
Auditability	Document dates are inconsistent — an approval dated after the payment	No — this is hard to explain and is one of the first things auditors look for
Internal fairness	Units that follow the process wait longer than units that ask for special handling	Yes, but slowly — what has to change is people's expectations, not a number

Thai Procurement Regulation Already Provides a Fast Lane

A point that often gets overlooked: Thai law is not built on the assumption that everything can be planned in advance. Section 8 of the Public Procurement and Supplies Administration Act B.E. 2560 (2017) sets out four principles at once — value for money, transparency, efficiency and effectiveness, and auditability. "Efficiency" sits at the same level as "auditability"; it is not subordinate. Speed is therefore not something to be traded against correctness — the statute requires both simultaneously.

In practice that framework translates into explicitly defined routes:

Legal basis	When it applies	Conditions that must all be met
Section 56, paragraph one (2)(d) Specific method, emergency case	Supplies are needed urgently because of an accident, a natural disaster, or a dangerous communicable disease under the communicable diseases law	Using open bidding or the selection method would cause delay and risk serious damage — the full procurement documentation is still required; only the method of choosing the supplier changes
Ministry of Finance Regulation B.E. 2560, Clause 79, second paragraph	An urgent necessity that arose unforeseen and cannot be handled in time through the normal procedure	The responsible officer may proceed first, then promptly report and request the concurrence of the head of the state agency; once granted, that report is treated as the inspection evidence by analogy

The part worth reading in full is that Clause 79, second paragraph does not remove the paperwork. It moves the paperwork later while specifying exactly what it is (a report requesting concurrence), who approves it (the head of the state agency), and what legal effect it carries (it stands as inspection evidence by analogy). Those three elements are precisely the difference between "acting first and reporting afterwards, as the regulation permits" and "skipping the process".

IT Governance Reached the Same Design Earlier

Organizations that have been through an ISO/IEC 27001:2022 assessment will recognize control Annex A 8.32 Change Management, which classifies change requests into three tiers. The same framework maps directly onto administrative requests:

Tier	Approval	Procurement / disbursement equivalent
Standard pre-authorized	No per-instance approval, because the class of change has already been risk-assessed	Repeat low-value items from suppliers already under contract — these should carry fewer approval tiers, not the same route as capital purchases
Normal standard route	Reviewed by a change advisory board before implementation	Work that can be planned normally — PR → approval → PO → inspection → payment, in order
Emergency retrospective approval	May proceed immediately, but requires post-event approval and a root-cause review, and must still be recorded in the central log like any other request	This is Clause 79, second paragraph — act first, report for concurrence afterwards, with the case always appearing in the document register

The most valuable requirement in this framework is that an emergency closed without a post-implementation review must be escalated rather than quietly closed. That mechanism is what stops the emergency route from becoming the default route, because every use of it generates follow-up work owned by someone.

Five Approaches That Work

1. Write Down the Urgency Grades

Define which cases qualify as emergencies by reference to the regulation's conditions, not by the seniority of the requester. Criteria that hold up in practice:

• Emergency — damage or a service outage has occurred or is about to, and the cause was not foreseen: a primary device failing mid-service-window, a utility failure
• Time-critical — an externally imposed deadline that cannot move: a filing date set by a regulator, an event date already announced — normal route, with priority in the queue
• Normal — everything else, including work that started late, which is the largest category

The immediate benefit is that the word "urgent" regains meaning, and officers have a written basis to point to when they have to explain why a request is taking the normal route.

2. Make the Normal Route Fast Enough to Not Be Worth Avoiding

Procurify's 2026 Mid-Market Procurement Benchmark Report puts the median requisition-to-PO cycle at 58 hours in the lower mid-market, 65 hours in the upper mid-market, and 66 hours at enterprise scale, and notes that beyond 72 hours the process becomes a bottleneck associated with people starting to work around it.

The most actionable observation in that report is that the appropriate number of approval tiers for ordinary requests is two to three, and that approvers usually stall not out of reluctance but because they cannot see the remaining budget or the project code at the moment of decision. Adding that information to the approval screen therefore cuts waiting time more effectively than issuing reminders.

3. Open a Fast Lane With an Owner and a Deadline

A fast lane that actually works has to specify four things in advance:

Element	What must be defined
Entry criteria	Which causes qualify, and the maximum value per instance that may use this route
Approver	The position authorized to approve, plus a standing delegate when the primary holder is unavailable — defined by position, not by individual
Retrospective reporting deadline	How many working days the concurrence report must be filed within, and who follows up when it is late
Periodic review	A quarterly count of how often the route was used, broken down by unit and by cause, to see whether these are real emergencies or a planning problem

The last item is more useful than it looks. When one unit uses the emergency route at a high rate for several quarters running, what needs fixing is that unit's planning, not the strictness of the approval chain.

4. Move Enforceable Conditions Out of the Manual and Into the System

Conditions a system can enforce should not be left to daily judgement. Conditions worth encoding:

• An inspection document can only be created by pulling from an existing purchase order or contract, never typed from scratch
• Inventory balances change when the inspection document is completed, not when goods reach the warehouse door
• Remaining programme budget is checked on every approval request, and that balance is shown to the approver on the same screen where they approve
• Delegates are registered in advance so cases can move forward without skipping a level

The most valuable side effect is that the officer's answer changes shape — from a refusal into a statement of conditions — which visibly reduces interpersonal friction.

5. Retire Steps That Add No Control

Some steps were introduced to address a specific past incident and were never withdrawn. A review should ask of each step: which risk does this mitigate, and if it were removed, would that risk still be covered by another control? If there is no answer, the step is adding waiting time without adding control — which is what drives people around the process in the first place. A structured way to prioritize that review is set out in enterprise risk management.

How Saeree ERP Supports Urgent Processes

What a system contributes here is not prohibition — it is making the compliant route also the fastest one. This table pairs the problems above with the mechanisms that exist in the product:

Situation	Mechanism in Saeree ERP
The approver is away and the work cannot wait	The purchase requisition (PR) module supports delegation of approval authority, so a delegate can be registered in advance and the case moves forward in the correct sequence — no skipped levels, no signing after the fact
Documents stall because nobody knows it is waiting on them	Automatic approver notifications via email and LINE, together with real-time approval status tracking — you can see which level a case is sitting at and follow up precisely instead of asking around
Approving without seeing the remaining budget	Automatic budget availability checking before approval — the budget module checks on every disbursement request, with a real-time budget dashboard and alerts when a budget is nearly exhausted or exceeded
Funds need to be reserved before the case completes	The BG-03 budget reservation screen reserves funds in advance pending disbursement, which prevents other approvers from seeing a balance higher than reality
Goods received first, documents chased later	The IM-01 material receipt screen creates the document by pulling data from the purchase order or contract, with the inspection committee attached, and stock balances only update once the inspection document is completed — the sequence is enforced by document structure rather than by warehouse-officer judgement
An emergency requiring the specific procurement method	The purchase order (PO) module supports every Thai public procurement method — e-bidding, e-market, selection, and the specific method — so using the specific method in an emergency stays inside the system with complete documentation instead of moving offline
Reconstructing afterwards how a case progressed	Document tracking from requisition through to payment and retrospective document search and tracking — auditors are answered with the sequence the system recorded, rather than by assembling files after the event (compare with working in separate files, discussed in the risks of running on Excel)

To be straightforward about the boundary: these mechanisms control at the level of documents and budget amounts. They do not decide whether a given cause qualifies as an emergency under the regulation — that remains the discretion of the head of the agency, as the regulation provides — and setting the urgency-grading criteria remains work the organization has to do itself. What the system contributes is consistent enforcement of those criteria and an auditable record of them; it does not remove the need to have them.

Which Route Fits Which Case

Nature of the case	Route to use	What must follow
Damage or a service outage has already occurred and the cause was unforeseen	Emergency route — proceed first under Clause 79, second paragraph	File the concurrence report to the head of the agency promptly, and include the case in the quarterly emergency-route count
An externally imposed deadline that cannot be moved	Normal route, with queue priority and a standing delegate	No extra documentation — but record where the deadline came from, to inform the next planning cycle
Repeat low-value items from a supplier already under contract	A route reduced to two or three approval tiers	Periodically review the value threshold and the item categories that qualify
Work with a known deadline that was started late	Normal route — it does not meet the "arose unforeseen" condition	Record it as input for the annual procurement plan (see procurement management)
Capital or high-value items, however urgent the requester states	The full normal route, with no reduction in tiers	If it genuinely cannot be accelerated, adjust the downstream schedule rather than the approval sequence

Good regulation is not measured by how strict it is, but by whether people can still follow it on the day something is urgent — and when they cannot, what needs fixing is the route, not the people.

— Sureeraya Limpaibul, Managing Director, Grand Linux Solution Co., Ltd.

Conclusion

Urgency is a normal operating condition, not an exception. Thai law already recognizes this — in Section 8, which places "efficiency" on the same footing as "auditability", and in Clause 79, second paragraph, which permits acting first and reporting afterwards under clearly stated conditions. What organizations have to do is therefore not choose between speed and correctness, but:

• Write down the urgency grades — so that "urgent" means something again and officers have a basis to point to
• Make the normal route fast enough — fewer approval tiers for ordinary items, and remaining budget visible at the point of decision
• Open a fast lane with an owner, a reporting deadline, and a usage count — on the same framework IT change management already uses
• Move enforceable conditions into the system — so the officer's answer is a statement of conditions rather than a refusal
• Watch the emergency-route share — that figure identifies which unit has a planning problem faster than waiting for an audit finding

If you would like to use Saeree ERP to structure approval workflows, budget availability control, and retrospective auditability in your organization, please contact our team for more information.

References

• Public Procurement and Supplies Administration Act B.E. 2560 (2017) — Section 8 (value for money, transparency, efficiency and effectiveness, auditability) and Section 56, paragraph one (2)(d), the specific method for emergency cases
• Ministry of Finance Regulation on Public Procurement and Supplies Administration B.E. 2560, Clause 79, second paragraph — urgent necessity: proceed first, then promptly report for concurrence (Comptroller General's Department, Ministry of Finance)
• ACFE — Occupational Fraud 2026: A Report to the Nations (Association of Certified Fraud Examiners) — figures from 2,402 cases: median loss, duration before detection, and the share of cases involving missing or overridden controls
• ISO/IEC 27001:2022 Annex A 8.32 — Change Management — classification of requests as Standard / Normal / Emergency and the requirement for post-event approval with root-cause review
• Procurify — 2026 Mid-Market Procurement Benchmark Report — median requisition-to-PO cycle times by organization size, the 72-hour bottleneck threshold, and the appropriate number of approval tiers