How will it be supported? Is this for walls, or all sides? What kind of plywood? I can't say either way, but I do know that without knowing those pieces of information, you won't get a 'for sure' answer.
It depends on how you build it. I like the thought of "over build". I think for designs where you will use external bracing with 2x4's spaced every so many inches and you are good. If you aren't using the external bracing design I would go thicker. But I have seen some thin stuff work. I'm doing internal bracing and using 1"(25.4mm) wood. I don't wanna worry about people or objects bumping into the side of mine. The resin or fiberglass coat will also toughen it up a bit.
Thickness depends on bracing and actual depth of the exposed glass below the water line. If it's actually 2.5 feet from the surface water line to the bottom and the bottom is exposed, then 12MM is thin. It's possible with sufficient support to manage that, but I think it's risky. At 12MM, the safety factor is only 2.0, so I'd want 15-17MM with some extra bracing at 15MM.
If the actual depth is 2 feet (the bottom of the tank is plywood and the glass is only exposed at 6 inches above the bottom and 24 inches below the water line), then 12MM would be fine.
I read on another web site that "structural" plywood should not be used due to having a water based glue. Not sure how true this is, but if it is like particle board (looks like a bunch of wood chips glued together) when it gets wet it disintegrates.