Fintech & payments regulation in Thailand (2026)
Fintech and digital payments in Thailand: licensing regime.
Thailand has a comprehensive, operational licensing regime for digital payments and fintech anchored in the Payment Systems Act 2017, with the Bank of Thailand as the primary prudential and oversight authority. Payment service providers, including e-money issuers, credit/debit card operators, and bill-payment services, must obtain a Designated Payment Service License from the Ministry of Finance on BOT recommendation, or register with the BOT depending on scope. The framework was significantly extended in June 2025 when the Ministry of Finance approved three virtual bank applicants, and BNPL remains the principal gap, with formal guidelines expected in 2026.
Legal framework
Payment Systems Act B.E. 2560 (2017), administered by the Bank of Thailand (BOT); Ministry of Finance issues designated payment service licenses on BOT recommendation
Key points: digital payments & fintech in Thailand
Payment Systems Act 2017
The Payment Systems Act B.E. 2560 (2017), effective April 2018, is the primary statute. It classifies regulated activities into essential payment systems, payment systems under supervision, and payment services under supervision (e-money, card schemes, bill payment, electronic funds transfer). The BOT is the competent authority for oversight and enforcement.
E-money & payment institution licensing
E-money issuers and designated payment service operators require a Ministry of Finance license issued on BOT recommendation. E-money licensees must maintain minimum paid-up capital of THB 100 million, hold 100% reserves in bank accounts, and submit a full application package (business plan, IT description, AML/KYC policies) with a typical processing time of 4-6 months.
PromptPay instant payment rail
PromptPay, launched in 2017 and operated under BOT oversight, is Thailand's national instant-payment infrastructure, enabling real-time transfers via mobile number, national ID, or QR code. It now underpins over 35 billion transactions annually and is interlinked with ASEAN QR payment schemes in Malaysia (DuitNow), Singapore (PayNow), Indonesia, and others.
Open banking status
Open banking remains in a policy development phase. Following a public consultation in February 2024 on 'Open Banking Data for Consumer Empowerment', the BOT outlined a roadmap but formal mandatory open-banking rules and standards have not yet been published. Steering committees and working groups are being established to drive implementation.
Virtual bank licenses (2025)
On 19 June 2025, the Minister of Finance approved three virtual bank applicants: ACM Holding (CP Group consortium); Krung Thai Bank / AIS / PTTOR consortium; and SCB X / WeTechnology / KakaoBank consortium. Approved entities must establish a public limited company and pass a BOT readiness assessment before commencing operations within one year of approval.
BNPL regulatory gap
Buy Now Pay Later products currently fall outside the BOT's direct supervisory perimeter because BNPL transactions are not legally classified as 'loans' under existing statutes, meaning debts are not reported to the National Credit Bureau. The BOT has flagged systemic risk from hidden household debt and is expected to introduce BNPL-specific guidelines in 2026 covering mandatory credit assessments and reporting obligations.
Timeline of decisions
- GuidanceBOT Expands Sandbox to Include Programmable Payments and Thai-Baht Stablecoin Testing
The Bank of Thailand expanded its Enhanced Regulatory Sandbox on 24 December 2025 to allow DLT-based programmable payments and Thai-baht-pegged stablecoins, accepting open-ended applications. This is the first supervised pathway for condition-based smart-contract payments in Thailand and feeds directly into the CBDC learnings from 2023.
Baker McKenzie (citing BOT)
- Decision · officialMinistry of Finance Grants Three Virtual Bank Licences
On the BOT's recommendation, the Minister of Finance approved three consortia, Krung Thai Bank/AIS/PTT-OR, SCBX/WeBank/KakaoBank, and a third group, to establish fully digital banks targeting the underserved, each requiring THB 5 billion initial capital rising to THB 10 billion within five years. Operations must begin within one year of approval.
Bank of Thailand
- Law · officialDigital Asset Businesses Decree Amended with Extraterritorial Licensing Scope
Amendments to the Emergency Decree B.E. 2561 (2018) require offshore digital asset platforms that actively target Thai users to obtain Ministry of Finance approval before offering services in Thailand. The amendment closes a key regulatory gap exploited by unlicensed cross-border crypto operators.
Thailand Securities and Exchange Commission
- DecisionSEC Carves Out Sandbox Exemption from Crypto-Payment Prohibition
The SEC revised Notification No. 5/2565, granting digital asset operators enrolled in the BOT's Programmable Payment sandbox a specific exemption from the blanket crypto-as-payment ban. This allows live testing of tokenised baht payments while keeping the general prohibition in force.
Mahanakorn Partners Group (MPG)
- Guidance · officialBOT Publishes Retail CBDC Pilot Findings (Project Bang Khun Phrom)
Following a live pilot from late 2022 to October 2023 with ~4,000 users and 140 merchants across three financial service providers, the BOT concluded that a retail digital baht could foster competition and support programmable payments but announced no immediate plans for full-scale issuance.
Bank of Thailand
- Decision · officialFive ASEAN Central Banks Sign Multilateral Real-Time Payment Connectivity MOU
At the G20 Bali Summit, the central banks of Indonesia, Malaysia, the Philippines, Singapore, and Thailand signed an MOU committing to interconnect their national fast-payment systems. The agreement formalised the ASEAN Payment Connectivity initiative and extended PromptPay's bilateral linkages into a regional network.
Bank of Thailand
- DecisionSEC Bans Use of Crypto as a Means of Payment
The Thai SEC issued Notification No. 5/2565 prohibiting licensed digital asset exchanges, brokers, and custodians from facilitating or promoting cryptocurrency as payment for goods and services, citing volatility, money-laundering risk, and threats to monetary stability. Crypto trading on licensed exchanges was unaffected.
Baker McKenzie Blockchain Blog (citing SEC Notification)
- Law · officialPayment Systems Act B.E. 2560 (2017) Enters Force
The landmark Act replaced Thailand's fragmented payment laws, giving the Bank of Thailand statutory authority over essential payment infrastructure, supervised payment networks, and designated payment services (e-money, card schemes, bill payment, electronic funds transfer). It introduced payment-finality protections, customer-fund safeguards, and oversight aligned with CPMI-IOSCO Principles for Financial Market Infrastructures.
Bank of Thailand (Official Act Text)
- Decision · officialPromptPay National Instant Payment System Launched
The BOT-mandated PromptPay system, operated by National ITMX and built on alias-based routing (mobile number or national ID), went live in January 2017 as the centrepiece of the National e-Payment Master Plan. It enabled near-zero-fee real-time interbank transfers and grew to 67 million registered users by 2023, later adding QR merchant payments and government disbursements.
World Bank Fast Payments Toolkit
- Guidance · officialBank of Thailand Issues Fintech Regulatory Sandbox Guidelines
The BOT published its sandbox framework in December 2016, offering financial institutions and fintech companies supervised 6-12 month testing windows for innovations under BOT oversight. Early sandbox work produced the Thai QR Code Payment Standard, subsequently adopted as the national QR standard by all banks.
Bank of Thailand
- Decision · officialNational e-Payment Master Plan Announced
The Ministry of Finance and BOT jointly launched a five-pillar national digital payments strategy, covering PromptPay, card-terminal expansion, e-tax, government e-disbursements, and public education, targeting annual savings of THB 75 billion from reduced cash usage. It set the strategic foundation for Thailand's entire digital payments ecosystem over the following decade.
Bank of Thailand
Sources
- bot.or.th/content/dam/bot/documents/en/laws-and-rules/laws-and-regulations/lega
- bot.or.th/en/our-roles/payment-systems/payment-act-oversight.html
- bot.or.th/content/dam/bot/fipcs/documents/FPG/2561/EngPDF/25610089.pdf
- bot.or.th/en/financial-innovation/digital-finance/digital-payment/promptpay.htm
- bot.or.th/en/news-and-media/news/news-20250619.html
- bot.or.th/en/financial-innovation/digital-finance/virtual-bank.html
- openbankingtracker.com/regulator/thailand
- nationthailand.com/business/banking-finance/40060025
- fosrlaw.com/2025/payment-processing-licenses-in-thailand-updated-2025-overview/
- nortonrosefulbright.com/en-th/knowledge/publications/397bf640/buy-now-pay-later-regulation-ar
- sarah-huang.com/post/state-of-open-banking-thailand-2025
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Next topicOrientation, not legal advice: verify against the primary sources linked above. Last verified 24 May 2026. Methodology & how to cite · State of Technology Regulation 2026