THAILAND LAW AND PRACTICE Contributed by: Wongsakrit Khajangson, Panupan Udomsuvannakul, Koraphot Jirachocksubsin and Pitchaya Roongroajsataporn, Chandler Mori Hamad a
digital assets. This will enable authorities to identify appropriate measures to manage the risks associ - ated with such financial technologies while ensur - ing adequate protection for users. Furthermore, there has been progress in open data initiatives to empower consumers to transfer their data conveniently and securely from one provider to another, enabling them to access superior services. The BOT’s parallel efforts include implementing a digital factoring platform using a central web service to reduce invoice fraud and broaden SME access to finance, and the continued rollout of the dStatement/ open data agenda alongside PromptPay/Thai QR enhancements for SMEs and cross-border use cases. Issuance of Legal Framework for Virtual Banks Due to the rapid development of digital finance, almost all business operators in Thailand, whether banks or non-banks, have been focusing on provid - ing services via digital channels. In 2024, the MOF issued a notification outlining the criteria, conditions and procedures for applying for a licence to establish branchless commercial banks, also known as “virtual banks”. Concurrently, the BOT announced regulatory guidelines to accommodate the operations of future virtual bank licensees. These new frameworks aim to promote financial inclusion and enhance competition within the financial market. Following the application period from March to Sep - tember 2024, five applicants submitted proposals to establish virtual banks. On 19 June 2025, the MOF, upon the recommendation of the BOT, approved three applicants to proceed with the establishment of virtual banks, as follows: • ACM Holding Company Limited and its partners; • a consortium comprising Krung Thai Bank Public Company Limited, Advanced Info Service Public Company Limited and PTT Oil and Retail Business Public Company Limited; and • a consortium comprising SCB X Public Company Limited, WeTechnology Limited and KakaoBank Corp The approved licensees are expected to commence operations in 2026 under an initial restricted phase
focused on risk controls, IT robustness and govern - ance, before full rollout.
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models
The major players in the Thai fintech industry are pre - dominantly financial institutions and traditional non- banking financial institutions, which have adopted technology for their services to facilitate customers’ needs and to increase their market share. Other play - ers include venture capitalists and start-ups. The main fintech business models in Thailand are as follows. E-Money, E-Wallets and E-Payment E-money, e-wallet and e-payment service providers are among the most significant players in the Thai fintech industry. Their business operations and ser - vices can now be conducted or provided through their online platforms rather than physical branches. As of early 2026, payments and transfers remain the largest fintech vertical by firm count, and digital wallets have continued to gain share alongside A2A/QR usage. Other than financial service providers, a number of new players are entering this area, most of which are backed by venture capitalists, as start-ups that co- operate and partner with major social platform busi - ness operators. This can also serve as an alternative solution for foreign financial service providers facing certain capacity limitations or stringent qualification requirements under Thai law. Digital Assets In 2018, the SEC recognised digital tokens and cryp - tocurrency as digital assets. Business operators in this sector are categorised into two groups, as follows. Primary market A business operator in the primary market can be either: • an ICO issuer looking to raise funds by issuing coins; or
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