Fintech 2026

THAILAND LAW AND PRACTICE Contributed by: Wongsakrit Khajangson, Panupan Udomsuvannakul, Koraphot Jirachocksubsin and Pitchaya Roongroajsataporn, Chandler Mori Hamad a

• an ICO portal providing token digital system ser - vices. As of the time of writing, two ICO issuers have received SEC approval in Thailand. One digital asset fundrais - ing project was successfully completed in Thailand during 2025. Several additional digital token offerings remain under regulatory review or in pre-consultation stages with the SEC. Secondary market In the secondary digital assets market, the service providers relating to digital assets that are currently recognised by Thai regulations and supervised by the SEC are as follows: • digital asset exchanges; Digital lending is an important platform that financial service providers use to reach new retail customers, eliminate physical limitations and facilitate business activities with customers. Many financial service pro - viders, especially personal loan providers, are inter - ested in expanding their online services. Some financial service providers have chosen to co- operate with social platform operators in providing digital lending services to the platform’s customers, and vice versa, rather than develop their own (online) platform and obtain licences. Peer-to-Peer Lending Platforms Peer-to-peer lending platforms are electronic platform services that link lenders and borrowers. The plat - forms’ role also includes facilitating loan contracts and carrying out fund transfers and repayments between the parties. According to the BOT, as of October 2025, there were 12 peer-to-peer lending service operators that had obtained licences from the MOF, of which seven had commenced operations. Additionally, five operators were testing their systems in the BOT regu - latory sandbox as of December 2025. Entry by region - • digital asset brokers; • digital asset dealers; • digital asset advisory services; • digital asset fund managers; and • digital asset custodial wallet providers. Digital Lending

al alternative lenders and tighter data-sharing with the National Credit Bureau are expected to support the prudent scale-up of P2P volumes in 2026. Crowdfunding Both equity and debenture crowdfunding exist for private and public limited companies through crowd - funding portals in Thailand. In this respect, crowd - funding, where shares or debentures are issued as consideration, is deemed a type of public offering under SEC regulations. A crowdfunding portal opera - tor must obtain a licence from the Office of the SEC. 2.2 Regulatory Regime Currently, the fintech industry is not directly regulated by any specific overarching legislation in Thailand. However, operators need to comply with certain busi - ness-related regulations. The key regulations related to fintech business activi - ties are as follows. Payment Systems (Including E-Money, E-Wallet and E-Payment) In order to enhance the supervision of payment sys - tems and payment services, the Payment Systems Act B.E. 2560 (2017) (the “Payment Systems Act”) was enacted, and came into effect on 16 April 2018. Its main purpose is to regulate the following. Highly important payment systems are payment sys - tems that are important to the security and stability of the country’s payment systems, financial systems or monetary systems. Designated payment systems are: • payment systems that are networks between system users that handle fund transfers, clearing or settlement, such as retail fund transfer systems, payment card networks and settlement systems; and • any other payment systems that may affect the public interest, public confidence, or stability and security of the payment systems.

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