THAILAND LAW AND PRACTICE Contributed by: Wongsakrit Khajangson, Panupan Udomsuvannakul, Koraphot Jirachocksubsin and Pitchaya Roongroajsataporn, Chandler Mori Hamad a
2.5 Regulatory Sandbox Financial Services
programmable payment, TrustBiz Connext, letter of guarantee, biometric technology, QR payment, and Thai baht-referenced e-money token pilots within the Enhanced Regulatory Sandbox. Concurrently, the SEC’s Digital Asset Regulatory Sandbox, launched in August 2024, continues to support testing across exchanges, brokers, dealers, fund managers, advisers and custodial wallet providers. Securities The amended regulatory sandbox regulations that became effective in 2020 afford operators more flex - ibility by increasing the types of businesses that can participate, and continue to be utilised through 2025– 2026. According to the SEC, the types of business under the amended regulatory sandbox regulations cover all activities in capital markets. The additional types of businesses are as follows: • intermediaries – ie, securities investment advisory services, private fund management businesses, derivatives agent businesses, derivatives dealing businesses, derivatives advisory services, deriva - tives fund management businesses, newly added securities brokerage businesses, securities dealing businesses, securities underwriting businesses, mutual fund management businesses, and securi - ties borrowing and lending businesses; • post-trading service providers – ie, securities clear - ing houses, securities depository centres, securi - ties registrars, and the newly added derivatives clearing houses; • trading system service providers – ie, electronic trading platforms, and the newly added securities trading centres and derivatives exchanges; and • digital infrastructure for capital market providers. Digital Asset Services The SEC’s Digital Asset Regulatory Sandbox initia - tive, launched in August 2024, further expands the scope of innovation in the capital markets by allowing participants to test and develop digital asset services under flexible regulatory guidelines, including tourist wallets and programmable payment integrations co- ordinated with the BOT. This initiative aims to improve service efficiency, reduce operational costs, and provide investors with access to new and improved digital asset services. Participants in the sandbox
In 2024, the BOT introduced new regulatory sandbox guidelines developed from past concepts, aiming to enhance the progression of fintech, extend the scope of technologies that can be tested in the sandbox, and study the appropriate regulatory approaches for these technologies. In June 2025, the BOT also published draft Guiding Principles on AI Risk Management for supervised institutions and payment providers, sig - nalling supervisory expectations around governance, data integrity, model risk and explainability, followed by continued supervisory engagement through late 2025. According to the previous regulatory sandbox guidelines, there were two sandbox concepts, namely the “Regulatory Sandbox” and the “Own Sandbox”, and in 2024, a new concept, the “Enhanced Regula - tory Sandbox”, was added to enable broader, multi- party pilots (including programmable payments and e-money tokens) under tighter risk controls. For the Regulatory Sandbox, financial service opera - tors that can apply for testing in this sandbox must meet the following conditions: • Be under the BOT’s supervision. • Offer new or improved financial services or fintech innovations. • Offer financial services which: (a) contribute to the development or standardisa - tion of Thailand’s financial sector in collabora - tion with other providers; or (b) are required to be tested in the Regulatory Sandbox. The participants consist of: • financial institutions; • companies within a group of financial institutions; • non-banks under the BOT’s supervision; • fintech firms; and • technology firms that either test independently or in collaboration with those mentioned above. As of the time of writing, there are various financial innovations running tests under these regulatory sandboxes, eg, e-money on blockchain, cross-border payment, digital RD, peer-to-peer lending, national ID,
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