You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

December 7, 2020

Bank of Thailand Introduces Digital Personal Loans

Informed Counsel

With technological advancements, business operators are able to access more varieties of data than ever before, and are able to use that data to assess the terms on which loans are provided. This means that they can provide services to consumers more efficiently and with lower operating costs. More importantly, however, it allows them to provide financial services to a broader range of consumers who would otherwise not be able to access vital funds.

To facilitate this, on September 15, 2020, the Bank of Thailand (BOT) introduced a new type of personal loan—the digital personal loan—under BOT Circular Re: Rules, Procedures and Conditions for the Undertaking of Digital Personal Loan Business. Sometimes known as “quick loans” or “easy loans” in other jurisdictions, this new type of loan instrument is intended to promote Under the circular, a digital personal loan is defined as a personal loan for which business operators utilize digital technology and alternative data (e.g., utility and mobile phone bill payment records) to assess the borrower’s ability and willingness to repay. The digital personal loans do not include loans for which car registration is used as collateral.

The key requirements for undertaking a digital personal loan business are as follows:

  1. Business operators are expected to use technology and alternative data to determine the customer’s risk profile, based on their ability or willingness to repay. The alternative data that is used must be from a trusted source and use a sensible hypothesis in assessing the customer’s credit profile. Such business operators may comply with the BOT’s information-based lending guidelines.
  2. Business operators must use electronic channels for both the provision and repayment of the loans. This may include disbursing and repaying by bank transfer, direct debit, or e-money to create a digital footprint in the financial sector for the customers.
  3. Business operators must disclose relevant information to customers, including interest rates, fines, service fees, operating fees, outstanding loan tables, and any other fees relating to the Digital Personal Loan. This information must also be easily accessible for customers through electronic means (for example, by being hosted and easily accessible on the loan providers website).
  4. The maximum loan amount is THB 20,000 with a tenure of not more than six months.
  5. Business operators are prohibited from charging additional interest rates, fines, service fees, operating fees, or any other fees to customers for early repayment of a loan.
  6. Business operators are required to have IT security risk management measures in place. This includes measures to protect data from unlawful collection, processing, use, and destruction. Business operators also have an obligation to business continuity management, which they must satisfy by having a business continuity plan and an IT Disaster Recovery Plan. If the business operator will outsource their IT systems or connect their IT systems to third party services in a way that will involve the transfer of sensitive data (e.g. by using a cloud computing service), the third party must also have risk management and cybersecurity processes in place to the same standards.

Personal loan license holders that wish to offer digital personal loans must submit an application and supporting documents, including information on their minimum viable product, for BOT consideration at least 30 business days prior to the date on which they plan to begin offering digital personal loans. However, this application requirement is waived if the provision of digital personal loans only uses traditional methods of assessing customers’ ability or willingness to repay their loans (such as the National Credit Bureau).

Business operators who would like to issue digital personal loans but do not currently have a personal loan license must first apply for one from the BOT in accordance with the requirements of BOT Notification SorNorSor. 12/2563 Re: Regulations, Procedures and Conditions for Undertaking Business of Personal Loan under Supervision. In practice, these business operators may apply for a personal loan license and simultaneously apply for BOT approval of their plan to issue digital personal loans.

While digital personal loans look set to become a major offering in Thai consumer banking, they are also of particular interest to non-traditional loan operators—especially e-money operators, large-scale casual employers (such as ride-share operators and delivery services), and even retailers, as has been the case with similar “quick loan” systems in other jurisdictions.

RELATED INSIGHTS​ 

June 5, 2026
Vietnam’s AI regulatory framework has reached an important milestone. While the Law on Artificial Intelligence No. 134/2025/QH15 (AI Law) established the foundation for AI governance, many practical compliance requirements were left to implementing regulations. On April 30, 2026, the government issued Decree No. 142/2026/ND-CP (Decree 142), which took effect on May 1, 2026, and provides the first detailed guidance on the implementation of the AI Law. Although an official list of high-risk AI systems is still pending from the prime minister, Decree 142 provides valuable insight into how Vietnam’s risk-based AI regulatory framework will operate in practice. Risk Classification Framework The AI Law adopts a risk-based approach under which AI systems are classified as high-risk, medium-risk, or low-risk. Decree 142 builds on this framework by providing detailed guidance on how these classifications are determined. High-risk AI systems are determined based on factors such as (i) their potential impact on life, health, property, human rights, public interests, or national security; (ii) the sector in which they are deployed; and (iii) the scale of affected users or integration with critical infrastructure. The latest draft list of high-risk AI systems appears to follow these same principles. Medium-risk AI systems generally include systems that may mislead, influence, or manipulate users, particularly where users may not realize they are interacting with AI or AI-generated content. The focus is therefore on transparency and authenticity risks rather than broader societal or safety concerns. Low-risk AI systems are those that do not meet the criteria for either high-risk or medium-risk classification. Importantly, Decree 142 seeks to avoid over-classification. Certain systems may fall outside the high-risk or medium-risk regimes, including internal-use systems, office-support tools, technical editing applications, certain back-end processing systems, and AI systems used in artistic, gaming, cinematic, or other creative contexts. Providers must also review and
June 5, 2026
On May 11, 2026, Thailand’s Ministry of Social Development and Human Security released a draft Child Protection Act (“CPA”) for public review. The draft CPA would completely repeal and replace the current Child Protection Act B.E. 2546 (2003). This represents the most comprehensive overhaul of Thailand’s child protection framework in over two decades, reflecting the government’s stated objective of modernizing the law to address evolving social challenges—including those arising from digital technology—and to promote greater coordination among government agencies, local authorities, and civil society. The public review period closes on June 9, 2026. Key changes introduced by the draft CPA that could have significant implications for businesses, particularly online platform providers, media companies, and entities operating child-related services in Thailand, are set out below. Expanded Definition of “Child” Under the current CPA, a “child” is defined as a person under the age of 18, excluding those who have attained legal majority through marriage. The draft CPA removes the marriage exception entirely, broadening the scope of the law’s protections to include all individuals under 18 without exception. Replacement of “Abuse” with Broader Concept of “Violence” The current CPA uses the term “abuse/cruelty,” which covers acts causing harm to a child’s liberty, body, or mind; sexual offenses against children; and using children in harmful or immoral activities. The draft CPA replaces this with the broader concept of “violence,” which encompasses any act or omission causing harm to a child’s body, mind, or development; abandonment or neglect; improper exploitation; and sexual abuse. Notably, the new definition adds developmental harm as a recognized category of injury and captures all forms of misconduct regardless of the child’s consent. New Standalone Definition of Sexual Abuse, Including Online Conduct One of the most significant additions in the draft CPA is the introduction of a standalone definition
May 25, 2026
After several years of policy discussion and continued efforts led by the Ministry of Commerce (MOC) to relax the list of reserved businesses under the Foreign Business Act B.E. 2542 (1999) (FBA), the reform process has now reached a significant milestone. On May 12, 2026, the Thai cabinet approved in principle two draft subordinate legislative instruments aimed at delisting certain reserved business activities under the FBA and reducing licensing requirements for foreign business operators. These developments signal a renewed and concrete effort by the government to modernize Thailand’s business regulatory framework in order to attract foreign investment and boost Thailand’s competitiveness in the global market. Nine Businesses Set for FBA Delisting Below is a list of the nine businesses that are being targeted for delisting from the FBA’s restrictions. A draft ministerial regulation would delist the first eight reserved businesses, while a royal decree has been drafted to delist the ninth business: Telecommunications services (Type 1 license only, covering operators without their own telecommunications infrastructure), under the supervision of the Office of the National Broadcasting and Telecommunications Commission. Treasury center services subject to the Foreign Exchange Control Act B.E. 2485 and under the supervision of the Bank of Thailand. Securities-collateralized lending, pursuant to the laws governing securities and exchange and derivatives regulated by the Securities and Exchange Commission. Agency, dealer, advisory, or fund management services relating to derivatives where the underlying assets fall outside the scope of the Derivatives Act B.E. 2546 (2003) Intra-group shared services, including administrative, human resources, and IT functions Intra-group domestic debt guarantee services Leasing of partial space for installation of financial service machines and automatic vending machines for employee use Petroleum drilling services Trading of agricultural product derivatives through a futures exchange, with physical delivery or receipt of agricultural products at a futures exchange–designated
May 25, 2026
Thailand published new rules on May 1, 2026, establishing clear procedures for how the Anti-Money Laundering Office (AMLO) handles digital assets seized during criminal and money laundering investigations. Taking effect the following day, the Regulation of the Anti-Money Laundering Board on the Custody and Management of Seized or Frozen Assets (No. 3) B.E. 2569 applies to digital asset businesses, cryptocurrency holders, and anyone subject to asset seizure under Thailand’s anti-money laundering laws. For the first time, authorities now have a detailed roadmap for transferring seized digital property from private or foreign control into secure state custody. Digital asset businesses holding customer assets under investigation must be prepared to comply with these rules compelling repatriation of such assets in enforcement actions. Expanded Definition of Digital Assets The regulation defines digital assets to include not only those covered by Thailand’s existing digital asset business law but also any other property that can be stored using the same methods as digital assets. This broad formulation means the custody rules will apply to emerging blockchain-based assets and tokenized property that may not yet fall within the statutory definition of a digital asset business, giving authorities flexibility as the technology evolves. Mandatory Transfer to Domestic Custody When digital assets are held with service providers outside Thailand, AMLO will first attempt to transfer them to an account the office maintains with a licensed domestic digital asset business operator. If the domestic operator does not support that particular asset, the office will instead move the assets to its own cold wallet (offline, internet-isolated storage system). If neither option is feasible, the seizing official will report the situation to the Anti-Money Laundering Committee for alternative instructions. A similar hierarchy governs assets held in an accused party’s private wallet or by any third party that is not a