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

August 3, 2026

Bank of Thailand Proposes New Digital Channel Security Standards

Subscribe to Updates

On July 23, 2026, the Bank of Thailand (BOT) released for public comment its draft Notification on Digital Channel Security, which would significantly expand the scope and stringency of Thailand’s existing mobile banking security framework. If finalized in its current form, the draft notification would extend mandatory security requirements to credit card providers and credit providers, cover internet banking in addition to mobile applications, phase out SMS one-time passwords (OTPs) for transaction authentication, and introduce biometric verification requirements for high-value transactions. The public comment period is open through August 24, 2026.

Background

The BOT’s existing Mobile Banking Security Notification, issued in 2024, sets minimum security standards for financial institutions, specialized financial institutions (SFIs), and e-money providers, significantly reducing “money-draining app” fraud. However, fraudsters have since shifted to nonbank providers and internet banking channels, prompting the BOT to propose broader security requirements.

Expanded Scope of Regulated Entities and Channels

The existing Mobile Banking Security Notification covers only financial institutions, SFIs, and e-money providers offering mobile banking services. The draft expands coverage in two key areas: entities and channels. On the entity side, it adds credit card providers and credit providers that offer fund transfers to third parties at other financial service providers or that provide cash withdrawal services to individual retail customers. On the channel side, it broadens coverage to include internet banking in addition to mobile banking.

Strengthened Customer Authentication

The draft introduces enhanced authentication requirements in three areas:

  • Service enrollment and device changes. Providers must implement rigorous identity verification, notify customers of enrollment results through out-of-band communication channels, and adopt risk-mitigation measures such as cooling-off periods and temporary transaction limits.
  • Transaction-level authentication. Providers must use two-factor authentication for fund transfers, cardless ATM withdrawals, and transaction limit increases.
  • Secure authentication factors. Key requirements include the following:
    • “What-you-know” factors must protect against brute-force attacks.
    • “What-you-have” factors must use secure methods such as a registered mobile application with device binding or hard/soft tokens.
    • SMS OTPs must be discontinued for transaction authentication.
    • Biometric factors must use effective antispoofing technology, such as facial scanning, in compliance with the BOT’s guidelines on biometric technology in financial services.

Providers must cease sending SMS messages and emails containing embedded links and must establish incident response processes for counterfeit applications or websites.

Mobile Application Security Controls

Providers must ensure application integrity and block remote-access applications. Facial comparison with antispoofing technology is required for transfers exceeding THB 50,000 (approx. USD 1,490) per transaction or THB 200,000 (approx. USD 5,960) per day.

Next Steps

Affected financial service providers should assess their current systems against the draft requirements and consider submitting comments to the BOT by August 24, 2026.

Related Professionals

Industries

Fintech

Technology

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

November 29, 2021
On November 25, 2021, the Myanmar Investment Commission (MIC) issued a list of investment sectors that will receive priority attention in order to encourage national development and state building. The investment activities that MIC will prioritize are the following: Fertilizer manufacturing Cement manufacturing Iron and steel manufacturing Agriculture and livestock farming and related industries Value-added manufacturing of foodstuffs Electric vehicle manufacturing Pharmaceutical and medical device manufacturing Public transportation services Both foreign investors and local investors may invest in these sectors, and the MIC, ministries, and relevant state and regional governments will provide necessary assistance to the investors under the Myanmar Investment Law 2016. For more details on the new requirements, please contact Tilleke & Gibbins at [email protected] or +95 9 772 440 001.
Read More
November 24, 2021
Attorneys from Tilleke & Gibbins have provided the latest update to the Thailand contribution to Doing Business in…, a Q&A-style guide published by Thomson Reuters Practical Law that presents an overview of the legal framework for doing business in 63 jurisdictions worldwide. The Thailand chapter of the guide outlines Thailand’s legal system and key laws applicable to foreign companies doing business in the country. The chapter specifically covers the following main topics: Legal system: Thailand’s court system and codified legal system. Foreign investment: Lists of reserved business activities, restrictions on doing business with certain jurisdictions, exchange controls and currency regulations, and grants and incentives available to investors. Business vehicles: Ordinary partnerships, registered ordinary partnerships, limited partnerships, private limited companies, and public companies. Environment: Main laws and regulations, factory operation. Employment: Laws, employment contract requirements, work permits, and termination and redundancy. Tax: Taxes on employment, tax and nontax resident employees and businesses, corporate income tax, value added tax, special business tax, municipal tax, stamp duty, dividends, interest, intellectual property royalties. Competition: Important aspects of Thailand’s regulatory regime surrounding competition, centered around the updated Trade Competition Act. Antibribery and corruption: Laws, compliance requirements, regulatory authority. Intellectual property: Patents, trademarks, registered and unregistered designs, and copyright. Marketing agreements and advertising: Regulation of marketing agreements, Thailand’s Consumer Protection Act, direct marketing, role of the Consumer Protection Board and Food and Drug Administration. E-commerce: E-commerce laws and regulations, marketing and sales via online platforms. Data protection: An outline of Thailand’s Personal Data Protection Act. Product liability: Procedures and regulations for product liability and product safety, including the Unsafe Goods Liability Act and the Consumer Case Procedure Act. Product liability: Key regulatory authorities for trade competition, environmental issues, and financial services. To browse, download, or print the Thailand chapter, please visit the Practical Law website.
Read More
October 25, 2021
Michael Ramirez, a counsel in Tilleke & Gibbins’ dispute resolution group in Bangkok, has updated the firm’s contribution to the Global Attorney-Client Privilege Guide, published by Lex Mundi. The newly expanded guide provides information on what constitutes attorney-client privilege in over 70 countries around the world. The Thailand section of the guide contains in-depth information on the function and applications of attorney-client privilege in Thailand (or, as explained in the guide, an equivalent concept enshrined in Thai law), including coverage of the following topics: Privilege in corporations Common interest doctrine Litigation funding Crime-fraud exception Work product doctrine/litigation privilege Other privileges including mediation, accountant-client and settlement negotiation The interactive guide features expert contributions by Lex Mundi member firms from jurisdictions worldwide. Readers can browse the contributions, generate country-specific reports, and compare attorney-client privilege in multiple jurisdictions. For more information, please visit the Lex Mundi website.
Read More
October 19, 2021
On September 9, 2021, Laos announced a new pilot program to allow the mining and trading of cryptocurrency. Notification No. 1158, issued by the Prime Minister’s Office, provides for an electricity sale-purchase agreement with six companies involved in the pilot program. Under the notification, the six companies authorized by the prime minister to mine and trade cryptocurrency in Laos will pay a capped fee for energy they use in data processing or mining cryptocurrency. This effectively establishes a sandbox in which these six companies may mine and trade cryptocurrency—including on international cryptocurrency exchanges. The Ministry of Technology and Communications (MTC) is in charge of coordinating the program, together with the Ministry of Finance, the Bank of the Lao PDR, the Ministry of Planning and Investment, the Ministry of Energy and Mines, the Ministry of Public Security, and Électricité du Laos. The MTC is also charged with drafting the rules of the pilot program and setting the conditions on which the participating companies can mine, sell, and purchase cryptocurrency in Laos. One of the six selected companies will also act as a coordinator for the other companies and report to the government on any benefits of cryptocurrency observed during the pilot program. The next step is for the MTC to compile data analysis from each of the other government agencies and submit the conclusions to a meeting of the prime minister and the deputy prime ministers before the pilot program is implemented. The pilot program was originally scheduled to start in September, but there has not yet been any update on the implementation of the program, which nonetheless is expected to start in the near future.
Read More