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​ 

September 8, 2022
While much attention has been paid to the data localization requirements for foreign enterprises under Vietnam’s 2018 Cybersecurity Law (“CSL”) and the recently issued Decree 53 guiding its implementation, the corresponding requirements for domestic enterprises are often overlooked, despite being potentially more troublesome. Under Decree 53, “domestic enterprises” are defined to mean enterprises established or registered for establishment under Vietnamese law and having their head offices in Vietnam (Article 2.11), so this designation includes not only Vietnamese companies, but foreign-invested enterprises as well. Background Before analyzing the stipulations in Articles 26 and 27 of Decree 53 further guiding the data localization/storage requirements, it is worth restating the very problematic Article 26.3 of the CSL, which reads: “Domestic and foreign enterprises providing services on telecommunication networks or the internet or value-added services in cyberspace in Vietnam with activities of collecting, exploiting, analyzing, and/or* processing personal information data, data on the relationships of service users, or data generated by service users in Vietnam must store such data in Vietnam for the period prescribed by the government. Foreign enterprises mentioned in this clause must open branches or representative offices in Vietnam.” [* Note: The Vietnamese text simply uses a comma here, without specifying whether this should be “and” or “or,” leading to additional problems in interpretation.] Because of this very broad and ambiguous wording, Article 26.3 of the CSL required further guidance from the government and remained unenforced for more than three years after the CSL took effect on January 1, 2019. Decree 53 guiding the implementation of the CSL was finally issued on August 15, 2022, and provides additional clarity on this matter. But does Decree 53 provide sufficient guidelines for implementation with regard to domestic enterprises? Scope of Application With regard to foreign enterprises, although there remains some ambiguity, Decree
Read More
September 6, 2022
The Thai National Cybersecurity Committee (NCSC), as required by the Cybersecurity Act, reported to the cabinet in mid-August on trends and developments regarding cyber incidents in Thailand. According to the NCSC, the top five most common cyber incidents involve website phishing, website defacement, data leakage, data security vulnerabilities, and ransomware. Reported incidents of cyberattacks have increased in recent years. The report stated that affected organizations primarily responded to cyber incidents and attacks by notifying the NCSC about the incident and the remedial actions planned or taken, and conducting internal training to increase awareness of cyber threats. Only two organizations chose to conduct IT risk assessments and vulnerability tests as preventive measures against future cyber threats. The NCSC report also showed that aside from telecom infrastructure, energy and utilities, and education operators falling victim to cyberattacks, healthcare, webhosting, and data center operators have also become “more common victims” of cyber incidents. The NCSC recommended that all organizations prepare for inevitable future cyber incidents. This includes ensuring that businesses and organizations comply with international standards, which includes measures that are recognized and incorporated in Thailand’s Personal Data Protection Act (PDPA) and Cybersecurity Act. Conducting internal training for employees as well as directors and officers is also recommended by the NCSC, as this can help prevent cyber incidents and ensure that businesses comply with the minimum required security standards issued by the Personal Data Protection Committee (PDPC) in their Notification Re: Security Measures of the Data Controller B.E. 2565 (2022), which came into effect on June 21, 2022. Industry-specific minimum required security standards (e.g., those regulated by the Bank of Thailand, Office of Insurance Commission, etc.) should also be considered in conjunction with those in this PDPC notification—particularly when sectoral requirements are more stringent than the PDPC’s recommended measures. PDPA statutory penalties
Read More
August 19, 2022
Vietnam’s Cybersecurity Law was promulgated on June 12, 2018, and came into effect on January 1, 2019, with a majority of its provisions enforceable from the effective date. However, certain provisions of the law, including the very concerning data localization requirements, still awaited further guidance from implementing regulations. After more than three years of being drafted and submitted back and forth to the government for consideration and approval, Decree No. 53/2022/ND-CP to implement certain articles of the Cybersecurity Law (Decree 53) was finally promulgated on August 15, 2022, with an effective date of October 1, 2022. Key provisions of Decree 53 include the following. 1. Data localization requirements (Articles 26 & 27) Decree 53 retains most of the data localization requirements of the last accessible version of the draft decree dated August 21, 2019 (Draft Decree), clearly extends the scope of requirements to cover both domestic and foreign enterprises, adds regulations on force majeure events, and amends the timeline to implement data localization requirements for business facilitation. (i) Data subject to data localization: Data (information in the form of symbols, writing, numbers, images, sounds, or similar forms) which must be stored in Vietnam (“regulated data”) includes: Data on personal information of service users in Vietnam: Data used to identify an individual. Data generated by service users in Vietnam: Data reflecting the process of participating in, operating and/or using cyberspace by service users and information about network equipment and services used in order to connect with cyberspace in the territory of Vietnam. This includes the account name for use of services, duration of use of services, credit card information, email address, IP addresses for the latest login and logout, and registered telephone number attached to the account or data. Data on the relationships of service users in Vietnam: Data reflecting
Read More
August 11, 2022
In July 2022, the Thai cabinet approved in principle a royal decree exempting some businesses and other entities from parts of the Personal Data Protection Act B.E. 2562 (PDPA). The draft royal decree proposes to exempt certain business operators and activities from the requirements of the following portions of the PDPA: Chapter II: Personal Data Protection – Consent, notification, cross-border transfer of the personal data requirements, etc. Chapter III: Rights of the Data Subject – Requirements and criteria on data subject rights. Chapter V: Complaints – Requirements on the submission of complaints to the Office of the Personal Data Protection Commission. Chapter VI: Civil Liability – Conditions in relation to the civil liability of a data controller or data processor. Chapter VII: Penalties – Administrative and criminal penalties. The proposed exemptions would apply to three main categories of business operators and activities: 1. Data controllers acting on government requests in adherence with specific laws for the following purposes: State security and public safety. Exempted operations include activities intended to safeguard state security, intelligence, and information relating to national security, as well as efforts to maintain fiscal and economic security and public security. Also exempt are prevention and suppression of certain criminal activities, such as money laundering, drug trafficking, transnational threats and terrorism, transnational crime, and human trafficking; activities to bolster anticorruption or cybersecurity efforts; and actions relating to public health, sanitation to prevent epidemics, and protection of public life, health, and property. Taxation. Exempted activities include those related to tax collection under laws that are the responsibility of the Revenue Department, Customs Department, or Excise Department. This also extends to any action relating to the enforcement of taxation fees or duties, and actions related to social security, the performance of obligations, or international cooperation. Risk mitigation, monitoring, and surveillance.
Read More