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August 2, 2021

Chambers & Partners Aviation Finance & Leasing Guide 2021 – Thailand Chapter

Lawyers from Tilleke & Gibbins’ Bangkok office have authored the Thailand chapter of the 2021 edition of Chambers & Partners Aviation Finance & Leasing Guide. John Frangos, partner and deputy director of Tilleke & Gibbins’ dispute resolution practice; Santhapat Periera, partner in the firm’s corporate and commercial department; and Nuanchun Somboonvinij, senior associate in the firm’s dispute resolution group, provided the Thailand update for the publication, which covers the most important legal developments affecting aircraft lessors, lessees, and financiers in 32 jurisdictions worldwide.

The guide provides in-depth details on the legal regimes affecting all aspects of aircraft sale and purchase, aircraft and engine leasing, and aircraft debt finance, including sale and lease agreement terms; taxation; lease registration and enforcement; lease assignment/novation; insurance and reinsurance; debt structuring; securities; liens; and many others that affect the day-to-day operations of leading players in the aviation industry.

Chambers and Partners’ Global Practice Guides provide in-house counsel with expert legal commentary focusing on practical legal issues affecting business, and enable readers to compare legislation and relevant procedures across a range of key jurisdictions. The full Chambers & Partners Aviation Finance & Leasing Guide—including the Thailand chapter—is available for free on the Chambers and Partners website, and the Thailand chapter be downloaded as a stand-alone PDF through the button below.

RELATED INSIGHTS​ 

February 20, 2026
Thailand’s Supreme Administrative Court has issued a decisive ruling annulling the Ministry of Labor’s notification that had granted an exemption for foreign pilots to fly domestic routes under wet‑lease arrangements. A wet lease is a leasing arrangement in which the aircraft is provided together with its foreign flight crew, including pilots, and related operational support, rather than the airline supplying its own pilots. The judgment, delivered on November 17, 2025, and published in the Government Gazette on January 30, 2026, follows a legal challenge brought by the Thai Pilots Association, which argued that the exemption unlawfully enabled foreign workers to assume a role traditionally reserved for Thai nationals. The notification in question, dated December 13, 2024, authorized foreign pilots who came as part of wet‑leased aircraft to fly domestic routes. The Thai Pilots Association disputed the legality of this rationale, asserting that the exemption was triggered by a private airline’s request rather than by any statutory necessity. The Ministry of Labor justified this measure by relying on aircraft‑specific approvals issued by the Ministry of Transport and by enabling the Department of Employment to issue corresponding work permits. Arguments Presented in the Case The Thai Pilots Association argued that the exemption undermined the interests of domestic pilots and conflicted with the policy intent of Thailand’s foreign‑worker regulatory framework. The lawsuit emphasized that the notification arose directly from a private airline company’s request to operate two A320 aircraft under a wet lease and that the measure had the practical effect of displacing Thai pilots who remained unemployed. Meanwhile, the Ministry of Labor defended the exemption as a temporary and necessary response to industry shortages and part of national efforts to support tourism and restore aviation capacity. Legal Framework Thai law establishes a general prohibition against foreign nationals piloting domestic aircraft. Section
January 22, 2026
On December 10, 2025, Vietnam’s National Assembly enacted Law No. 139/2025/QH15 amending the Law on Insurance Business. The amendment, effective from January 1, 2026, introduces various changes in an effort to lift restrictions and hurdles for insurance businesses. Key points that may impact the activities of stakeholders in Vietnam’s insurance market are highlighted below. Management Personnel Qualifications To broaden the talent pool while ensuring competency standards, the amended law opens up the positions of director or general director to more candidates. Previously, candidates were required to hold either (i) a university degree or higher in insurance or (ii) a university degree in another discipline and an insurance certificate issued by a qualified insurance training institution. Now, candidates holding a university degree or higher in economics, finance, banking, law, business administration, accounting, or auditing, with at least one insurance‑related module, are also accepted. These changes are expected to mitigate the ongoing challenges faced by insurers in recruiting suitably qualified candidates for key executive positions, while still maintaining appropriate professional standards. Fewer Registrations for Insurance Businesses As part of the legislature’s broader initiative to reduce administrative burdens across all business sectors, the amended Law on Insurance Business relaxes registration requirements for the insurance industry, notably: Insurance enterprises and foreign non‑life insurance branches are no longer required to register and obtain prior approval from the Ministry of Finance (MOF) for their methodologies and bases for calculating premiums for motor vehicle insurance products (excluding compulsory civil liability insurance for motor vehicle owners). Instead, insurance enterprises are now only required to notify the MOF before applying or amending these methodologies. While life insurers must continue to register with the MOF their principles for separating owners’ equity from insurance premium funds, non‑life insurance enterprises and foreign non‑life insurance branches are now only required to notify
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Thailand has expanded the circumstances under which state agencies may bypass competitive bidding procedures to address urgent security challenges. On November 28, 2025, Thailand’s Ministry of Finance published the Ministerial Regulation Determining Cases of Procurement by Specific Method (No. 6) B.E. 2568 in the Royal Gazette, introducing a new pathway for procuring supplies and services needed to address cyber and military threats that may affect the stability of government agencies or the nation. For technology vendors, cybersecurity firms, and defense contractors, this regulatory change creates immediate opportunities to engage directly with government buyers facing urgent security challenges. New Fast-Track Category for Security Threats The regulation amends Thailand’s Public Procurement and Supplies Management Act B.E. 2560 (2017) to add a new category of procurement that qualifies for the “specific method”—a noncompetitive, direct selection process. Previously, agencies could use this expedited method only in limited circumstances, such as emergencies, cases with proprietary technology requirements, or national security operations. The new provision explicitly covers procurement of supplies related to preventing or resolving cyber or military threats that could impact the stability of a state agency or the country. This addition recognizes the urgent nature of modern security challenges, where competitive bidding timelines may leave agencies vulnerable during critical threat windows. State agencies dealing with active cyberattacks, preparing defensive measures against anticipated threats, or responding to military security concerns can now move directly to negotiate with qualified vendors rather than conducting lengthy public tender processes. Vendor Considerations Vendors offering cybersecurity solutions now have a regulatory avenue to work directly with government clients when stability concerns are present. These solutions include threat detection systems, anti-ransomware tools, incident response services, firewalls, and security consulting. Similarly, defense contractors providing military equipment or specialized security supplies can pursue direct engagement channels where traditional procurement methods would create
August 8, 2025
Thailand’s Office of Insurance Commission (OIC) has opened a public hearing period on its amendments of notifications concerning the timeframe for an insurance company to submit its annual financial statements and financial and operating reports (called “XML reports”). The amended notifications also require insurance companies to submit some data sets from the quarterly capital maintenance reports and XML reports to the OIC in advance, before the full reports are submitted. Key changes in these amended notifications are summarized below. Financial Statements Audited annual financial statements will need to be submitted to the OIC within two months from the last day of each calendar year (i.e., by the end of February of the following year), instead of within four months as currently required. Capital Maintenance Reports While the deadline for submitting quarterly capital maintenance reports is still 45 days from the last day of the quarter, the OIC will now require life and non-life insurance companies to submit a set of data from the report in advance, within 21 days from the last day of each quarter. This data set includes the following information from the capital maintenance report: Form 1 – Calculation of Capital Adequacy Ratio (CAR) Form 2 – Calculation of Total Capital Available (TCA) Form 4 – Calculation of Capital for Insurance Risk (Table 4.1, 4.2, 4.4, and 4.5 for life insurance companies; Table 4.1 and 4.2 for non-life insurance companies) Financial and Operating Reports (XML Reports) Similar to the audited annual financial statement, the annual XML report will need to be submitted to the OIC within two months from the last day of each calendar year, instead of within the current four-month timeframe. For quarterly XML reports, which must still be submitted within 45 days from the last day of each quarter, there is a new