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

September 19, 2016

Regulation of Domestic Debit Card Transactions in Thailand

Asian Banking & Finance

Back in 2012, Thailand’s Electronic Transactions Commission issued regulations that mandated domestic processing of domestic debit card transactions with debit cards issued in Thailand. It granted a grace period of one year for service providers to meet the new requirements. This was a policy goal that had been discussed and pursued for some time, with policymakers highlighting the cost savings that would be yielded by domestic processing, rather than offshore processing.

New regulations were issued in March 2016, which were published in the Government Gazette  in April. The changes in those regulations in relation to processing domestic debit card transactions mainly provided greater specificity and rules around outsourcing and requests for temporary exemptions from parts of the regulations.

More recently, in July, amendments were made to the regulations, and these were published in the Government Gazette  in August. Among other things, the new regulations refer to a chip card standard for debit cards, and they state that the standard is to be issued and imposed by the Bank of Thailand through discussions with the Thai Bankers’ Association, the Association of International Banks in Thailand, and the Council of State-Owned Financial Institutions.

Financial institutions that issue debit cards will be required to issue cards meeting this chip card standard, and the cards must be issued to use debit card networks in Thailand, unless an issuer utilizes its own system for processing the transactions. The regulations also affect consumer protection, in that they require issuers to provide users with information and details about the costs of each type of debit card that is sufficient, clear, and correct, so that users can use the service properly for their own purposes.

Where an issuer issues a card that is accepted on more than one network, at least one of those networks must be a domestic debit card network. In working with multiple networks, regulations require an issuer to observe its agreements and take account of the principle of equality.

The regulations also impose new obligations on acquirers. Specifically, they are required to have equipment and systems to accept debit cards that meet the aforementioned chip card standard and that utilize local debit card networks. Importantly, acquirers are prohibited from restricting the rights of merchants to use any debit card networks. They are also required to provide merchants with clear and accurate information on fees and services. In addition, where multi-network cards are processed, an acquirer must not charge any additional fees other than those for the network that is actually used.

Aside from issuers and acquirers, the regulations also set out additional requirements for service providers that provide switching service, clearing service, and settlement service. These service providers are required to arrange their systems to support debit cards on all debit card networks or to connect their systems with those of other service providers that provide switching, clearing, and settlement. In relation to cards that can be accepted on multiple networks, a service provider must not interfere with a merchant’s right to select a debit card network.

The new requirements are to be enforced from February next year. Consistent with earlier regulations, if an issuer or acquirer is unable to meet the new requirements, it can apply to the Bank of Thailand for additional time to come into compliance—up to an additional 180 days.  Also, for those cards issued prior to enforcement of the new requirements, they can continue to be used, but the issuer will eventually need to replace them with cards meeting the chip card standard by December 31, 2019.

These regulations follow an earlier announcement by the Bank of Thailand in May of this year that commercial banks in Thailand would, from May 16 onward, issue cards in conformity with the “Thai Bank Chip Card Standard,” which was established by the Thai Bankers’ Association. Last year, China UnionPay issued press releases about entering into a Chip Card Standard License Agreement with the Thai Bankers’ Association, which contemplated the adoption of China UnionPay’s chip card standard as “the standard of Thailand’s banking industry.” China UnionPay became a member of EMVCo in 2013, thus joining Visa, MasterCard, American Express, JCB, and Discover in the consortium that manages EMV standards (the technical standard for such chips). However, much has also been written about the compatibility problems between China UnionPay’s version of EMV, and the versions of EMV used by other card schemes such as MasterCard and Visa.

In referring to the chip card standard, the new regulations do not make specific reference to the China UnionPay standard, or any particular standard, for that matter. Moreover, in referring to the development of the chip card standard, the regulations make reference not only to discussions with the Thai Bankers’ Association, but also to the Association of International Banks in Thailand and the Council of State-Owned Financial Institutions, which is quite broad consultation.

China UnionPay is a major shareholder in Thailand Payment Network Co., Ltd. (TPN), established in 2014, which is one of the small number of companies that have been granted licenses necessary for providing switching and clearing services for domestic debit card transactions in Thailand. One can now see some debit cards issued by Bangkok Bank—the other major shareholder in TPN—that bear TPN branding, together with China UnionPay branding. In essence, TPN will compete with National ITMX Co., Ltd., which is owned by ten major banks in Thailand and has been providing local debit card switching services for some years.

As it now stands, most banks in Thailand issue Visa and MasterCard debit cards, each with EMV chips. It remains to be seen whether TPN and China UnionPay will become popular.  Customers like Visa and MasterCard because of their ease of acceptance, particularly when traveling overseas. In contrast, TPN has positioned itself as a low-cost provider for local transactions, which it says should enable merchants to accept TPN branded-cards for small transactions. Ultimately, more competition in the processing of domestic debit card transactions is good for merchants. Indeed, this has already prompted several banks to reduce their fees for debit card transactions. Thailand’s electronic payments landscape continues to excite.

RELATED INSIGHTS​ 

August 25, 2025
To implement the recently issued Resolution on International Financial Centers in Vietnam (“IFC Resolution”), which is set to take effect on September 1, 2025 (see our previous article), the government of Vietnam is making every effort to formulate and issue guiding decrees—up to eight in total—before the effective date of the resolution. These decrees will establish key principles, define the rights and obligations of stakeholders, and outline permissible business activities within the IFCs, and serve as a foundation for the legal framework of the IFCs. Below are highlights of two draft decrees that have been released for public consultation. Draft Decree on IFC Establishment Ho Chi Minh City: The IFC in Ho Chi Minh City will focus on capital markets integrated with asset management services, fund management, insurance, financial products and financial derivatives; banking systems and money market products; fintech and financial innovation through sandbox mechanisms; specialized exchanges and new trading platforms; commodity markets, commodity and commodity derivatives exchanges linked to domestic and international physical commodity markets; and regional supply chain services, logistics hubs, maritime transport, and seaport infrastructure. Da Nang: The IFC in Da Nang will mainly develop green finance and commercial finance for SMEs and innovative enterprises, non-resident organizations and individuals (i.e., offshore financial services); cross-border trade activities linked to free trade zones, high-tech zones, new economic zones, and industrial zones; pilot control mechanisms for emerging models, such as digital assets, cryptocurrencies, and digital payments and transfers; new exchanges and trading platforms; investment funds, remittance funds, and small and medium fund management companies; startups in financial solutions for consumer services, tourism, e-commerce, logistics, and services within free trade zones; and related support, advisory, development, and legal services. Incentives: The People’s Committees of Ho Chi Minh City and Da Nang will need to decide on their list of
August 19, 2025
On August 6, 2025, Myanmar’s National Defence and Security Council (NDSC) issued Order No. 20/2025, announcing a change in the composition of the country’s Foreign Exchange Supervisory Committee (FESC). The prime minister has been appointed committee chair of the FESC, and five other individuals were appointed to the committee. The order took immediate effect. Originally established in April 2022, the FESC is responsible for approving foreign currency conversion, granting exemptions to foreign exchange restrictions, and permitting overseas transfers of foreign currency. The FESC supervises the flow of foreign currencies for domestic and foreign investment, manufacturing, exports and imports, and service businesses (including education- and health-related initiatives). The FESC is specifically responsible for considering and approving the use of foreign currency for the following: Importing machinery, vehicles, equipment, and raw materials essential for foreign investment and manufacturing projects; Importing fuel, medicine, cooking oil, fertilizer, insecticide, and construction materials not readily available on the domestic market; Covering Myanmar citizens’ needs abroad, such as medical treatment, education, or religious activities; Facilitating imports of general goods, loan repayments, interest payments to foreign lenders, service payments, and profit repatriation from investments; and Importing luxury products, including brand-name goods, jewelry, sports cars, and watches. The FESC is empowered to carry out further duties related to foreign exchange management as assigned by the NDSC Importers, exporters, investors, and business owners are encouraged to consult the most current FESC guidelines and approval lists before conducting transactions in Myanmar. For more details on these FESC composition developments, or on any aspect of financial regulations in Myanmar, please contact Tilleke & Gibbins at [email protected].
July 25, 2025
On June 17, 2025, the National Assembly of Vietnam adopted Law No. 76/2025/QH15 (Amended LOE) amending and supplementing the 2020 Law on Enterprises, which aims to reshape the legal framework to enhance transparency and alignment with international standards. The Amended LOE took effect from July 1, 2025. Below are key notes on the Amended LOE. Recognition of Beneficial Owners The beneficial owner (BO) concept was previously addressed under Vietnam’s anti-money laundering framework. However, the formal recognition of a BO in the Amended LOE marks a pivotal advancement in embedding ownership transparency into corporate governance, in line with the G7 Financial Action Task Force’s standards on anti-money laundering and counter-terrorism financing. Under the Amended LOE and Decree No. 168/2025/ND-CP of the government dated June 30, 2025, on enterprise registration (Decree 168), a BO is identified through either equity ownership or control rights. Equity ownership: Individuals holding 25% or more of a company’s charter capital or voting shares, either directly or indirectly, qualify as BOs. Indirect ownership is further defined as ownership of at least 25% of charter capital or voting shares through an intermediary organization. Control rights: Individuals with the authority to make or influence major decisions are considered BOs. The actual control over a company includes the power (i) to appoint or remove most or all members of the board of directors or the members’ council or the general director of a company; (ii) to amend the charter; or (iii) to decide other key matters specified in the company’s charter. Notably, individuals representing state ownership in state-owned enterprises are excluded from the scope of the BO concept. Companies are responsible for collecting, updating, and retaining information about BOs and cooperating with authorities when requested to identify BOs, among other obligations. Additionally, any companies registered before July 1, 2025, must
July 11, 2025
Vietnam’s recent embrace of “regulatory sandboxes” reflects a deliberate policy choice to balance the need for robust oversight with an equally pressing imperative to catalyze innovation. A sandbox is a controlled, time-bound framework in which businesses may pilot emerging technologies, products, or business models under relaxed or tailor-made regulatory requirements, thereby allowing regulators to observe risks in real time while innovators validate commercial viability without bearing the full weight of the traditional compliance regime. By issuing sandbox regulations, the government of Vietnam is signaling its commitment to accelerating digital transformation, attracting investment, and developing a knowledge-based economy, all while safeguarding financial stability, consumer protection, and national security. This strategy is embodied in a suite of instruments that together establish sector-specific sandboxes: Decree No. 94/2025/ND-CP on the Regulatory Sandbox in the Banking Sector (Fintech Sandbox Decree), effective July 1, 2025. Law on Digital Technology Industry (DTI Law), effective January 1, 2026, and Law on Science, Technology and Innovation (STI Law), effective October 1, 2025. Resolution No. 222/2025/QH15 on International Financial Centers (IFC Resolution), effective September 1, 2025. In addition, a draft resolution on the pilot implementation of the crypto-asset market (Draft Crypto Pilot Resolution) is expected to introduce a dedicated sandbox for crypto-asset service providers later this year, further underscoring Vietnam’s holistic, forward-looking approach to regulating emerging technologies. Below is a brief summary of all the regulatory sandboxes, who they are open for, and what businesses are attracted. Fintech Sandbox Decree Under the Fintech Sandbox Decree, besides credit institutions and foreign bank branches, fintech companies operating in Vietnam can apply for a Certificate of Sandbox Participation issued by the State Bank of Vietnam to operate any of the following services in Vietnam: Credit scoring: A solution applicable to information technology systems of credit institutions, branches of foreign banks, and fintech