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

June 13, 2024

Thailand Accepting Applications for Programmable Payment Regulatory Sandbox

The Bank of Thailand (BOT) has announced its new Enhanced Regulatory Sandbox, which provides an opportunity to experiment with currently restricted financial innovations under a controlled environment. The BOT is employing a thematic approach to determine the scope of technology or innovations that may participate in the Enhanced Regulatory Sandbox and will only accept applications in each theme for a limited period.

The first announced theme is “programmable payments,” which refers to payment and payment-related transactions with automatic execution upon the fulfillment of a predefined condition utilizing distributed ledger technology (DLT) and a smart contract or comparable technology in which electronic data units are issued on an electronic system or network. The application period for programmable payment testing in the Enhanced Regulatory Sandbox runs from June 13 to September 13, 2024.

A summary of the programmable payment testing framework under the Enhanced Regulatory Sandbox is provided below.

Scope

The Enhanced Regulatory Sandbox accepts applications for the following programmable payment activities:

  • Automated payment and settlement upon fulfillment of predefined conditions.
  • Escrow services with predefined delivery or transactional conditions.
  • Asset tokenization through issuance of digital tokens representing rights in an asset, with payment for tokens or payment of benefits or returns to holders of digital tokens occurring automatically when conditions are met.
  • Other testing related to the items mentioned above.

Requirements and Conditions

Programmable payment testing activities in the Enhanced Regulatory Sandbox must comply with the following requirements and conditions:

  • Electronic data units issued for programmable payment testing must be pegged to the Thai baht (THB) on a one-for-one basis (i.e., 1 unit = THB 1), with the float account storing THB equal to the value of the electronic data units issued.
  • Participants must define the redemption rights of the unitholders and proceed with the THB redemption according to the participants’ service level agreements.
  • Participants must have risk management, IT support, business continuity, and IT disaster recovery plans.
  • Participants must comply with know your customer (KYC), know your merchant (KYM), and customer due diligence (CDD) standards under the relevant laws and regulations of Thailand’s Anti-Money Laundering Office.
  • Participants must have a client suitability assessment process to prevent vulnerable customers from using services under the testing.
  • Participants must have measures to prevent the utilization of electronic data units for purposes outside the scope of testing (e.g., using the units as means of payment outside the scope of the test, listing the units on digital asset platforms, or using the units for investment or speculation purposes).

For more information on the BOT’s regulatory sandbox program, regulations on programmable payments, or any other aspect of fintech in Thailand, please contact Athistha (Nop) Chitranukroh at [email protected], Pornpan Wichawut at [email protected], or Rujaporn Paritsantik at [email protected].

RELATED INSIGHTS​ 

February 27, 2026
The Bank of Thailand (BOT) has officially implemented a new regulatory framework supervising systemically important retail payment systems (SIRPS), effective February 21, 2026, with PromptPay being the first payment system designated as a SIRPS. Under this new set of regulations, the BOT may designate payment systems under the Payment Systems Act B.E. 2560 (2017) as SIRPSs based on quantitative and qualitative assessments. Once a system is designated as a SIRPS, the operator becomes subject to expanded supervisory obligations beyond the general requirements of the Payment Systems Act. Enhanced Supervisory Requirements SIRPS operators must comply with a heightened supervisory regime across three key areas, outlined below. 1. Governance SIRPS operators must maintain robust and transparent governance structures, including: Balanced board composition, with at least one-third of the board comprising independent directors who represent stakeholders in the system (such as payment service providers, consumers, and experts). Independent directors may serve for no more than two consecutive terms. Subcommittees to assist the board in overseeing compliance, policy implementation, and operational strategy. Clear separation between executives responsible for risk and information security and those overseeing day-to-day business operations. Risk Management and System SecuritySIRPS operators must implement comprehensive risk management frameworks, including: Clear service agreements between the SIRPS operator and its direct participants (payment service providers who connect directly to the SIRPS), defining roles and responsibilities among stakeholders. These agreements must include obligations for direct SIRPS participants to supervise any indirect participants they onboard to ensure compliance with service agreements and business rules. A business continuity plan covering both IT and non-IT aspects, with annual review. The SIRPS must target service availability comparable to international payment infrastructures, including the ability to recover operations within two hours of a disruption and to maintain scalable operational capacity. Tools and controls to monitor and manage material or
February 4, 2026
On November 18, 2025, Vietnam’s Ministry of Finance released for public consultation a draft decree on administrative sanctions in the field of crypto assets and crypto asset markets (the “Draft Decree”), intended to implement Resolution No. 05/2025/NQ-CP dated September 9, 2025, on the pilot crypto asset market in Vietnam (“Resolution 05”). While Resolution 05 sets out who may participate and under what conditions, the Draft Decree addresses a more practical question for market participants, i.e., what happens if those conditions are not met. In doing so, the Draft Decree offers important insight into how Vietnamese regulators intend to supervise, discipline, and ultimately shape the crypto market during the pilot phase. Regulatory Scope and Overall Sanctions Architecture The Draft Decree applies to both domestic and foreign organizations and individuals engaging in crypto-related activities in Vietnam’s market. Covered entities include: (i) crypto asset issuers; (ii) crypto asset service providers, including trading platforms and market operators; (iii) Vietnamese and foreign investors participating in the pilot market; and (iv) other organizations involved in the offering, issuance, or provision of crypto-related services in Vietnam. The breadth of this scope is deliberate. It appears to reflect a regulatory view that cross-border structures, offshore platforms, and indirect participation may not necessarily insulate market actors from compliance obligations once they operate within the pilot framework. For the crypto industry, this may mark a shift from regulatory ambiguity toward a more explicit articulation of jurisdictional reach. At first glance, the Draft Decree’s monetary penalties appear restrained. The maximum fine per administrative violation is capped at VND 200 million (approx. USD 7,700) for organizations and VND 100 million (approx. USD 3,800) for individuals. However, focusing solely on fine levels risks missing the point. The Draft Decree also places great regulatory weight on supplementary sanctions and corrective measures, including: (i)
January 23, 2026
On December 31, 2025, the State Bank of Vietnam (SBV) issued Circular No. 72/2025/TT-NHNN (Circular 72), establishing a streamlined foreign exchange framework for Vietnam’s International Financial Center (IFC). Circular 72, which took effect on the same day, implements core provisions of Decree No. 329/2025/ND-CP and marks a fundamental shift from ex ante licensing to ex post supervision for IFC member enterprises and foreign investors. These changes are designed to accelerate capital flows, reduce compliance costs, and position Vietnam as a competitive regional financial hub by granting IFC members substantially greater autonomy in currency transactions, borrowing, lending, and investment activities. Key provisions for IFC members to note are discussed below. Use of Foreign Currency and Payments within the IFC Vietnam generally requires the use of Vietnamese dong for transactions within the country, with limited exceptions. This can be burdensome for foreign investors, who may be unfamiliar with all the foreign exchange rules they must comply with. Under the new regulation, IFC member enterprises and foreign investors gain the ability to transact, list prices, and settle obligations in foreign currency when dealing with other IFC members or offshore counterparties, avoiding currency risk and conversion friction. With respect to individuals and organizations located within Vietnam who are not IFC members, the use of foreign currency must continue to comply with general restrictions on foreign exchange usage within Vietnam. Dual-Track Account System for IFC Members The new regulation introduces a two-tier account structure that differentiates transactions by purpose and counterparty. IFC member enterprises must use a designated foreign currency capital account at an IFC member bank for four specified activities: Borrowing from offshore individuals and organizations Lending to offshore entities and domestic borrowers Outbound investing from the IFC Investing elsewhere in Vietnam from the IFC All other foreign exchange transactions—including operational receipts, vendor
January 22, 2026
On January 20, 2026, Vietnam’s Ministry of Finance (MOF) issued Decision No. 96/QD-BTC to formally launch pilot administrative procedures for licensing crypto asset trading market services in Vietnam. The decision took immediate effect and implements the government’s pilot crypto asset market program under Resolution No. 05/2025/NQ-CP. Notably, competent authorities have now begun accepting license applications, marking the first time Vietnam has operationalized a licensing pathway for crypto trading market operators. Administrative Procedures and Applications The decision stipulates procedures for (i) granting, (ii) adjusting, and (iii) revoking licenses to provide services for organizing crypto asset trading markets. It provides detailed, step-by-step guidance for each procedure, including dossier composition, internal review stages, coordination mechanisms, and statutory timelines. These procedures apply specifically to entities seeking to organize and operate crypto asset trading markets within Vietnam’s pilot regulatory framework. The MOF is the authority responsible for reviewing and deciding on the above procedures, with the State Securities Commission acting as the receiving, coordinating, and procedural focal point. For licensing applications, the MOF will coordinate with multiple authorities, including the State Bank of Vietnam and the Ministry of Public Security, particularly in relation to anti-money laundering, cybersecurity, system safety, and risk control requirements. Applications may be submitted in person, by post, or electronically via the National Public Service Portal or the administrative procedure information system, in line with applicable regulations. Statutory processing timelines vary depending on the specific procedure and stage involved. For applications to obtain a license to organize a crypto asset trading market, the process is conducted in multiple phases: The MOF will issue an initial written response within 20 working days from receipt of a complete and valid initial dossier, following which, upon submission of the full set of required documents, the MOF will complete substantive review and issue the license