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

March 16, 2026

Thailand Adds Digital Asset Operators to Institutional Investor Definition

Thailand’s Securities and Exchange Commission (SEC) has broadened the definition of institutional investors, expanded the types of qualifying investments, and updated financial qualification thresholds for various investor categories through a revised notification on the definitions of institutional investors, ultra-high net worth investors, and high net worth investors.

The amended framework, which came into force on March 1, 2026, adds digital asset business operators, investment planners, and investment consultants to the roster of entities recognized as institutional investors, and broadens the definition of investment to account for digital tokens.

Expanded Definition of Institutional Investors

Under the SEC’s revised notification, the category of institutional investors now expressly includes digital asset business operators licensed under the Royal Decree on Digital Asset Businesses B.E. 2561 (2018). This addition recognizes the growing role of digital asset platforms and service providers in Thailand’s investment ecosystem and aligns the regulatory treatment of digital markets with that of traditional markets.

The definition of institutional investors now also encompasses investment planners and investment consultants approved by the SEC. Previously, only SEC-approved investment analysts held this status; the expansion covers a broader scope of professionals who possess comparable expertise and experience in evaluating investment opportunities.

Broadened Investment Definition

The revised framework now defines investment to mean direct or indirect investment in a wider range of assets beyond deposits. Specifically, the definition covers:

  • Securities under the Securities and Exchange Act
  • Derivatives under the Derivatives Act
  • Investment tokens offered to the public
  • Government-issued digital tokens (G-tokens) as specified in a separate SEC notification

This expansion ensures that financial status assessments reflect the full spectrum of an investor’s holdings, including emerging digital assets.

Updated Financial Qualification Thresholds

The amended SEC notification also provides updated qualification thresholds for angel investors, ultra-high net worth investors, and high net worth investors. While the core criteria remain anchored in knowledge or experience and financial standing, the updated thresholds have been recalibrated. For instance, an individual angel investor (together with their spouse) must have net assets of at least THB 50 million, annual income of at least THB 4 million, or investment holdings of at least THB 10 million, or THB 20 million including deposits. Corporate angel investors must meet shareholder equity of at least THB 100 million, or investment holdings of at least THB 20 million, or THB 40 million including deposits. Similar adjustments apply to ultra-high net worth and high net worth investor categories.

Impact on Market Participants

These regulatory updates create significant opportunities across Thailand’s capital markets. The expanded definition of “investment,” encompassing securities, derivatives, and investment tokens, allows investors to leverage a broader portfolio when meeting qualification thresholds, giving them greater flexibility in demonstrating their financial standing. For digital asset business operators and other newly recognized institutional investors, this means enhanced access to a wider and more diverse range of investment sources and products. Securities issuers and investment service providers also stand to benefit, as the reforms expand the pool of sophisticated investors available to participate in Thai capital markets offerings.

RELATED INSIGHTS​ 

September 24, 2025
On September 12, 2025, the Bank of Thailand (BOT) officially released its AI Risk Management Guidelines for Financial Service Providers, building upon the draft guidelines issued in June 2025. The guidelines reflect a balanced approach, encouraging innovation while safeguarding financial stability and consumer protection. The guidelines are targeted at all financial service providers, including financial institutions and special financial institutions under the Financial Institution Business Act, as well as payment providers under the Payment Systems Act. The guidelines apply to both AI systems developed in-house and those developed by third parties that are adopted for use by financial service providers. AI Risk Management Guidelines The two main pillars in managing AI risk are (1) governance of AI system implementation and (2) AI system development and security controls, consisting of the following key elements: 1. Governance Stakeholder roles and responsibilities. Boards and senior management assume accountability for decisions and operations involving AI systems, and are responsible for defining roles and responsibilities for AI oversight. This includes establishing an AI system usage policy, designating personnel responsible for AI risk management, and building awareness of AI-related risk within the organization. Organizations are expected to foster internal capabilities to use AI securely and avoid overreliance that could compromise business continuity or customer service. AI system usage policy. Policies governing AI usage should align with organizational goals, regulatory obligations, and recognized responsible AI frameworks—such as the FEAT principles (fairness, ethics, accountability, and transparency). These policies should be reviewed regularly to respond to technological advancements and evolving risk profiles. Risk management throughout the AI lifecycle. Risk management should encompass the entire AI lifecycle, from establishing risk appetite to implementing continuous risk assessment and control measures tailored to specific use cases. Financial service providers should assess risks and impacts of AI usage on operations and customer services.
September 22, 2025
On September 15, 2025, Vietnam’s Ministry of Science and Technology announced that the country will issue an updated version of its National AI Strategy (first issued in 2021) and its first-ever AI Law by the end of this year. The ministry emphasized that the AI strategy is not just a legal framework, but a commitment to embracing AI to drive Vietnam into a new era. The AI adoption plan is set as a priority of the country, and marks a significant step in shaping Vietnam’s AI governance and innovation landscape. Highlights of the plan include the following: Strategic vision. Vietnam’s ambition is to leverage AI for economic growth, social development, and global competitiveness, under the guiding principle “AI for humans – safe, autonomous, cooperative, inclusive, and sustainable.” AI as national infrastructure. The updated strategy positions AI as core national infrastructure, comparable to electricity or the internet, aiming to provide every citizen with a “personal digital assistant.” Core principles for AI legislation. The AI Law will be built around the following six core principles: Risk-based regulation Transparency and accountability Human-centric development Domestic AI autonomy AI as a driver of sustainable growth Digital sovereignty, with data, infrastructure, and AI technology being three strategic pillars Ethics and openness. A National AI Ethics Code will accompany the upcoming law, aligned with international standards but tailored to the Vietnamese context. The government emphasizes open standards and open-source development. Market development and incentives. The government plans to expand domestic AI adoption, particularly in public services and key industries. The National Technology Innovation Fund (NATIF) will allocate at least 40% of its budget to AI projects, prioritizing SMEs through vouchers for locally developed AI solutions. Background on AI Law Development Regulations on AI are found in various Vietnamese laws and regulations, notably the recently adopted Law
September 12, 2025
On September 10, 2025, Vietnam’s National Credit Information Center (CIC) reported to the Vietnam Cybersecurity Emergency Response Team (VNCERT) a suspected significant cybersecurity incident involving unauthorized access to the CIC’s credit information database. A hacker group has claimed responsibility and allegedly posted over 160 million records for sale, including sensitive personal and financial data. Implications for Banks and Financial Institutions Companies that share customers’ or potential customers’ personal data with the CIC for credit scoring or other purposes—and continue to act as a data controller for such data—may be obligated under Vietnam’s Personal Data Protection Decree (PDPD) and related regulations to: Notify A05 (Department of Cybersecurity and High-Tech Crime Prevention) and the State Bank of Vietnam without delay. Inform affected individuals if their personal data is at risk. Recommended Actions Companies that could be impacted by this data breach should take the following actions: Conduct an internal review of CIC-related data in their systems, and identify whether and how the systems have been affected by this incident. Assess whether to notify regulators and customers/potential customers. Enhance cybersecurity controls, monitor for suspicious activity, and implement additional safeguards to prevent secondary breaches.
September 11, 2025
Thailand’s Securities and Exchange Commission (SEC) has amended its digital asset regulations to permit the offering, trading, and provision of services related to tokenized environmental commodities by licensed digital asset exchanges, brokers, and dealers. This regulatory development is aimed at facilitating Thailand’s green economy and net-zero goals while diversifying the products available in the regulated digital assets market. The environmental commodities currently being traded on certain market platforms and via over-the-counter channels include: Carbon credits: Tradable certificates representing a reduction of CO₂ emitted into the atmosphere. Renewable energy certificates (RECs): Tradable proof of electricity generated from renewable energy sources. Carbon allowances: Tradable permits to emit a capped amount of greenhouse gases. The tokenization of these instruments is essentially the process of converting them into digital tokens, making it possible to list them on blockchain exchanges for trading purposes. Background Tokenized carbon credits, RECs, and carbon allowances fall under the category of utility tokens for consumption purposes or tokens representing entitlement certificates—that is, group 1 utility tokens, which are not considered financial products. The offering, trading, and provision of secondary-market services of this type of token are exempted from licensing requirements for regulated digital asset businesses under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018). Under the previous regulatory framework, licensed digital asset business operators were not allowed to provide services involving such unregulated tokens, as it was deemed to be engaging in “other businesses,” which digital asset operators generally cannot engage in without prior SEC approval. Regulatory Amendment Under the amended digital asset regulations, licensed digital asset exchanges, brokers, and dealers may now apply for SEC approval to offer services related to these tokenized assets as “other businesses,” including listing them for trading on digital asset exchanges. Apart from requiring operators to comply with the general conditions