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 19, 2025

Thailand Drafts AI Risk Management Guidelines for Financial Service Providers

Subscribe to Updates

The Bank of Thailand (BOT) has released draft guidelines establishing principles for managing artificial intelligence (AI) risks in the financial sector. The draft guidelines provide a structured framework for the responsible adoption of AI technologies. Financial service providers will be able to use the guidelines as a reference to appropriately manage their risks in a manner that aligns with internationally recognized best practices.

The BOT is accepting public comments on the draft guidelines until June 30, 2025.

Scope and Application

The draft guidelines apply to 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. These guidelines supplement existing BOT risk management guidelines covering IT risk management, third-party risk management, data governance, and market conduct.

The guidelines define AI systems as systems that mimic human intelligence, including machine learning, deep learning, generative AI (such as large language models), and agentic AI. This definition specifically excludes rule-based automation systems like robotic process automation and condition matching.

Key Risk Management Principles

The guidelines lay out two main principles in managing AI risk.

  1. Governance: Financial service providers should define and establish clear roles and responsibilities for their personnel and AI system supervision structures to uphold FEAT (fairness, ethics, accountability, and transparency) principles as follows:
    • Stakeholder roles and responsibilities. Financial service providers should define roles and responsibilities for boards and executives on AI risk oversight. Responsibilities include establishing an AI system usage policy, designating personnel responsible for AI risk management, and building awareness of AI-related risk within the organization.
    • AI system usage policy. The AI system usage policy should be aligned with organizational objectives, regulatory requirements, and FEAT principles. 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. When AI systems are used in strategic functions or customer interactions (e.g., loan approval, account opening), human oversight must be integrated into decision-making processes. In customer interactions with AI systems, customers should be notified and have options to disable or bypass AI features.
  1. Development and security controls: Financial service providers should have risk controls covering the AI development and deployment lifecycle as follows:
    • Data risk. Financial service providers should have measures to assess and ensure the quality, accuracy, currency, volume, and diversity of data used in AI model training. They should also implement data leakage prevention measures.
    • Model development risk. Financial service providers should have (1) clear evaluation metrics for assessing model accuracy and reliability through ongoing testing and monitoring both before and after deployment and (2) measures to ensure the explainability of AI outcomes. For generative AI applications, there should be specific measures to reduce AI hallucination risks.
    • Cybersecurity risk. Financial service providers should have measures to prevent and detect emerging cyber threats targeting AI systems, based on established standards such as the OWASP Machine Learning Security Top 10.

For more details on any aspect of fintech, technology, and cybersecurity in Thailand, please contact Athistha Chitranukroh at [email protected], Nopparat Lalitkomon at [email protected], Pornpan Wichawut at [email protected], Napassorn Lertussavavivat at [email protected], or Rujaporn Paritsantik at [email protected].

Related Professionals

Industries

Fintech

Technology

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

July 21, 2026
Thailand’s Ministry of Digital Economy and Society (MDES) published a notification establishing an expedited court-ordered takedown mechanism for online content in cases of “urgent necessity.” The notification, which was issued on July 17, 2026, under the Computer Crime Act B.E. 2550 (2007), as amended, took effect the following day. It significantly expands the categories of content subject to rapid government-initiated removal. Content Categories Subject to Takedown The notification defines “urgent necessity” (section 20, paragraph 5, of the Computer Crime Act) as circumstances where any delay in suppressing computer data may impact national security, religion, the monarchy, good morals, social culture, or public order. In this regard, it establishes four broad categories of content: Computer Crime Act offenses. National security offenses. IP and other criminal offenses, where it is contrary to public order or good morals and a competent officer has requested its suppression. Content contrary to public order or good morals, a broad residual category encompassing 14 subcategories approved by the Computer Data Screening Committee. The fourth category is the most expansive. Its 14 subcategories include: Content defaming, mocking, satirizing, or devaluing the monarchy. Online gambling advertising or facilitation. Offering illegal firearms for sale. Offering baraku (hookah) products or e-cigarettes for sale. Offering cannabis inflorescences or processed cannabis products for sale. Advertising or soliciting prostitution. Content inciting violence, hatred, or social division. Unauthorized overseas employment advertising. Offering boiled kratom juice for sale. Online sale or advertising of alcoholic beverages. Content satirizing or degrading Buddhism. Money lending at interest rates exceeding legally prescribed limits. Advertising or disseminating information about surrogacy services. Forgery of documents, cards, or official documents. Enforcement Procedure In cases of urgent necessity, a competent official assigned by the MDES permanent secretary must file a petition with supporting evidence to the court with jurisdiction, requesting an order to
Read More
July 20, 2026
On July 16, 2026, Thailand’s Personal Data Protection Committee (PDPC) published a notification in the Government Gazette establishing detailed rules governing data subjects’ right of access under section 30 of the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The notification will take effect 60 days after publication—mid-September 2026—giving data controllers a limited window to bring their processes into compliance. Scope The notification covers requests to access or obtain copies of personal data and requests for disclosure of the source of data collected without consent. Data subjects may exercise their rights directly or through authorized representatives. Key Requirements Important requirements set by the notification include the following: Required request channels. Controllers must provide at least two request channels: direct submission at the business location and registered mail. Electronic channels are optional but, if offered, may also be used for fulfilling requests. Request contents. Requests must be in writing or in electronic form and include the data subject’s name, the preferred access method, details of the data requested, and the requester’s signature. Controllers may request additional identifying information as needed. Identity and authority verification. Controllers may require official identity documents for verification. Authorized representatives must provide authorization documents and identity documents for both the data subject and the representative. Alternative verification methods (e.g., digital authentication) are permitted if they do not unreasonably obstruct data subjects’ rights. Review and response timelines. Controllers must review requests within 15 days. If the request is incomplete, the controller must notify the requester and allow at least 15 days to correct deficiencies. If not corrected, the request may be treated as abandoned. Once verified, controllers must fulfill requests within 30 days, extendable by another 30 days for large-volume or complex requests with notice to the requester. Methods for providing access or copies. Controllers may fulfill
Read More
July 17, 2026
On July 11, 2026, media reports conveyed key messages from Bank of Thailand (BOT) Governor Vitai Ratanakorn’s announcement of a sweeping regulatory crackdown on grey capital activities. The measures target high-value cash transactions, gold trading, and stablecoin flows, with new requirements set to take effect in the fourth quarter of 2026. The initiative aims to prevent financial institutions from facilitating shadow economy activity, money laundering—particularly through stablecoins—and capital flight, through enhanced compliance obligations on commercial banks across multiple transaction channels. Expanded Cash Controls Close the Deposit–Withdrawal Circuit New fourth-quarter guidelines will require individuals depositing THB 5 million or more in cash to formally verify the source of their funds. This builds on restrictions introduced in April 2026, which required anyone withdrawing 5 million baht or more in cash to provide their bank with verified commercial justification for why electronic transfers or checks could not be used. That initial measure caused high-value physical cash withdrawals to drop by 35 percent nationwide. The upcoming deposit-side requirement closes the circuit on large cash movements. The BOT is also assessing tracking mechanisms for high-value banknote swaps, specifically targeting individuals seeking to exchange large volumes of THB 1,000 notes into smaller THB 100 or THB 500 denominations without clear business justification. Governor Vitai emphasized that these measures require continuous deployment of multiple parallel strategies rather than short-term fixes. Tightened Bullion Reporting Frameworks Restrict Money Laundering Channels The BOT has also tightened reporting frameworks for gold trading to close money laundering loopholes and shield the Thai baht from speculative bullion volatility. Regulators identified a recurring pattern in which buyers purchased large quantities of gold through digital applications in the morning and then made same-day physical withdrawals from retail gold shops in the afternoon. Gold shops are reminded of their duties to flag and report cash
Read More
July 16, 2026
Thailand’s Office of the Personal Data Protection Committee (PDPC) published a series of draft guidance documents for public consultation on July 7, 2026. Issued under the Personal Data Protection Act B.E. 2562 (2019) (PDPA), the drafts address a range of compliance issues and offer insight into the regulator’s current enforcement priorities. This article examines two of those drafts: one on lawful bases for processing personal data, and another on marketing and direct marketing. Together, they reflect the Office of the PDPC’s evolving expectations on lawful-basis selection, accountability, and the use of personal data in marketing. Organizations operating in Thailand should assess the practical implications now, before the guidance is finalized. Lawful Bases: A Structured Selection Process The draft guidance on lawful bases introduces a systematic five-step process for selecting an appropriate lawful basis for each processing activity. Organizations are expected to: Identify the processing activity involved. Assess the appropriate lawful basis. Evaluate whether the data is necessary for the processing. Conduct a legitimate interest assessment (LIA) where applicable. Ensure transparency through privacy notices. The guidance provides practical explanations and examples for each lawful basis under section 24 of the PDPA—including archiving, research, statistics, vital interests, contractual necessity, legal obligation, public task, legitimate interests, and consent—as well as the bases applicable to sensitive personal data under section 26. The aim is to promote more consistent and accurate lawful-basis selection across public- and private-sector organizations. A recurring theme throughout the guidance is that organizations should select the lawful basis that most accurately reflects the actual purpose and circumstances of the processing activity. The guidance cautions against treating consent as a default or catch-all basis where another lawful basis is more appropriate. For processing based on legitimate interests, organizations should conduct and document an LIA. Processing involving sensitive personal data may require
Read More