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

August 14, 2026

Thailand Identifies Online Triggers of Insurance Licensing Requirements

Thailand’s Office of the Insurance Commission (OIC) has issued guidelines clarifying the boundaries between permissible and prohibited activities for unlicensed individuals—including influencers, bloggers, and content creators—when communicating about insurance products on social media. The Good Practice Guidelines for Persons Not Licensed as Insurance Agents or Brokers Regarding the Dissemination of Insurance Content Through Digital Media B.E. 2569 (2026) took effect on July 24, 2026.

Activities Requiring a License

The guidelines reserve the following activities for licensed agents and brokers:

  • Soliciting or facilitating insurance contracts.
  • Providing personalized advice on product suitability.
  • Recommending policy cancellation to purchase promoted products.
  • Creating links that facilitate contract formation.
  • Receiving performance-based compensation tied to policies or premiums generated.

Importantly, boilerplate disclaimers such as “this is not a recommendation to buy insurance” will not shield individuals from liability if the OIC views the content as personalized advice or solicitation.

Permitted Activities

Unlicensed persons may present general educational content about insurance—such as explaining terminology, sharing industry statistics, reporting news, or sharing personal experiences—provided the content does not target specific individuals to purchase from specific companies.

The guidelines also set out best practices for communication, including presenting information in a fair and balanced manner that covers both benefits and limitations, encouraging consumers to read policy terms and consult licensed professionals, verifying information from credible sources before dissemination, and exercising special care when the audience may include vulnerable groups such as persons aged 60 and older.

Prohibited Practices

Prohibited practices include fear-based marketing, creating artificial urgency, omitting material limitations, making exaggerated claims, falsely claiming professional credentials, using fake engagement mechanisms, and sharing false or misleading content.

The guidelines also reinforce the prohibitions under section 83 of the Life Insurance Act B.E. 2535 and section 78 of the Non-Life Insurance Act B.E. 2535 against soliciting insurance contracts with foreign operators not licensed in Thailand—including recommending such companies, sharing sign-up links, or providing application guidance. Failure to comply with these guidelines may lead to imprisonment for up to six months, a fine of up to THB 50,000, or both.

Sponsored Advertising Requirements

Sponsored content must be governed by a written agreement with insurance companies or brokers, covering scope, content approval processes, and compensation (which must not be performance-based). All content requires preapproval from insurance companies and/or brokers, and any personal comments or post approval edits must be approved by insurance companies and/or brokers.

Content disseminators must disclose both the sponsorship relationship and their license status, and must verify that the commissioning party is properly licensed with the OIC. The guidelines also set out format-specific disclosure requirements:

  • Still images and animations must display disclosure text rather than requiring viewers to click to read more.
  • Short-form videos must show on-screen text throughout or at the start.
  • Long-form videos must include disclosures at the beginning and in the video description.
  • Carousel posts must include disclosures on at least the first image, and preferably on every image.
  • Audio and podcasts require spoken announcements.
  • Livestreams require continuous on-screen disclosures with periodic verbal announcements.

Unlicensed persons must additionally state: “This advertiser is not licensed as an insurance agent or broker. This content is for informational purposes only. Please consult a licensed professional before making a decision.”

Ongoing Monitoring Obligations

Content disseminators must continuously monitor published content and comment sections, promptly correct inaccuracies, remove fraudulent links, direct viewer inquiries to licensed professionals or the OIC hotline (1186), and maintain records of corrective actions.

Key Implications for Stakeholders

The guidelines provide clarity for all stakeholders involved in online insurance content:

  • Insurance companies and licensed intermediaries engaging influencers or content creators will need to implement comprehensive written agreements, preapproval workflows, and compensation structures not linked to performance.
  • Influencers, bloggers, and content creators now have clearer boundaries defining permissible activity, along with disclosure obligations and monitoring duties.
  • Foreign insurance companies without a Thai license will find it harder to use local influencers as a marketing channel and will face greater challenges providing insurance products and services through online channels.

Next Steps

Affected stakeholders should review their existing practices, contracts, and compliance procedures against these clearer regulatory boundaries. Offshore insurance companies and brokers should revisit their internal guidelines when conducting activities related to customers in Thailand.

RELATED INSIGHTS​ 

August 4, 2026
Thailand’s Personal Data Protection Act B.E. 2562 (2019) (PDPA) could soon see some important changes, as a draft bill to amend the PDPA has been introduced in the House of Representatives. The draft amendment is currently in the public consultation phase, with comments accepted from July 16 to August 15, 2026. If enacted in its current form, the amendment would make three key changes: expanding the government exemption to cover anticorruption operations, introducing a statutory definition of “government agency,” and restructuring the lawful bases for personal data processing to align with international standards. Background The PDPA has encountered several enforcement challenges since its implementation, including three core problems identified by the bill’s sponsors: (1) the current exemptions for government agencies do not cover anticorruption and misconduct-prevention operations; (2) the PDPA lacks a clear statutory definition of “government agency,” causing legal uncertainty as to which entities are covered; and (3) the existing framework for lawful bases of data processing does not align with international standards—particularly the multiple-lawful-bases system in the EU’s General Data Protection Regulation (GDPR)—making compliance inflexible for both government and private sector entities. Expanded Government Exemption The current PDPA exempts government agencies performing duties related to national security (including fiscal security), public safety, anti-money laundering, forensic science, and cybersecurity. The proposed amendment adds “prevention and suppression of corruption and misconduct” to this list of exempted functions. This would allow anticorruption bodies—most notably the National Anti-Corruption Commission (NACC), which is identified as a directly affected party—to collect, use, and disclose personal data without being subject to PDPA requirements when carrying out their duties. New Statutory Definition of “Government Agency” Notably, while the current PDPA use the term “government agency” in several provisions, the term is not comprehensively defined, creating potential uncertainty as to its scope. The draft bill therefore
August 3, 2026
On July 23, 2026, the Bank of Thailand (BOT) released for public comment its draft Notification on Digital Channel Security, which would significantly expand the scope and stringency of Thailand’s existing mobile banking security framework. If finalized in its current form, the draft notification would extend mandatory security requirements to credit card providers and credit providers, cover internet banking in addition to mobile applications, phase out SMS one-time passwords (OTPs) for transaction authentication, and introduce biometric verification requirements for high-value transactions. The public comment period is open through August 24, 2026. Background The BOT’s existing Mobile Banking Security Notification, issued in 2024, sets minimum security standards for financial institutions, specialized financial institutions (SFIs), and e-money providers, significantly reducing “money-draining app” fraud. However, fraudsters have since shifted to nonbank providers and internet banking channels, prompting the BOT to propose broader security requirements. Expanded Scope of Regulated Entities and Channels The existing Mobile Banking Security Notification covers only financial institutions, SFIs, and e-money providers offering mobile banking services. The draft expands coverage in two key areas: entities and channels. On the entity side, it adds credit card providers and credit providers that offer fund transfers to third parties at other financial service providers or that provide cash withdrawal services to individual retail customers. On the channel side, it broadens coverage to include internet banking in addition to mobile banking. Strengthened Customer Authentication The draft introduces enhanced authentication requirements in three areas: Service enrollment and device changes. Providers must implement rigorous identity verification, notify customers of enrollment results through out-of-band communication channels, and adopt risk-mitigation measures such as cooling-off periods and temporary transaction limits. Transaction-level authentication. Providers must use two-factor authentication for fund transfers, cardless ATM withdrawals, and transaction limit increases. Secure authentication factors. Key requirements include the following: “What-you-know” factors must
July 28, 2026
Data protection officers (DPOs) have become a fixture of Thailand’s privacy compliance landscape since the Personal Data Protection Act B.E. 2562 (2019) (PDPA) took full effect and the Office of the Personal Data Protection Committee (PDPC) began requiring certain organizations to appoint them. On July 7, 2026, the Office of the PDPC presented draft guidance on DPOs as part of a public consultation on a series of draft personal data protection manuals and recommendations. The draft offers the clearest indication yet of how the regulator expects the DPO role to work in practice, addressing recurring implementation issues under the PDPA—including when an organization must appoint a DPO, how the DPO should operate independently, how to manage conflicts of interest, and how data subjects and regulators should be able to contact the DPO. Because it remains in draft, organizations have an opportunity to weigh the practical implications now before the guidance is finalized. When a DPO Must Be Appointed The draft guidance clarifies the triggers for mandatory DPO appointment, including: Regular and systematic monitoring of personal data or systems on a large scale, such as tracking, analyzing, or predicting behavior, attitudes, or individual characteristics. Core activities involving large-scale processing of sensitive personal data, such as health data, biometric data, or criminal records. Certain foreign-organization representative arrangements. Public-sector coverage under relevant notifications identifying government entities that must appoint a DPO. Processing involving 100,000 or more data subjects may be considered large-scale. The guidance also contemplates voluntary DPO appointment for organizations that wish to raise their privacy governance standards, and such organizations should still comply with the standards applicable to DPOs under the law. Independence and Reporting Lines The draft guidance identifies lack of DPO independence as a core risk because an ineffective or constrained DPO may be unable to raise deficiencies
July 27, 2026
Vietnam’s new E-Commerce Law, which took effect on 1 July 2026 along with its implementing Decree No. 248/2026/ND-CP (Decree 248), marks a significant development in the country’s approach to online intellectual property (IP) enforcement, reflecting a clear shift from a reactive model of intermediary liability to one that expects platforms to play a more active role in preventing infringement. From notice-and-takedown to platform responsibility The most significant change introduced by the E-Commerce Law is the transformation of the legal role of e-commerce platforms. The existing safe harbor provisions under the IP Law and the copyright notice-and-takedown regime established by Decree 17/2023/ND-CP (Decree 17) largely required intermediaries to act only after receiving notice of infringement. Once infringing content had been removed, the platform’s legal obligation was generally considered fulfilled. The new legislation adopts a fundamentally different approach. Article 17 of the E-Commerce Law requires intermediary platforms to screen information relating to goods and services before publication in order to prevent listings involving counterfeit or IP-infringing goods, and goods of unknown origin. Rather than relying exclusively on complaints from rights holders, platforms are now expected to implement preventive measures before infringing listings become publicly available. Decree 248 further requires platforms to update keyword filters based on recommendations issued by competent authorities. These filtering mechanisms are intended to prevent prohibited listings from appearing on the platform and represent a further move away from a purely complaint-driven enforcement model. The legislation also introduces Vietnam’s first statutory stay-down obligation. Under the E-Commerce Law and Decree 248, major digital platforms must maintain automated systems capable of reviewing, warning against, and removing unlawful listings while also implementing measures to prevent repeat violations, defined under Decree 248 as conduct that has previously been identified and handled by the platform, but continues to recur. This obligation addresses one