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​ 

November 15, 2024
On November 9, 2024, the government of Vietnam promulgated Decree No. 147/2024/ND-CP on the management, provision, and use of internet services and online information (“Decree 147”). This decree supersedes the previous Decree No. 72/2013/ND-CP dated July 15, 2013, on the same topic (“Decree 72”) and its amending regulations, and will take effect on December 25, 2024. Spanning over 200 pages, with an appendix of 62 forms, Decree 147 addresses a wide range of key internet and online topics, including internet services; domain names; cross-border information provision; social network services; aggregated information websites; online game services; app store services; information content services on mobile telecom networks; responsibilities of telecom, internet, web hosting, data center, and telecom application service providers; and measures to handle illegal content. This decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields, and will potentially tighten the regulatory landscape for internet services and online information provision in Vietnam. Some highlights from the new Decree 147 compared to its predecessor are detailed below. Cross-Border Information Provision Offshore service providers, including offshore social network service providers and offshore app store service providers, who provide services on a cross-border basis and either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months must adhere to stricter requirements than other providers. Notable obligations of these regulated cross-border providers include: Notifying the Authority of Broadcasting and Electronic Information (ABEI) of their contact information. Monitoring and removing illegal content. Storing and managing user data as required. Authenticating social network user accounts using Vietnamese mobile number or ID number. Reporting to the ABEI annually as well as on an ad hoc Handling user complaints. Only cross-border providers who have notified the
November 13, 2024
Thailand’s Electronic Transactions Committee has publicized a new draft notification detailing additional duties for specific marketplace digital platform service operators under Section 18(2) of the Royal Decree on Operation of Digital Platform Service Businesses Subject to Prior Notification B.E. 2565 (2022). The draft notification, which is open for public comments until November 30, 2024, aims to provide enhanced protection for users of “specific marketplace platforms” (defined below). Some key points of the draft notification are detailed below. Scope The draft notification applies to “marketplace digital platform services,” which refers to digital platform services that serve as an intermediary for buying or exchanging goods and provide services to facilitate sale transactions, such as providing communication systems (e.g., chat features), shopping carts, delivery arrangements, and supplemental payment processing facilitation. “Specific marketplace platforms” refers to Section 18(2) of the Royal Decree on Digital Platform Services, which covers digital platform services that pose risks to financial and commercial security, the reliability and credibility of data messaging systems, or potential harm to the public, and that have a high level of potential impact based on the criteria for assessing the impact of digital platform service operations. Key Obligations Registration. The draft notification requires the marketplace operators mentioned above to be registered as legal entities in Thailand. Terms and conditions. The draft notification details additional obligations relating to marketplace operators’ terms and conditions: In addition to existing obligations prescribed in the Royal Decree and the relevant subordinate laws, the draft notification emphasizes that the terms and conditions must be in Thai, clear, accessible, and understandable, and may include graphical elements to aid explanation. The terms and conditions must prescribe conditions relating to the sale of products subject to specific standards, such as those restricted under the Food Act, the Drugs Act, and the Industrial Product
November 11, 2024
The Vietnamese government has demonstrated a strong commitment to building a digital government, digital economy, and digital society through its recently issued national strategy on digital infrastructure. Under Decision No. 1132/QD-TTg dated October 19, 2024, on “Digital Infrastructure Strategy to 2025 with Orientation to 2030,” the government will create supportive conditions for both domestic and international businesses to invest in digital infrastructure with cybersecurity as a priority. Recognized as vital to the economy, this digital infrastructure will consist of four main components: (i) telecommunications and internet infrastructure, (ii) data infrastructure, (iii) physical-digital infrastructure, and (iv) digital utility infrastructure, including digital technology as a service. Key goals for 2025 include universal fiber optic access for households, 100% 5G coverage across all provinces and cities, deployment of at least two new international undersea fiber optic cables, establishment of AI data centers, development of green-standard data centers, and platforms for IoT, AI, big data, blockchain, and cybersecurity. By 2030, goals include fiber access with speeds of at least 1 Gbps, 5G coverage for 99% of the population, readiness for 6G trials, six additional international undersea fiber optic cables, development of a hyperscale data center, and positioning Vietnam as a digital hub. To achieve these goals, the government has outlined some core tasks, creating significant opportunities for both foreign and domestic investors: Developing telecommunications and internet infrastructure for widespread fiber optic and 5G access, while preparing for emerging technologies like 6G, Open RAN, satellite, and IpV6. Telecommunication enterprises will jointly invest in and share the use of international fiber optic cable routes to ensure efficient capacity utilization and optimize investment capital. Attracting foreign and domestic investment to establish hyperscale data centers and cloud computing services that meet global standards. Creating physical-digital infrastructure by integrating technology across key sectors such as transportation, energy, healthcare,
November 8, 2024
On October 31, 2024, Thailand’s Office of the Personal Data Protection Committee (PDPC) opened a public consultation period on its draft notifications—one directed at data controllers and another at data processors—regarding exemptions from the requirement to create and maintain records of processing activities (ROPAs) under the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The draft notification for data controllers aims to amend and revoke certain aspects of the first ROPA exemption notification issued in June 2022 and outlines the criteria for data controllers to be exempted from the obligation to prepare and maintain such records. Although it is officially titled “Notification of the Personal Data Protection Committee on Exemption from Record-Keeping Requirements for Small Business Data Controllers,” this draft notification applies to all types of exempted data controllers (see list below), and not only small businesses. The draft notification for data processors is new and does not replace any prior notification. The criteria under both draft notifications exempt certain data controllers and data processors from the obligation to maintain ROPAs, but exempted data controllers are not free from the obligation to retain information on the rejection of data subjects’ requests to exercise certain rights under the PDPA. While these criteria remain consistent with the June 2022 ROPA exemption notification, there are a few key takeaways from the notifications, as detailed below. Types of Exempted Parties The draft notification on data controllers adds condominium and housing estate juristic persons, as well as individuals, to the list of parties eligible for an exemption, while removing internet cafes from the list. The new draft notification for data processors mirrors the corresponding list in the draft notification for data controllers. The complete list of parties eligible for ROPA exemptions under the draft notifications is as follows: SMEs according to the law on