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​ 

January 20, 2025
Thailand’s official draft Platform Economy Act (PEA) was released on January 15, 2025, for public comment until February 15, 2025. The draft PEA is positioned as a general or overarching law for digital intermediary services and digital platform service businesses. The official release of the draft came after the sharing of the set of principles that would form the basis for the official draft PEA in November 2024. The draft PEA incorporates those principles and adds more detailed provisions. Especially notable is that the draft PEA requires all intermediary service providers and online platform operators—both Thai and foreign—to appoint a point of contact to liaise with the Electronic Transactions Development Agency (ETDA) if they have any users in Thailand. However, the draft PEA does not mandate establishment of a local entity in Thailand. Types of Intermediary Services The draft PEA sets out a three-tiered classification system for different types of service providers, ordered from fewest obligations to most: Intermediary services. Intermediary services are further divided into three subcategories: mere conduit, caching, and hosting. Each type of intermediary service has different safe harbor provisions, which define their scope and limitations. Online platform services. Online platform services are defined as involving “the provision of intermediary services in the hosting category that involve facilitating the matching of various types of users to enable transactions or interactions, whether or not a fee is charged. Additionally, such services may include other provisions to facilitate these transactions or interactions.” Key obligations for online platform providers include: Informing users of their rights and duties under relevant laws Implementing a notice-and-action mechanism Disclosing advertising information Publishing T&Cs, including details such as service fees, algorithms, and complaint management mechanisms. Very large online platform services. Very large online platform services (VLOPs) have extra duties beyond regular online platform services,
January 16, 2025
On January 13, 2025, Thailand’s cabinet approved in principle the draft Entertainment Complex Act, as proposed by the Ministry of Finance. This landmark legislative proposal, which would allow casinos as part of larger “entertainment complexes,” will now proceed through further parliamentary review and approval. Key provisions of the draft act are described below. Corporate structure: Entertainment complexes must be operated by Thai-registered limited companies or public limited companies with a minimum paid-up capital of THB 10 billion. Directors of the licensed entity must be individuals and have the qualifications and none of the prohibited characteristics specified in the draft act. The draft act does not impose restrictions on foreign-majority ownership structures; however, it is worth monitoring whether any amendments addressing this matter are introduced during the legislative process. Operating conditions: Each entertainment complex must be located in an area designated under a royal decree. It must also include at least four types of entertainment businesses listed in the annex to the draft act (e.g., shopping mall, hotel, sports stadium, amusement park), along with a casino. The allocation of casino space must comply with regulations to be specified at a later date. Licensing conditions: Licenses will be valid for 30 years, renewable in increments of up to 10 years. The license issuance fee is THB 5 billion, the annual fee is THB 1 billion, and the renewal fee is THB 5 billion. The Entertainment Complex Policy Committee, chaired by the prime minister, will review and approve applications. Online gambling restrictions: Licensees are prohibited from offering gambling through internet-connected systems or electronic devices that allow access from outside the casino premises. Labor requirements: Thai and foreign employee ratios must adhere to prescribed regulations. Land privileges: Lease agreements for land use are limited to 50 years. Renewal is permitted for up to
January 13, 2025
The State Bank of Vietnam’s Circular No. 50/2024/TT-NHNN regulating safety and security for the provision of online services in the banking sector (“Circular 50”), issued on October 31, 2024, took effect on January 1, 2025, with delayed effectiveness for certain provisions on (i) network, communication, and security systems, online banking application software, and mobile banking application software (July 1, 2025); (ii) transaction confirmation for payment transactions conducted via the straight-through processing method (January 1, 2026); and (iii) authentication forms and reporting obligations (July 1, 2026). The cybersecurity situation in Vietnam is complicated, and the banking and finance sector has been one of the top targets of high-tech criminals. Circular 50 seeks to enhance user protection by expanding the technical requirements to more services in the banking sector as well as standardizing how transactions are authenticated. Expanded Scope of Services Covered Previous regulations on safety and security of online services in the banking sector only covered banking services and intermediary payment services. Circular 50 expands the scope to include other services of credit institutions and foreign bank branches such as credit information services, foreign exchange services, securities depository services, and services related to factoring and letters of credit, which now need to comply with technical requirements and standards for online services such as firewalls and DMZ network barriers. Risk-Based Approach to Authentication Circular 50 sets out standards for payment transactions and card transactions by: Classifying various online transactions based on the type of client, the purpose of the transfer, the value of the specific transaction, and the total value of certain transactions during the day; and Applying various types of authentication for the corresponding types of online transactions, e.g., using passwords or PINs for small-value online transactions, and using OTPs (through SMS, voice, or email), biometric matching, or e-signatures for
January 10, 2025
On January 8, 2025, Thailand’s Office of the Personal Data Protection Committee published two notifications in the Government Gazette—one for data controllers and the other for data processors—concerning exemptions for data controllers and data processors from the requirement to create and maintain records of processing activities (ROPAs) under the Personal Data Protection Act B.E. 2562 (2019). The notification for data processors took effect on January 9, 2025, the day after its publication. The notification for data controllers will take effect on April 8, 2025. The content of these notifications is identical to that in the draft versions of the notifications previously released for public consultation in October 2024. For more information on the ROPA exemptions for data controllers and data processors, or on any aspect of personal data protection in Thailand, please contact Nopparat Lalitkomon at [email protected] or Wilin Somya at [email protected].