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February 27, 2026

Thailand Introduces Systemically Important Payment System Framework, Starting with PromptPay

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The Bank of Thailand (BOT) has officially implemented a new regulatory framework supervising systemically important retail payment systems (SIRPS), effective February 21, 2026, with PromptPay being the first payment system designated as a SIRPS.

Under this new set of regulations, the BOT may designate payment systems under the Payment Systems Act B.E. 2560 (2017) as SIRPSs based on quantitative and qualitative assessments. Once a system is designated as a SIRPS, the operator becomes subject to expanded supervisory obligations beyond the general requirements of the Payment Systems Act.

Enhanced Supervisory Requirements

SIRPS operators must comply with a heightened supervisory regime across three key areas, outlined below.

1. Governance

SIRPS operators must maintain robust and transparent governance structures, including:

  • Balanced board composition, with at least one-third of the board comprising independent directors who represent stakeholders in the system (such as payment service providers, consumers, and experts). Independent directors may serve for no more than two consecutive terms.
  • Subcommittees to assist the board in overseeing compliance, policy implementation, and operational strategy.
  • Clear separation between executives responsible for risk and information security and those overseeing day-to-day business operations.
  1. Risk Management and System SecuritySIRPS operators must implement comprehensive risk management frameworks, including:
  • Clear service agreements between the SIRPS operator and its direct participants (payment service providers who connect directly to the SIRPS), defining roles and responsibilities among stakeholders. These agreements must include obligations for direct SIRPS participants to supervise any indirect participants they onboard to ensure compliance with service agreements and business rules.
  • A business continuity plan covering both IT and non-IT aspects, with annual review. The SIRPS must target service availability comparable to international payment infrastructures, including the ability to recover operations within two hours of a disruption and to maintain scalable operational capacity.
  • Tools and controls to monitor and manage material or systemic risks, including credit and settlement, liquidity, and operational risks.
  1. User Protection and CompetitionTo promote transparency and equitable market access, SIRPS operators must:
  • Establish fair, transparent, and nondiscriminatory criteria for system access and exit.
  • Develop and maintain business rules aligned with guidelines issued by the BOT’s new Payment Strategy Forum (PSF) working group. The BOT may require SIRPS operators to amend their business rules where appropriate.
  • Ensure fair fee structures covering fees charged by the SIRPS operator to system participants and fees charged by participants to their users (such as merchants). Fee structures must comply with BOT requirements and be approved by the PSF, and SIRPS operators must consider feedback from the SIRPS participants when setting their fees.

Key Takeaways

As PromptPay becomes a core element of Thailand’s retail payment ecosystem, its SIRPS designation heightens obligations for the PromptPay operator and all participating payment service providers. SIRPS participants—whether connecting directly or indirectly—must ensure that their operations and fee structures comply with PromptPay business rules aligned with BOT standards and requirements.

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