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March 17, 2026

Thailand Issues New Group-Wide Insurance Risk Supervision Rules

Thailand’s Office of Insurance Commission (OIC) has introduced comprehensive group-wide supervision requirements for insurers operating within corporate groups. Published on February 26, 2026, in two separate notifications in the Government Gazette, the new rules establish parallel frameworks for life and non-life insurance companies. Both notifications take effect on July 1, 2026, and impose significant new requirements on insurance business groups. Affected insurers should begin reviewing their group structures, governance frameworks, and risk management systems now to ensure timely compliance.

The notifications aim to ensure that group-level operations are orderly, stable, and reliable, and prevent the accumulation of systemic risk that could undermine public confidence in the insurance sector. Both notifications share a substantially parallel structure and require insurers to assess and manage the financial position, risk exposure, reliability, and corporate governance of their entire insurance business group on a comprehensive and ongoing basis.

The regulations introduce definitions for several key terms. An “insurance business group” encompasses the insurer together with its ultimate parent company, parent companies, subsidiaries, and related companies. The “head of the insurance business group” is the entity responsible for overseeing group-wide supervision, operations, and governance. An “ultimate parent company” is one that exercises control without itself being controlled by another entity.

Key Requirements

The notifications establish the following core obligations for insurers:

  • Group structure and shareholding reporting: Insurers must report the organizational chart and shareholding structure of their insurance business group—covering the ultimate parent company, parent companies, subsidiaries, and related entities—to the OIC registrar by June of each year, and whenever material changes occur. The regulations prescribe specific thresholds for determining when shareholding proportions constitute control.
  • Corporate governance standards: Board members, executives, and authorized persons of the ultimate parent company or parent company must not be disqualified (e.g., bankrupt individuals, persons convicted of property-related fraud, or persons removed from directorship for misconduct), and their qualifications must be reported to the OIC registrar annually by June of each year and whenever any disqualifying characteristic arises. Additionally, the head of the insurance business group must appoint a dedicated unit or committee for group-level supervision, with authority and responsibilities proportionate to the group’s size, nature, and complexity.
  • Intragroup transactions: All transactions between group entities must be conducted on an arm’s-length basis, with pricing and conditions comparable to those between independent third parties. Insurers must report intragroup transactions to the OIC registrar, ensuring transparency in areas including underwriting, investments, shared services, transfer pricing, mergers, assignments, and other related-party dealings. Where a group entity is located outside Thailand, its impact on the group’s capital, reserves, and risk exposure must not adversely affect the group.
  • Reinsurance: Insurers with intragroup reinsurance arrangements must report those transactions, disclose information relating to intragroup reinsurance in accordance with applicable accounting standards, and manage the risk arising from intragroup reinsurance arrangements.
  • Enterprise risk management and ORSA: Insurers must ensure that insurance business groups implement an enterprise risk management (ERM) framework and conducts an own risk and solvency assessment (ORSA). Group ERM/ORSA reports must be submitted to the OIC registrar. The ERM framework must, at a minimum, include identification of key risk indicators and an acceptable risk appetite; monitoring, evaluation, and control processes with clear reporting lines; internal control and audit mechanisms consistent with the group’s operations; a business continuity management (BCM) plan; and determination of risk limits appropriate to the group’s scale and complexity.
  • Risk management policy and internal audit: The head of the group must establish board-approved, group-wide risk management policies aligned with the group’s business plan and strategy. Internal audit procedures must be established and their effectiveness reported to the OIC registrar regularly. Adequate staff with relevant knowledge, skills, and experience must be allocated at every operational level.
  • Reporting and disclosure: Insurers must file periodic reports with the OIC registrar, including shareholding structure and corporate governance reports, by June of each year. Financial statements of the ultimate parent company or parent company, for fiscal years ending from 2025 onward, must also be submitted to the OIC registrar within six months from the end of each calendar year.

While both notifications take effect on July 1, 2026, transitional provisions grant grace periods for certain requirements. For the year 2026, only reports relating to the following aspects must to be filed with the OIC registrar by July 31, 2026:

  • Intragroup transactions
  • Intragroup reinsurance arrangements
  • Group structure and shareholding structure of insurance business groups
  • Disqualification of board members, executives, and authorized persons of ultimate parent companies or parent companies
  • Structure, authority, and responsibilities of business units or committees supervising insurance business groups
  • Financial statements of ultimate parent companies or parent companies for fiscal years ending in 2025

Recommended Actions

Affected life and non-life insurers operating within corporate groups in Thailand should consider taking the following steps ahead of the July 1, 2026, effective date:

  • Map the insurance business group. Confirm the full group structure, including the ultimate parent company, parent companies, subsidiaries, and related entities, and prepare the required shareholding and organizational charts for filing by July 31, 2026.
  • Review corporate governance. Verify that all board members, executives, and authorized persons of the ultimate parent company and any other parent companies satisfy the qualification requirements and are free from disqualifying characteristics.
  • Assess intragroup transactions. Audit all intragroup transactions for arm’s length compliance and prepare the necessary disclosures for the OIC registrar.
  • Develop or enhance ERM and ORSA frameworks. Ensure that a group-level ERM framework and ORSA process are in place, including key risk indicators, risk appetite, risk limits, BCM plans, and internal audit mechanisms.
  • Establish a dedicated group supervision function. Appoint or formalize the unit or committee responsible for group-level oversight, with clearly defined authority and responsibilities.

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