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

September 27, 2017

Thailand: New Payment Systems Act

Subscribe to Updates

Thailand is in the process of reforming laws related to payment systems and services, as well as consolidating several overlapping laws that regulate electronic money businesses, with the National Legislative Assembly approving the new Payment Systems Act in August 2017. The new draft of the bill is awaiting royal assent and is expected to be published in the Government Gazette within this year, becoming effective 180 days after its publication.

Under the current system, a business that wishes to provide a certain type of e-money service is required to apply for two licenses, in accordance with two laws: (1) the Royal Decree Regulating Electronic Payment Services B.E. 2551 (2008); and (2) the Notification of the Ministry of Finance: Business that Requires a Permit according to Section 5 of the Notification of the Revolution Council No. 58 (Electronic Money Card Businesses), dated October 4, 2004. Once the new Payment Systems Act comes into force, it will simplify procedures for business operators by repealing these laws.

Under the new law, different types of electronic payment systems and businesses will be reclassified into three new classifications: (1) important e-payment systems; (2) supervised e-payment systems; and (3) supervised e-payment services. Criteria for supervised e-payment systems and e-payment services will be determined in ensuing subordinate legislation by the Minister of Finance, based on recommendations from the Bank of Thailand (BOT). 

Current business operators will be required to reapply for registrations or licenses if their businesses fall within the category of a supervised e-payment system or a supervised e-payment service. Certain new businesses that fall under either category may be required to apply for registration, rather than applying for a license (e.g., new businesses utilizing new financial technology that are in the process of being tested, or providing services to a limited number of customers which may not significantly impact public interests).

The BOT will be the key regulator of the new Payment Systems Act and will supervise the operation of payment systems and payment services, with the Electronic Transactions Commission supervising information technology security standards. The law grants the BOT the authority to announce rules and regulations relating to: 

  • minimum financial status and performance;
  • business operation standards;
  • good governance;
  • risk management;
  • outsourcing;
  • collection and disclosure of a customer’s personal data;
  • customer protection; and
  • security systems. 

Business operators and their management will be required to submit financial statements, operations reports, accounts, and data relating to the business operations, in any form, with the BOT having the authority to examine business operations, assets, and debts of business operators. In the case of noncompliance, the BOT may order business operators to rectify any associated problems, or it may impose a temporary suspension or cessation order within a specified period. Noncompliant business operators may be subject to administrative fines of up to THB 3 million, and criminal penalties that include imprisonment of up to 10 years and/or fines of up to THB 10 million.

Reformation of the payment systems law in Thailand will result in more streamlined license application and compliance obligations for business operators, as well as the establishment of an effective regulatory framework to support the development of e-payment services and businesses under the government’s “Thailand 4.0” policy.

Related Professionals

Industries

Technology

Practices

Banking and Finance

Corporate/M&A

Location

RELATED INSIGHTS​ 

January 13, 2026
On January 9, 2026, Thailand’s Securities and Exchange Commission (SEC) filed a criminal complaint with the Economic Crime Suppression Division (ECD) against five individuals for unauthorized operation of a digital-asset dealer business under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018). This precedent-setting case signals that the regulator is willing to pursue crypto enforcement against natural persons even in the absence of a licensed platform entity. Background and Implications The case follows the SEC’s October 2025 public warning about the use of iris-scanning technology in exchange for certain digital tokens. In its warning, the SEC cautioned that exchanging or trading these specific tokens with unlicensed service providers exposes users to heightened fraud, scam, and money laundering risks. Unlike prior regulatory enforcement matters, which involved platform-level administrative fines for operational or compliance failures, this case targets misconduct by individuals who may not be professional traders but openly advertised their willingness to buy these tokens from the public, opened individual over-the-counter (OTC) trade channels for these tokens, and facilitated off-exchange transactions in a manner resembling ordinary commercial dealing. This enforcement action establishes a clear precedent that natural persons engaging in public-facing digital-asset dealing may face criminal liability under Thai law, even without operating through a corporate or licensed platform structure. Outlook The alleged offenders may not settle this crime by payment of fines. Following the SEC’s referral, the ECD will undertake further investigation, after which prosecutors may review the case and proceed to court. The SEC has stated that it will cooperate fully with enforcement agencies throughout the criminal enforcement process.
Read More
January 9, 2026
Vietnam has taken a decisive step into the global artificial intelligence regulatory landscape with the promulgation of the Law on Artificial Intelligence No. 134/2025/QH15 (AI Law), adopted on December 10, 2025, and effective from March 1, 2026. As one of the earliest comprehensive, standalone AI statutes in Southeast Asia, the AI Law signals Vietnam’s ambition to position itself as both an innovation-friendly and governance-conscious AI market. In doing so, the legislature has also streamlined Vietnam’s AI regulatory architecture. The AI Law repeals most AI-related provisions previously embedded in the Law on Digital Technology Industry No. 71/2025/QH15, consolidating AI governance under a single, unified legal framework. This structural move underscores an intent to provide greater regulatory clarity and coherence for businesses operating across the AI value chain. Against this backdrop, the key question for AI developers, providers, deployers, and governance teams is how the new risk-based framework will shape compliance expectations, operational decisions, and governance design in practice. This article examines the new AI Law through that practical lens, focusing on what it means for AI businesses operating in or into Vietnam. Scope of Application The AI Law applies broadly to Vietnamese organizations and individuals, as well as foreign entities that participate in AI-related activities within Vietnam. The law expressly excludes AI activities conducted solely for national defense, security, and cryptography purposes. A defining feature of the AI Law is that it regulates by role, not by industry. It distinguishes between: Developers, who design, build, train, test, or fine-tune AI models and have direct control over the technical methods, training data, or model parameters; Providers, who place AI systems on the market or put them into use under their own names; Deployers, who use AI systems under their control in professional, commercial, or service-provision activities; Users, who interact with AI
Read More
January 9, 2026
Thailand continues to advance its legal and regulatory framework for the technology sector, with several key laws undergoing review and proposed amendments. These developments reflect Thailand’s broader efforts to ensure that its regulatory landscape keeps pace with rapid technological change and aligns more closely with international standards and best practices. The following are key legal developments and proposed legislative reforms in 2026 that are expected to impact businesses operating in the technology sector and the broader Thai business landscape. Data Privacy and Cybersecurity Personal Data Protection Act B.E. 2562 (2019) Following the full enforcement of Thailand’s Personal Data Protection Act (PDPA) in June 2022, businesses and practitioners have identified practical implementation challenges and interpretative issues. These challenges were reflected in an effectiveness assessment conducted by the Personal Data Protection Committee (PDPC) in late 2024. The PDPC published a set of principles for public consultation to identify issues and directions for potential amendments to the PDPA. Key issues: Emerging issues include clarifying the definitions of “data controller,” “data processor,” and “criminal record”; revisiting the scope of sensitive personal data to better reflect Thailand’s context; proposing amendments to the hierarchy of legal bases to avoid misconceptions of consent as the default legal basis; and clarifying the required level of expressiveness for explicit consent, as well as rules for collecting personal data from other sources. Current status: The first round of public consultation has concluded. Next steps: The proposed amendments are proceeding to a revised draft following the consultation outcomes. Cybersecurity Act B.E. 2562 (2019) Thailand is moving forward with proposed amendments to enhance the effectiveness of its national cybersecurity framework, as evolving digital technologies bring new risks such as misinformation, system intrusions, and attacks on critical infrastructure, making cybersecurity a national priority. Key issues: The amendments aim to clarify and strengthen
Read More
January 8, 2026
Thailand’s Digital Government Development Agency (DGA) has proposed new standards that would require government agencies to select cloud services exclusively from a preapproved shortlist of providers. The draft Digital Government Standards re: Cloud Service Provider Standards aims to strengthen procurement confidence and reduce risks associated with selecting cloud service providers that do not meet the required standards. A public hearing period on these standards concluded on December 27, 2025. The DGA will now review submitted comments and consider revising the standards accordingly. Shortlisted Cloud Service Provider Tiers The draft standards establish three tiers of cloud service providers based on their assessed service capability levels, core qualifications, and certifications. The DGA sets qualification requirements for each tier, and it is at the discretion of each agency to select the tier of cloud service provider that best suits its operational needs, as follows: Tier 1 cloud service providers are suitable for providing services involving disclosable official data. Tier 2 cloud service providers are suitable for handling official data and protected data, such as personal data, which requires a high-security public cloud (e.g., virtual private cloud). Tier 3 cloud service providers are suitable for providing services to agencies with specific regulatory and security requirements that handle highly protected data, such as the national security system. These providers must offer sovereign or hybrid cloud as stipulated by the Ministry of Digital Economy and Society. All tiers of cloud service providers must be legal entities incorporated under Thai law and can be authorized distributors of offshore cloud service providers. However, each tier will be subject to different requirements, including infrastructure obligations. Government agencies are encouraged to select a cloud service provider appropriate for their intended use. For example, if a government agency intends to procure cloud services for operating applications that process personal data,
Read More