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

March 12, 2024

Thailand Unveils Virtual Bank Licensing Framework

Thailand’s Ministry of Finance has issued the Notification re: Criteria, Methods and Conditions for Applying for and Issuing Licenses to Operate Virtual Bank Business, which was published in the Government Gazette on March 4, 2024. This notification opens an opportunity for qualified experts in technology, digital services, and diverse data usage fields to apply for virtual bank licenses to provide financial services through new digital channels. The main goal is to serve the financial needs of target groups that may not have received sufficient or tailored financial services from the traditional banking system.

Licensing Timeline

  • Application submission period: 6 months (March 20–September 19, 2024).
  • Announcement of successful applicants: Mid-2025 (approx. 9 months–1 year from the end of the submission period)
  • After the announcement, successful licensees must demonstrate their readiness to commence virtual bank operations within 1 year (extendable for up to 1 additional year) via the following:
    • Having paid-up registered capital of THB 5 billion and plans to increase the paid-up registered capital to at least THB 10 billion after the initial business period;
    • Establishment or adjustment of a financial business group;
    • Procurement of human resources, IT systems, and relevant risk management tools.

Number of Licenses to be Issued

No written or specified limit, subject to the discretion of the Bank of Thailand (BOT).

Key Qualifications

Applicants must have the following:

  • Experience and resources to support virtual banking operations according to the business model and plan.
  • Expertise and experience in conducting business that utilizes technology and provides services through digital channels.
  • Experience demonstrating the ability to obtain, access, manage, and utilize data, including development of systems or data connections to facilitate user activities, allowing them to use their data to conduct transactions with other providers.

Criteria

In assessing applicants’ qualifications for a virtual bank license, the BOT will consider the following criteria:

  • Whether the applicant possesses the key qualifications;
  • Whether the applicant can conduct business operations following the BOT’s expected green line (i.e., financial services meet customers’ needs, good customer experience, fair competition) and avoiding its red line (i.e., unsustainable business operations, inappropriate competition, stakeholder conflict of interest);
  • Whether the applicant has the potential and ability to operate a virtual banking business using flexible, sustainable, secure, and trusted technology; knowledge, skills, and appropriate governance; ability in risk management, financial business, and maintenance of a strong culture of risk mitigation; and status and financial support from shareholders.

For more information on Thailand’s regulations pertaining to virtual banks or any other financial technology, please contact Athistha (Nop) Chitranukroh at [email protected], Pornpan Wichawut at [email protected], or Rada Lamsam at [email protected].

RELATED INSIGHTS​ 

January 8, 2026
Thailand has enacted comprehensive sexual harassment legislation that significantly expands criminal penalties and creates new compliance obligations for online platform operators. The Act Amending the Penal Code (No. 30) B.E. 2568 (2025), enacted on December 29, 2025, and taking effect the following day, introduces a comprehensive definition of sexual harassment, establishes new criminal offenses with graduated penalties, and imposes content removal obligations on social media platforms and computer system service providers. The amendment, which establishes a comprehensive framework for addressing sexual harassment in both physical and digital environments, significantly expands legal exposure for online service operators. It also grants courts authority to order takedowns of violating data accessible to the public. Definition of Sexual Harassment The law introduces “sexual harassment” as a distinct statutory concept covering physical conduct, verbal conduct, sounds, gestures, expressions, postures, communications, surveillance, stalking, and acts committed through computer systems or electronic devices. Conduct qualifies as sexual harassment when it is sexual in nature and likely to cause the victim distress, annoyance, embarrassment, humiliation, fear, or a sense of sexual insecurity. Criminal Offenses and Penalties The amended Penal Code establishes graduated penalties based on the severity and context of the harassment—including enhanced penalties for public or online conduct. For instance: Basic sexual harassment is punishable by imprisonment for up to one year, a fine of up to THB 20,000, or both. Continuous or repeated harassment that prevents normal life escalates penalties to imprisonment for up to two years, a fine of up to THB 40,000, or both. Critically for online operators, harassment committed in public places, in the presence of the public, or through computer systems accessible to the general public triggers imprisonment for up to three years, a fine of up to THB 60,000, or both. Acts of harassment committed by supervisors, employers, or others
January 6, 2026
On December 30, 2025, Thailand’s Electronic Transactions Development Agency (ETDA) notified digital marketplace operators of a consolidated list of “high‑risk products” that are subject to strict monitoring on digital platforms. The list was jointly prepared by the Thai Industrial Standards Institute (TISI) and the Food and Drug Administration (FDA) to guide platform compliance in the initial phase of implementation of the Electronic Transaction Committee’s Notification on Other Measures for Marketplace for Goods with Specific Characteristics under Section 18(2) of the 2022 Royal Decree on Digital Platform Businesses Requiring Notification B.E.2568 (2025). The notice is addressed to operators of digital platform services that function as product marketplaces with specific characteristics laid out in the notification. The ETDA states that the TISI and the FDA are closely monitoring the high‑risk product categories on digital platforms, and the published list serves as the baseline reference for platform screening during the initial phase of the notification’s implementation. High‑Risk Product List The list aggregates categories of products that are illegal to sell online or are otherwise tightly regulated under Thai law, with an emphasis on health-related products, controlled substances, medical devices, and a wide range of industrial products that require certification or compliance with specified Thai Industrial Standards, as detailed below. Prohibited and tightly controlled health products. This includes all categories of modern medicines subject to control other than general household remedies; all categories of controlled herbal products except for over-the-counter herbal products; narcotics; psychotropic substances; and medical devices requiring use in medical facilities or a physician’s prescription. Selected industrial products requiring heightened controls. The list highlights dozens of TISI-regulated items commonly sold online. Examples include pacifiers, rice cookers, electrical wire, food wrap film, crayons, washing machines and dryers, air conditioners, electric cookers and air fryers, water heaters, microwave ovens, LED luminaires, hair dryers
January 6, 2026
Among the eight implementing decrees issued on December 18, 2025, to provide the legal framework for Vietnam’s new International Financial Centers (IFC), Decree No. 323/2025/ND‑CP serves the core function of officially establishing the IFC as a unified entity in two locations—Ho Chi Minh City and Da Nang—and setting out a plan for its development and governance. The key contents of the decree are summarized below. Location and Focus of IFCs The Vietnam International Financial Center in Ho Chi Minh City (VIFC‑HCMC) and the Vietnam International Financial Center in Da Nang (VIFC‑DN) are designed to attract capital, fintech, and international market participants under a dedicated regulatory framework. The IFCs will host functional zones for financial trading, banking, securities and commodities exchanges, offices, dispute resolution (via specialized court and international arbitration center), and related activities as set by the executive authority of each IFC. VIFC-HCMC, with a total area of 898 hectares in central Ho Chi Minh City, is oriented to develop a comprehensive and diverse financial ecosystem, providing traditional and specialized financial services, and leveraging synergies between financial services such as capital mobilization, investment, payment services, issuance and trading of financial products, asset management, fintech, and green financial services. VIFC-DN, with a total area of 300 hectares, is oriented to develop as a modern IFC, closely integrated with the innovation ecosystem, digital technology, and sustainable finance. VIFC-DN will establish a controlled testing platform for new financial models, taking the lead in the deployment and scaling of digital-asset products, digital payments, and specialized trading platforms and exchanges, while promoting supply chain finance, third-party services, and non-bank financial intermediaries to complement and support the traditional financial market, developing specialized, flexible, and innovative financial products. Near‑Term Priorities and Review Timeline In 2026, the government will prioritize completing the essential infrastructure and ensuring adequate
January 5, 2026
On December 31, 2025, the government of Vietnam promulgated Decree No. 356/2025/ND-CP detailing and guiding the implementation of the new Personal Data Protection Law (PDPL) that was issued in June 2025. The new decree, like the PDPL, entered into force on January 1, 2026, with the previous Decree No. 13/2023/ND-CP on personal data protection ceasing effect on the same day. Some key points of the new decree include the following: Comprehensive lists of basic and sensitive personal data are provided, which will require companies to review again their existing documents and data type classification to ensure compliance. New timelines are established for responding to specific data subject requests. These timelines are more reasonable and longer than the previous 72-hour requirements. Additional consent guidelines are provided, prohibiting default consent or ambiguous instructions that confuse data subjects about giving or withholding consent. Mandatory content for data transfer agreements/clauses in particular cases is provided. This covers, among other things, (i) the legal basis for the transfer of personal data; (ii) responsibilities for personal data protection during the transfer and processing of personal data; (iii) responsibilities for ensuring the exercise of the rights of personal data subjects; and (iv) responsibilities for coordination and compliance of the parties in cases where violations of personal data protection regulations are detected. The qualifications and responsibilities of data protection officers (DPOs) and data protection departments include, among others, having been trained and fostered in legal knowledge and professional skills regarding personal data protection. There are no specific provisions governing the qualifications or requirements for organizations that provide data protection training or education. New mandatory templates and requirements are provided in relation to data processing impact assessment and data transfer impact assessment, and for cases in which companies need to re-submit assessments to the regulator. Stricter requirements are