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​ 

September 30, 2026
On September 15, 2026, Vietnam’s Ministry of Finance (MOF) released for public consultation a draft circular on reporting and information disclosure in the pilot crypto asset market. The draft implements Resolution No. 05/2025/NQ-CP on the Pilot Implementation of the Crypto Asset Market in Vietnam and provides further detail on how licensed crypto asset service providers (“CASPs”) will be supervised once the market becomes operational. The draft indicates a data-intensive supervisory model, with licensed CASPs serving as the first line of market oversight. Public Disclosure Requirements The draft imposes detailed public disclosure requirements on CASPs, aimed primarily at market transparency. CASPs and crypto asset issuers must make disclosures in both Vietnamese and English, retain reported and disclosed information for at least 10 years, and keep information published on their websites accessible for at least five years. For CASPs, disclosure obligations arise both periodically and when specific events occur. A CASP must announce any crypto asset to be admitted to trading on its website at least seven days before trading begins and publish periodic financial statements. Certain extraordinary events and information requested by the MOF must generally be disclosed within 24 hours. CASPs must also provide ongoing market information. During trading hours, they must publish key trading data, including prices and volumes, daily highs and lows, average prices, the three best bid and offer levels, and transactions by foreign investors. By 9:00 a.m. each trading day, they must publish specified information on the previous day’s trading activity. Regulatory Reporting Requirements Separate from public disclosure, the draft requires CASPs to provide regulators with detailed information enabling ongoing supervision of their operations and the market. For market activity, CASPs must report decisions to admit or remove a crypto asset from trading within 24 hours, submit previous-day trading data to the State Securities Commission
Read More
September 24, 2026
Vietnam is implementing and developing a broad package of regulatory reforms that could reshape how IP, data, digital platforms, and product authenticity are regulated and enforced. Several of the key measures have been led by the Ministry of Public Security in its legislative and administrative capacity, as part of a broader government effort. The core reform package consists of four key legal instruments: proposed amendments to the Criminal Code, a proposed new Data Security Law, a draft Decree on Product Identification, Authentication and Traceability, and the newly enacted Decree No. 330/2026/ND-CP. These instruments include rules on criminal enforcement, data security, electronic identification, product identification and traceability, administrative violations, and cybersecurity sanctions. Combined, these measures will affect copyright enforcement, industrial property rights, trade secrets, AI training data, product provenance, online takedowns, valuation of counterfeit goods and electronic evidence. It is worth noting that, in addition to strengthening criminal penalties for IP crimes, Vietnam’s emerging regulatory framework increasingly treats infringement, data misuse, product authentication, and platform-enabled violations as interconnected regulatory and enforcement challenges. For rights holders and foreign investors, this could mean stronger tools against counterfeiting and online infringement, but also more compliance obligations around data, traceability, AI, platform controls and government-facing reporting. Expansion of Criminal IP Enforcement Proposed amendments to Article 225 of the Criminal Code would expand criminal copyright exposure beyond reproduction and distribution to cover large-scale commercial public performance and online communication of works, phonograms and video recordings. This is important because piracy is increasingly about streaming, unauthorized communication, and platform access models rather than physical copying. Aggravated copyright infringement could be subject to up to 10 years in prison for individuals and fines of up to VND 6 billion (about USD 228,300) for commercial legal entities. The amended Article 226 would expand criminal industrial property liability beyond
Read More
September 17, 2026
Thailand’s Office of the Consumer Protection Board (OCPB) has released for public comment a draft bill to amend the Consumer Protection Act B.E. 2522 (1979), the country’s foundational consumer protection legislation. The draft amendment aims to modernize the nearly five-decade-old framework to address the rapid growth of digital commerce, online advertising, influencer marketing, and new business models. The public consultation period is open until October 10, 2026. Expanded Definitions Covering Digital Commerce The draft significantly broadens several core definitions to capture modern commercial activities: “Consumer” is expanded to include natural persons and nonprofit juristic persons who purchase or receive services, including those solicited by businesses and end users who do not directly pay for the goods or services. “Business operator” now explicitly covers advertising business operators and hired advertising persons, such as influencers and content creators. “Advertising media” is expanded to include digital platforms, social media, and social media user accounts. “Label” now encompasses electronic labels—symbols, codes, or other electronic formats displaying product information. Influencer and Advertising Disclosure Requirements In addition to these expanded definitions, “hired advertising person for selling goods or services” is a new definition covering influencers, content creators, live streamers, affiliate marketers, and virtual online media operators who receive monetary compensation or other benefits for advertising goods or services. Hired advertising persons—including influencers and content creators—must disclose to consumers that content is advertising and reveal their relationship with the business owner. Disclosure is required when the business owner employs the advertiser, pays or provides other benefits for the advertisement, or provides free or discounted products or services. These requirements apply where consumers would not otherwise know that the business has a connection to the person presenting the content. Labeling Requirements for Importers The draft introduces a clearer labeling obligation for importers of label-controlled goods, who must
Read More
September 11, 2026
Thailand’s National Broadcasting and Telecommunications Commission (NBTC) has published a new five-year master plan that will bring significant regulatory changes to the broadcasting and digital media sectors, including formal licensing requirements for internet-based audiovisual services. The Master Plan for Broadcasting and Television, 3rd Edition (B.E. 2569–2573/2026–2030) was published in the Government Gazette on September 1, 2026, and will affect OTT platforms, internet-based audiovisual service providers, and traditional broadcasters. Licensing Reform The NBTC will develop new licensing frameworks ahead of existing digital television license expirations, which are slated to occur between 2028 and 2030. This creates both uncertainty and opportunity for incumbents and new market entrants. New licensing criteria will also be developed for audiovisual services delivered over the internet, meaning previously unregulated internet-based providers may face licensing, fee, and content obligations for the first time. The plan also calls for a new law to govern converged communications services. OTT Regulation and Content Oversight The plan explicitly acknowledges and aims to lessen the regulatory asymmetry between traditional broadcasters—which are subject to licensing, fees, and content regulation—and internet-based services that currently face fewer obligations. The NBTC intends to develop regulatory frameworks to bring internet-based audiovisual services, including OTT platforms, streaming services, and user-generated content platforms, under content, consumer protection, and licensing requirements. Consumer Protection and Digital Rights The NBTC will strengthen its oversight of broadcasting, television, and telecommunications operators to ensure compliance with consumer protection and personal data protection requirements. This includes updating relevant notifications and orders and more strictly enforcing rules against practices that unfairly exploit consumers. These measures may layer NBTC-specific requirements on top of Thailand’s existing Personal Data Protection Act obligations. Stricter enforcement against practices that exploit consumers is a priority, with particular scrutiny on advertising practices. The NBTC will modernize complaint resolution processes, meaning service providers should
Read More