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

Foreign business restrictions on telecommunications, treasury center businesses, and intragroup support services were eased when Thailand published the Ministerial Regulation Prescribing Service Businesses Not Requiring Permission for Foreign Business Operations (No. 5) B.E. 2569 (2026) in the Government Gazette on August 28, 2026. The ministerial regulation expands the categories of service businesses that foreign investors may operate without a foreign business license (FBL) under the Foreign Business Act B.E. 2542 (1999) (FBA). Of particular relevance to the telecommunications, fintech, and technology sectors, the ministerial regulation exempts: Type 1 telecommunications licensees, which do not have their own networks; Treasury center businesses operated in accordance with Thailand’s exchange control regulations; and Certain intragroup administrative, human resources, and information technology management services. Telecommunications Services Foreign-owned businesses providing telecommunications services under a type 1 telecommunications license may now operate without obtaining an FBL. This may streamline market entry for qualifying telecommunications and digital infrastructure businesses. The exemption applies only to the FBA licensing requirement. Operators must continue to comply with applicable requirements under the Telecommunications Business Act and the regulations of the National Broadcasting and Telecommunications Commission, and the change does not affect foreign ownership restrictions applicable to type 2 or type 3 telecommunications businesses. Treasury Center Businesses The ministerial regulation also exempts qualifying treasury center businesses from the FBL requirement. This may facilitate centralized treasury functions in Thailand, including liquidity management, foreign exchange management, and intragroup funding arrangements. Treasury center operations remain subject to applicable requirements of the Bank of Thailand and other competent authorities. Intragroup Administrative, HR, and IT Services Certain administrative, human resources, and information technology management services provided between affiliated entities are also exempt, provided the relevant entities satisfy prescribed ownership or management criteria. The exemption is available where the service provider and recipient are related through specified ownership

On August 21, 2026, Thailand’s Securities and Exchange Commission (SEC) published two consultation papers that would broaden regulated access to crypto assets while tightening custody standards. The first proposes a framework for establishing crypto exchange-traded funds (crypto ETFs) in Thailand. The second proposes enhanced qualification requirements for foreign digital asset custodians serving mutual funds and private funds that invest in digital assets. The proposals seek to expand regulated access to crypto assets while strengthening custody, governance, disclosure, and investor protection, and they affect fund managers, trustees, and licensed digital asset operators. Comments on both papers are due by September 20, 2026, and the SEC expects the resulting rules to take effect later in 2026. Elevating Foreign Custodian Standards Under current rules in effect since January 16, 2025, mutual funds and private funds investing in digital assets may use foreign custodians that meet qualifications similar to those set for domestic digital asset business operators. The SEC now proposes that foreign digital asset custodians satisfy two cumulative requirements: Compliance with the existing baseline qualifications: demonstrated expertise, robust cybersecurity measures, segregation of client assets, controls preventing unauthorized asset transfers, and sound financial standing. Supervision by a regulator that is either (1) an IOSCO Signatory A member under the Multilateral Memorandum of Understanding, the international arrangement through which securities regulators share information and cooperate on enforcement, or (2) a regulator in a jurisdiction that the Thai SEC designates as having adequate supervisory and investor protection standards. The SEC is initially considering 11 jurisdictions for the approved-country list: France, Germany, Hong Kong SAR, Ireland, Japan, Liechtenstein, Luxembourg, Malaysia, Singapore, South Korea, and the United States. The SEC may expand this list over time based on its assessment of other jurisdictions’ regulatory frameworks governing custodian licensing, asset segregation, secure custody practices, client rights in insolvency,

The Bank of Thailand (BOT) is seeking public feedback on a proposed overhaul of the regulatory framework for licensed money changers authorized by the finance minister, under the Exchange Control Act, to buy and sell foreign banknotes separately from commercial banks and specialized financial institutions. The BOT published the draft principles on August 19, 2026, for public consultation, with comments accepted through September 18, 2026. If adopted in its current form, the new framework would substantially raise licensing standards, require existing licensees to undergo a review and upgrade process, temporarily freeze new applications in 2027, and reduce application intake rounds from 2028 onward, with significant implications for both existing operators and prospective new entrants. The overhaul initiative stems from the BOT’s recognition of a need to prevent the use of licensed money changers as channels for financial crime. The stated objectives are to build public confidence, ensure the safety of financial service users, and align the supervisory framework with the current risk profile of the business and evolving market conditions. Upgraded Licensing Standards The BOT intends to significantly revise the licensing framework, including requirements relating to registered capital, branch management, operational standards, and customer transaction limits. Detailed criteria have not yet been released and are expected to be subject to further consultation. All existing licensees will be required to upgrade to meet the new standards and submit evidence of compliance for BOT review on a case-by-case basis. Existing licensees that are unable to satisfy the upgraded requirements may face regulatory consequences, subject to the final framework and BOT review process. Freeze and Reopening The BOT will temporarily stop accepting new license applications throughout 2027 to focus resources on inspecting and upgrading existing money changers. Any party wishing to obtain a new money changer license must submit its application by