The Bank of Thailand (BOT) is accepting public comments until May 2, 2025, on three draft notifications that will institute an enhanced supervision scheme and impose additional requirements for systemically important retail payment system (SIRPS) operators to align with international standards and encourage open infrastructure and competition. The SIRPS operators will be determined by the BOT from the “designated payment system operators” under the Payment Systems Act B.E. 2560 (2017).

SIRPS Designation

The BOT will announce a list of payment system operators designated as SIRPS operators and thus subject to enhanced supervision. The BOT will evaluate whether the payment system operator should be deemed a SIRPS operator when it meets the criteria in either the BOT’s quantitative or qualitative assessments, which cover the following:

• Quantitative assessment: The payment system’s transaction values, market share, cross-border payment network scale and value, and settlement with other financial market infrastructure.
• Qualitative assessment: The payment system’s function as a part of the country’s payment system infrastructure, the significance of the system users’ roles in the payment services, the substitutability of the payment system, and the impact level on the public and users in the event of an emergency or system suspension.

Supervision of SIRPS Business Operations

SIRPS operators will be subject to heightened supervision in three areas, in addition to various BOT regulations on designated payment system supervision, as follows:

• Governance: SIRPS operators will be required to have a balanced board composition with an independent director and directors with varied expertise, establish subcommittees to assist the board in supervising the operator’s compliance with its policy and strategy, and have senior executives overseeing risk and technology security separately from the executives overseeing business operations.
• Risk management and security: SIRPS operators will be required to have comprehensive risk management to ensure system stability and security. This includes having a clear service agreement and tools for monitoring and managing legal, credit, liquidity, and fraud risks. Emergency plans must cover IT and non-IT disruptions, with annual tests and the ability to recover within two hours of a disruption.
• User protection and competition: There must be transparent and fair criteria for accessing and exiting the system. In addition, SIRPS operators must establish business agreements (scheme rules) in accordance with guidelines to be established by a new working group called the Payment Strategy Forum (PSF). These guidelines will pertain to mechanisms for stakeholder feedback and other pertinent issues. SIRPS operators must also take any PSF and BOT comments on their scheme rules, and the BOT may require SIRPS operators to amend their rules where appropriate. The fee structures—both the fees that a SIRPS operator charges its system users and the fees that system users charge their payment service users (e.g., merchants)—must be fair, developed taking stakeholder and PSF feedback into account. SIRPS operators and system users will be required to notify the BOT of new or changed fee structures within the BOT-prescribed timeframe, and the BOT has discretion to request additional information, oppose the fee structure, or prescribe conditions for the operators and system users before implementation of the fee structure.

Compliance Timeline

When these notifications become effective, the BOT will announce the list of designated SIRPS operators. They will have 90 days to comply with this new set of compliance requirements.