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BOT operates payment-system licensing under the Payment Systems Act B.E. 2560 (2017). BOT layered on the SIRPS supervisory tier (eff. 21 Feb 2026), designating PromptPay as the first SIRPS, and issued Thailand's first Virtual Bank licence (CLICX — Krungthai Bank/AIS/PTT OR consortium, licensed 14 May 2026 under BOT Notification FPG.6/2567), targeting a June 2026 launch.
The designated-services architecture flows from Section 16 of the PSA: the Minister of Finance, with BOT advice, designates credit/debit/ATM card services, electronic money, electronic fund transfer and money remittance as Designated Payment Services requiring a licence or registration. The structure is three-tier — e-payment service, e-money service and payment system operator — with direct licensing running roughly nine to fifteen months and foreign ownership generally capped at 49% without BOI approval. The non-bank PI/EMI route covers e-money, payment gateway/facilitation, e-money transfer, acquiring and payment-on-behalf.
The bank versus non-bank distinction is structural here. Commercial banks must apply for BOT approval to engage in e-Money business under Section 36 of the Financial Institutions Businesses Act B.E. 2551 (2008), in addition to payment-services law licensing — a separate s.36 FIBA approval pathway for bank-PSP e-money that runs parallel to the PSA designated-service route used by non-bank PIs and EMIs. The net effect is a market that is structurally accessible to non-bank entrants but foreign-ownership-constrained.
Outlook
The W1a baseline is established and confirmed. The licensing perimeter is stable; the live forward variable is how the three virtual-bank consortia, licensed in June 2025, operationalise within the bank-side approval framework as they commence operations during 2026.
Licensing, Authorisation & Market Access
The Bank of Thailand designated PromptPay as Thailand's first Systemically Important Retail Payment System, effective 21 February 2026, under the authority of the Payment Systems Act B.E. 2560 [wpm-2026-W1a-001]. The Systemically Important Retail Payment System framework is itself new to Thailand's regulatory architecture, and PromptPay's designation as the inaugural instrument under it formalises what has long been true in practice: PromptPay is the backbone of Thailand's retail instant-payments ecosystem, and its systemic designation brings it under a heightened supervisory regime spanning both the bank and non-bank participants that rely on the rail.
Separately, the Bank of Thailand granted Thailand's first Virtual Bank licence on 14 May 2026, under Notification FPG.6/2567, to CLICX, a consortium formed by Krungthai Bank, AIS and PTT Oil and Retail Business, with a targeted June 2026 launch [wpm-2026-W1a-002]. This is a market-access event of a different character to the SIRPS designation: rather than formalising oversight of existing infrastructure, it opens an entirely new licensed channel to market, combining a state-linked bank, a mobile-network operator and a retail-and-energy conglomerate in a single bank-chartered entity.
Both developments should be read against the bank-PSP versus non-bank-PI/EMI distinction that structures Thailand's payments market access. The SIRPS designation applies to PromptPay as shared infrastructure used by both bank and non-bank participants, while the virtual-bank licence is, by definition, a bank-charter route, meaning CLICX will operate under full banking-sector prudential requirements rather than the lighter payment-institution or e-money-institution regimes available to non-bank players. For non-bank PSPs and EMIs, the practical market-access lesson this cycle is that Thailand's most significant new licensing pathway remains a bank-charter route, even as the SIRPS framework extends systemic oversight to infrastructure non-bank participants also depend on.
Outlook
CLICX's targeted June 2026 launch is the immediate marker to watch: a successful, on-schedule launch would validate the consortium-licensing model and likely encourage further virtual-bank applications, while delay would signal implementation friction in Thailand's newest bank-charter pathway. Separately, watch for whether the Bank of Thailand extends the Systemically Important Retail Payment System designation beyond PromptPay to other retail payment infrastructure.
Sources and findings (5)
- T1https://www.bot.or.th/en/our-roles/payment-systems/payment-act-oversight.html
- T1https://www.bot.or.th/content/dam/bot/fipcs/documents/FPG/2561/EngPDF/25610195.pdf
- T1https://www.bot.or.th/content/dam/bot/fipcs/documents/FPG/2561/EngPDF/25610100.pdf
- T3https://paymentbrief.com/markets/thailand/
- T3https://kpmg.com/th/en/home/insights/2023/03/legal-news-update-issue-23.html