In brief
The Office of Insurance Commission (OIC) has issued the Notification Re: Group-Wide Supervision B.E. 2569 (2026), which formally introduces the Full Consolidation approach for overseeing risk management at the group-wide level for insurance companies.
The newly promulgated Full Consolidation approach further extends OIC supervision to cover the entire insurance group — starting from the ultimate holding company and including their subsidiaries entities within the organizational structure.
The core objective of this framework is to strengthen regulatory oversight throughout every level of insurance group structures, so as to allow the OIC to assess the financial status, associated risk within the same group and governance of the insurance business group. The OIC has outlined a range of new requirements and key responsibilities within the supervisory framework, as detailed below.
In more detail
What is the extent of the Full Consolidation approach?
The OIC uses Full Consolidation for regulatory oversight, supervising the whole insurance group from the parent company of the insurance company down to the subsidiaries.
Which entity will serve as the primary coordinator under the Full Consolidation approach?
The Thai insurance company will act as the principal coordinator and main point of contact with the OIC, ensuring effective compliance and communication throughout the group.
The Thai insurance company is required to designate an entity responsible for supervising the operations of the group as its head of the insurance business group. This head of the insurance business group is tasked with overseeing the group's comprehensive risk management and appointing a governing body overseeing the group.
Which entities fall under Full Consolidation supervision?
The ultimate holding company of the insurance business in Thailand, along with its subsidiary entities within the corporate group.
Overview of the key requirements
| Key requirements |
Details |
| Related transactions |
Investment Transactions The maximum limit for an insurance company's holding of assets or entering into a contact with its parent company, subsidiary, affiliate, or other related entities is either 25% of Total Capital Available or 10% of Assets Under Management, whichever is lower, in accordance with the Investment Regulation. All such transactions must be reported to the OIC within three days. Other Transactions (other investment transactions) Other related transactions conducted between an insurance company and/or other entities must follow the arm's length principle and must also be reported to the OIC. For example, financial transactions (e.g., guarantees or dividend payments) or other business transactions/contracts (e.g., shared services or other transactions related to cost and pricing). |
| Top management qualifications | The ultimate holding company and parent company of the insurance company must ensure that their directors, CEO, legal representatives and advisors have the required qualifications, including no record of bankruptcy or property-related imprisonment. |
| Dividend payments by the Thai insurance company |
Life insurance company: Dividend payments must be approved by the OIC. Non-life insurance company: Dividend payments must be reported to the OIC within 10 working days. |
| Intra-group reinsurance | The insurance company must disclose and report any relevant information to the OIC, with comprehensive risk management in place. |
| Governance | The insurance company must establish clear governance structures. It must report its organizational structure, details of directors of the parent company, subsidiaries and affiliates, as well as the structure, authority and responsibilities of any governing body overseeing the group of the insurance business, to the OIC on a yearly basis and when there is a significant change. |
| Group shareholding structure |
The insurance company must disclose the structure of: (i) The ultimate holding company or parent company, and head of the insurance business group. (ii) Other entities under the insurance business group. (iii) The directors of the ultimate holding company, parent company, subsidiaries and affiliates of the insurance business group. The insurance company must report the names of the shareholders of each entity within the insurance business group on an annual basis by June. In addition, if there is any significant change, it must be reported to the OIC within 15 days of such change. A significant change is defined as a person's shareholding reaching or dropping below 20%, or varying by at least 5% while remaining at or above 20% of total issued shares. |
| Internal Control | An independent reviewer (internal or external) must assess the group of insurance company's internal control system at least once a year and report the outcomes to the OIC. |
| Risk Management | The head of the group must review and assess the group's risk management system. The report must be submitted to the OIC at least annually or when there is a significant change. |
| Financial Statements | Insurance companies are required to submit financial statements for the preceding calendar year of their parent company or ultimate holding company, which have been audited and certified by a licensed auditor, to the OIC within six months from the end of the calendar year. |
| Capital Fund | The guidelines regarding group capital supervision and reporting will be established later. |
| Reports |
Under the Full Consolidation approach, the insurance company has an obligation to submit the following reports to the OIC:
During the initial year of implementation (2026), specific reports — including intra-group transactions, inter-group reinsurance transactions, group and governance structure, shareholder lists for each group entity, top management qualifications, and structure of the governing body overseeing the group of insurance business — are required to be submitted by 31 July 2026. These submissions should utilize data as of either year-end 2025 or mid-year 2026, as applicable. |
Effective date
The Full Consolidation supervisory scheme will be effective from 1 July 2026 onwards. The OIC has not yet released the relevant reporting forms. However, at this stage, the insurance company may consider assessing the implication and preparing the relevant report. In the meantime, our team is closely observing this development and will provide timely updates as necessary.
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Amnart Pitakgorn, Partner, Jarae Sithiwong, Partner, and Soravit Vongbunsin, Senior Associate, have contributed to this legal update.