In brief
On 16 October 2026, the Bank of Thailand (BOT), together with the Ministry of Finance (MOF), launched a public hearing on a proposed regulatory framework for Buy Now Pay Later (BNPL) services in Thailand. The proposed framework would bring certain BNPL services offered through significant digital marketplace platforms within Thailand's regulated personal loan regime and introduce specific requirements relating to licensing, product terms, consumer protection, and operational controls. The hearing is open until 15 November 2026.
The proposed framework reflects the Thai regulators’ increasing focus on the growth of BNPL services, particularly those offered through digital marketplace platforms, as well as their concerns regarding consumer over-indebtedness and BNPL activities currently operating outside the BOT’s regulatory landscape. If implemented, the framework would require certain BNPL service providers to assess their licensing requirements, and adjust the product terms, customer journeys and operational systems within the applicable transitional periods.
In more detail
1. Scope of the proposed framework
The proposed framework would apply to personal credit provided to an individual for the purchase of goods or services through a significant digital marketplace platform, with the specific purpose of serving as a source of funds for payment for goods and services, as part of the process for purchasing goods and services through the digital marketplace platform.
A significant digital marketplace platform means a platform that meets either of the following thresholds:
- The annual value of transactions arising from services provided in Thailand exceeds THB 100 million.
- The average monthly number of users in Thailand exceeds 5% of Thailand’s population.
The proposed scope also extends to certain platforms operated by entities within the same business group as the digital marketplace platform.
2. Key requirements
- Borrower eligibility: BNPL would generally be available only to individuals aged 20 or above with sufficient repayment capacity. Alternative data may be used to assess the consumer's ability or willingness to repay.
- Credit limit: BNPL credit would be capped at THB 20,000 per consumer, including on an aggregate basis across BNPL providers within the same business group.
- Tenor: Each BNPL transaction would be limited to a maximum repayment period of six months.
- Pricing: Interest, penalties, service charges, fees, and other relevant charges would be capped at 15% per annum on an effective-rate basis. In the event of default, additional charges for debt collection and default interest may apply. Prepayment fees would be prohibited.
- Credit reporting: BNPL providers would be required to become members of, and submit credit information to, the National Credit Bureau.
- Prohibited activities: BNPL credit could not generally be converted into cash or electronic money, transferred for unrelated purposes, used to purchase prohibited or readily cash-convertible goods, or repaid using a credit card or another credit facility.
- Licensing and capital requirements for non-bank operators: A non-bank operator wishing to provide regulated BNPL services would be required to obtain the relevant regulated personal loan license and satisfy the applicable licensing criteria, including a minimum paid-up registered capital of THB 50 million and requirements relating to the applicant’s financial and regulatory standing, AML/CFT history, and previous conduct of regulated financial or payment businesses.
3. Consumer protection and customer journey
The proposed framework would require BNPL providers to comply with BOT's Market Conduct regulations and Responsible Lending requirements, together with additional requirements tailored to BNPL services. BNPL providers would need to ensure that consumers can clearly and easily access key product information before entering into a BNPL agreement. Before a consumer confirms a purchase using BNPL, providers would also need to disclose a breakdown of the price of the goods or services, related costs, total BNPL interest, other service charges and discounts, together with the total amount payable.
Advertising and sales practices would not be permitted to encourage or pressure consumers to apply for credit. At checkout, a non-credit, full-payment method would need to be set as the default payment option. Where BNPL is selected, the consumer would need to be shown additional information on the total BNPL amount due in the next payment period, including the proposed purchase, as well as the potential consequences of late payment, and would be required to reconfirm the selection.
BNPL providers would also need to ensure that key credit and debt information and channels for assistance remain readily accessible throughout the credit relationship. Any change that increases a consumer’s obligations or risks, such as an increase in the credit limit, would generally require the consumer’s opt-in consent.
4. Transitional arrangements
Existing BNPL providers that are not already licensed to conduct regulated personal loan business would need to apply for the required license within 60 days after the relevant notification takes effect if they wish to continue operating. They may continue their BNPL business unless and until the Minister notifies them that license has not been granted. Where the proposed capital requirements are not initially satisfied, an applicant may submit a capital increase plan and satisfy the relevant requirements within 180 days.
Existing personal loan license holders that already provide BNPL services would be required to notify the BOT within 60 days of the effective date of the relevant notifications. The substantive BNPL requirements would generally apply 90 days after the effective date, while the requirement to become a member of and report information to the National Credit Bureau would apply 270 days after the effective date. Existing BNPL loans granted before the new requirements take effect may continue under their existing contractual interest, fees, and repayment terms until the relevant debt is fully repaid.
Next steps
The proposed framework remains subject to public consultation, which is open until 15 November 2026. Businesses and online shopping platforms that provide or are considering providing BNPL services in Thailand should assess the potential implications of the proposals for their existing operations and future business plans. Given the short transitional period, businesses should begin preparing early to make any necessary adjustments to their operations and prepare the required documents for submission to the BOT.
For further information, please contact our team at Baker McKenzie.
* * * * *
Phetrada Kampusiri and Phatraporn Phatrapiboon, Associates, have contibuted to this legal update.