Family offices in Thailand do not need a dedicated family-office licence. They do need to check whether the services they actually provide require securities licences. The Thai SEC’s guidance of 28 September 2026 explains how the existing framework applies, including limits that matter when designing services, advertising them or working with a licensed investment firm.
Which activities need a licence?
| Service | SEC licensing position |
|---|---|
| Legal, tax, accounting and purely administrative support | No securities licence for activities outside securities business; other laws still apply. |
| Personalised securities recommendations, with the client deciding | Investment-advisory licensing generally applies unless an exemption is available. |
| Managing a client’s securities portfolio with discretion to invest or rebalance | Private-fund management licensing generally applies when offered as a business. |
A single-family office handling a family’s internal affairs, without serving outsiders or offering services publicly as a business, can fall outside SEC licensing. Serving several families does not automatically trigger a licence: the actual services and operating arrangements remain decisive.
Why fewer than 15 clients may still require a licence
The investment-advice exemption requires no more than 15 investors in any 12-month period and no conduct holding the provider out as an investment adviser. The threshold concerns investors receiving advice, so providers should not assume they can simply count family groups.
The SEC gives a useful example: a provider publicly advertising investment-advisory services on its website may fail the exemption even with only five clients. Charging a fee does not, by itself, remove the exemption; the SEC considers the overall circumstances, including promotion, remuneration and continuity of service.
This exemption concerns investment advice. It does not authorise discretionary portfolio management. A separate exemption covers advice exclusively to institutional investors meeting the applicable definition.
Working with a licensed firm: define the limits
An unlicensed family office providing administrative coordination can arrange meetings, organise documents and track progress. Under that model, clients must send trading instructions directly to the licensed firm; the office cannot receive, confirm, change or relay those instructions for them.
Other arrangements are possible under specific rules. A licensed firm may outsource permitted work under its supervision while retaining responsibility. An investment-advisory licensee may also transmit orders as an appointed broker’s agent within the relevant conditions; the client retains the investment decision.
Referral payments and revenue sharing also need attention. The SEC requires licensed firms to manage conflicts and disclose the relevant business relationships and remuneration before the client decides. It says family offices should disclose the benefits they receive too.
Before launching or appointing a family office, put four points in writing: who gives advice, who decides, who handles orders and who gets paid by whom. Check the service agreement and public marketing against those roles and the relevant licences or exemptions.
Source: Thai SEC, “7 things to know” about family offices in Thailand, 28 September 2026, particularly pages 3–6.
Planning a family office in Thailand?
Tell us which families you intend to serve and what services you plan to provide. Contact AIM Bangkok to discuss the structure, licensing requirements and agreements with regulated service providers.
