On 6 August 2026, Thailand’s Department of Business Development (DBD) announced a public consultation on the principles of a future Ministerial Regulation that could remove the Foreign Business Licence (FBL) requirement for five narrowly defined business categories.
The proposed Thailand FBL exemptions 2026 are not a general opening of the services market. Their main purpose is to remove duplicate licensing where a sector regulator already supervises the activity, or where services are confined to companies within the same financial group. The consultation runs from 10 August to 30 September 2026.
Important: the DBD is consulting only on the principles. The text of the Ministerial Regulation has not yet been published, and none of the proposed exemptions is currently in force.
Which businesses should monitor this consultation?
The proposal is particularly relevant to the following foreign-owned businesses operating or planning to operate in Thailand:
- SEC-licensed securities or derivatives firms considering NAV calculation, asset valuation, investor-meeting representation, cross-border fund representation or shared management and IT services;
- foreign aircraft maintenance, repair and overhaul (MRO) operators that require CAAT repair-station certification;
- banks and other financial groups centralising customer-acquisition or debt-collection functions within the group; and
- foreign contractors providing services to Thai state enterprises or their subsidiaries.
Each category has narrow eligibility conditions. The proposed exemption would remove only the FBL layer and would not replace the licences, approvals or registrations required under the relevant sector-specific legislation.
Why the DBD is proposing further FBL exemptions
Section 9 of the Foreign Business Act B.E. 2542 (1999) requires the Foreign Business Committee to review the restricted business lists at least annually. Following its 2024 and 2025 reviews, the Committee recommended that five business categories be taken out of the FBL approval process.
The DBD’s stated reasons are to reduce overlapping government supervision, facilitate business operations, support investment and recognise that some of the activities are already regulated under specific legislation. For the two financial-group services, the proposal is also designed to reduce internal operating costs without opening the services to unrelated third parties.
The five proposed exemptions
1. Seven services supporting securities and derivatives businesses
The first category contains seven separate activities:
- calculating or certifying the net asset value (NAV) of mutual funds;
- providing information, news and training concerning capital-market products and services;
- providing asset-valuation services;
- acting as a client’s proxy at meetings of securities holders and exercising voting rights;
- leasing or using surplus real property arising from a securities or derivatives business;
- acting as the local representative of a foreign asset-management company under a cross-border mutual-fund arrangement; and
- providing specified management, marketing, human-resources and information-technology support to securities or derivatives operators and their affiliated companies.
This is not an exemption for general consultants or service providers. According to the DBD’s supporting explanation, a foreign operator wishing to conduct any of the seven activities must already hold the relevant licence from the Securities and Exchange Commission (SEC) to operate a securities or derivatives business and must obtain SEC approval before starting the additional activity.
The recipient limitation in item 7 is also important: the management, marketing, HR and IT services are restricted to licensed securities or derivatives operators and their affiliated companies. It should not be read as a general exemption for shared services supplied to the wider market.
2. Aircraft maintenance services
The second category covers maintenance of aircraft, major aircraft components, appliances and aircraft parts under Thailand’s air-navigation legislation.
Removing the FBL requirement would not remove aviation licensing. The operator would still need the appropriate repair-station certificate issued by the Civil Aviation Authority of Thailand (CAAT). The official explanation identifies three certificate types: one for aircraft, one for major aircraft components, and one for appliances and aircraft parts.
3. Procuring customers for financial products within a financial group
This category covers services that procure customers for financial products offered by companies within a financial business group. The foreign service provider must itself belong to that financial group and may provide the service only to companies within the same group.
4. Intragroup debt-collection services
The fourth category follows the same closed-group model. A foreign operator must be a company within a financial business group and may collect debts only for other companies within that group.
For these two categories, the DBD refers to the Bank of Thailand framework. A financial business group may include a commercial bank, its parent company, subsidiaries at every tier and joint ventures in Thailand or overseas.
Debt collection from an individual remains separately regulated. If the debtor is a natural person, the operator must register as a debt-collection business and comply with the Debt Collection Act B.E. 2558 (2015) and its implementing rules.
5. Services where a state enterprise is the counterparty
The fifth category is different. It is primarily an attempt to update an existing exemption rather than introduce a wholly new one.
A 2017 Ministerial Regulation already exempted services where a state enterprise was the counterparty. That regulation was based on the definition in the former Budget Procedure Act B.E. 2502 (1959). The Budget Procedure Act B.E. 2561 (2018) later adopted a narrower definition that no longer includes certain limited or public limited companies in which state enterprises hold more than 50% of the capital.
Because the 2018 Act contains a transitional rule for references in earlier legislation, the 2017 regulation still uses the older, broader meaning. The DBD proposes to align the exemption with the current definition and include transitional protection for foreign operators that began serving entities covered by the former definition before the new regulation takes effect.
The final wording will matter. Updating the definition could narrow the exemption for some state-enterprise subsidiaries, while the proposed transitional provision may protect existing arrangements. A definitive conclusion is not possible until the draft regulation is published.
What the proposal would—and would not—change
If adopted, the regulation would remove one regulatory layer: the requirement to obtain an FBL from the DBD for a qualifying activity. It would not remove the underlying sector-specific requirements.
- Securities and derivatives: SEC licensing and approval would remain.
- Aircraft maintenance: the relevant CAAT repair-station certificate would remain mandatory.
- Financial-group services: the Bank of Thailand framework and intragroup limitations would continue to apply.
- Debt collection from individuals: registration and compliance under the Debt Collection Act would still be required.
The proposal is therefore better understood as targeted regulatory streamlining, not broad liberalisation of Thailand’s foreign-business regime.
Current status and practical implications
The consultation is open until 30 September 2026. The DBD is gathering comments before preparing the legal text, and a further consultation should follow once draft provisions are available.
Foreign investors should not structure new operations on the assumption that the exemptions will be enacted in their current form. Until a final Ministerial Regulation is published in the Royal Gazette and takes effect, the existing FBL rules continue to apply.
This consultation is separate from the nine-business FBA reform package approved in principle by the Cabinet in May 2026. For the wider licensing framework, see our 2026 guide to the Foreign Business Licence in Thailand.
What businesses should do now
- Check whether the proposed category precisely covers the intended activity.
- Identify every sector-specific licence or approval that would remain necessary.
- For financial-group services, document the relationship between the provider and recipient entities.
- For state-enterprise contracts, review whether the counterparty falls within the old or current statutory definition.
- Monitor the second consultation and the eventual Royal Gazette publication before relying on an exemption.
If your business operates in one of these categories, AIM Bangkok can assess whether the proposed exemption fits the activity and identify the sector approvals that would still be required. Contact us →
Official source: DBD consultation announcement and supporting explanation, 6 August 2026.
