Thailand’s Department of Business Development will require Thai shareholders and directors in nearly 120,000 flagged companies to submit personal bank statements starting August 1, 2026, giving regulators a direct financial trail to verify whether foreign investment behind those companies is genuine. The move marks the most invasive enforcement step yet in Bangkok’s multi-year campaign against illegal nominee shareholding structures used to circumvent the country’s foreign ownership caps.
Key Facts At A Glance
- New DBD order takes effect August 1, 2026
- Thai shareholders and company directors must submit bank statements for verification
- Roughly 120,000 companies flagged for review nationwide
- Companies with 0.01% to 49.99% foreign shareholding are the primary target category
- Enforcement is concentrated in 16 risk provinces, with particular focus on firms where foreign ownership sits between 40% and 49.99%
- Officials will cross-check declared investment amounts against actual fund transfers for timing and proportion
- The department has identified a pattern of companies registering as 100% Thai-owned before gradually shifting ownership to foreign nationals
- The order follows earlier 2026 measures including AI-based screening of business registration data and asset freezes on suspected nominee networks
Escalating From Paperwork To Financial Forensics
Thailand’s Foreign Business Act generally bars non-citizens from holding more than a 49% stake in most local businesses. For years, some foreign investors have paid Thai nationals to appear as majority shareholders on paper while retaining effective control themselves, a practice regulators say has distorted competition and disadvantaged legitimate Thai-owned firms.
The Department of Business Development, an agency under the Commerce Ministry, said its latest measures respond to a specific evasion pattern. Poonpong Naiyanapakorn, the department’s director-general, said an analysis of business registration filings, shareholder records, financial statements, and accounting office data uncovered nearly 120,000 companies requiring further inspection. A significant subset of these initially registered as fully Thai-owned, then transferred shares or director positions to foreign nationals after the fact, a structure designed to avoid scrutiny under earlier enforcement orders that targeted companies with foreign ownership from the outset.
Under the new order effective August 1, the department will require two categories of people to submit bank statements: Thai nationals who are joint investors alongside foreign partners, and company directors responsible for receiving investment funds. Officials will then run consistency checks, comparing declared investment figures against the actual timing and proportion of financial transfers into the company.
The 16 provinces singled out for the intensified inspection regime include tourist-heavy areas such as Surat Thani, home to Koh Samui and Koh Pha-ngan, where foreign shareholding concentrations are among the highest in the country. Within the flagged pool, the department is prioritizing companies where foreign ownership sits just under the legal ceiling, in the 40% to 49.99% range, on the view that ownership stakes clustered near the cap are the most likely candidates for nominee arrangements designed to stay just inside the law.
Part Of A Broader 2026 Enforcement Campaign
The bank statement requirement builds on measures the department has rolled out through 2026, including AI-based screening tools used to analyze business registration and shareholder data, and case referrals to Thailand’s Anti-Money Laundering Office for financial tracing on large real estate firms suspected of nominee structures. Earlier in the year, a Cabinet-level review designated the nominee issue a national policy priority, citing concerns that population movement linked to Middle East conflict had increased the number of foreign nationals settling in Thailand and, in some cases, operating businesses in competition with Thai nationals.
Separately, the Land Department is studying a proposed amendment to Section 94 of the Land Code that would replace the current remedy for illegally held land, forced sale with proceeds returned to the foreign owner, with outright forfeiture to the state. That change has not been enacted and remains under review alongside broader amendments to the Foreign Business Act, which completed a public consultation period in April 2026.
For foreign investors and joint venture partners operating in Thailand through Thai corporate structures, the immediate implication is a shift from documentation-based compliance to financial substance verification. Structures that cannot demonstrate a genuine, proportionate flow of Thai capital into the business now face a materially higher risk of being reclassified as illegal nominee arrangements, with the accompanying exposure to asset freezes and forced divestment.