Thailand’s Department of Business Development (DBD) says its new registration rules are intended to stop a nominee-evasion pattern that occurs after a company has already been incorporated. In a July 31 release, DBD said Order 2/2569 took effect on August 1, 2026 and extends specified checks from incorporation to later registration amendments. Nation Thailand independently reported the release and its effective date.
The order’s filing requirements were covered in Houseviser’s July 23 report. The later DBD release adds the department’s explanation of the gap it says the order addresses.
Why DBD extended checks to amendments
According to DBD, its earlier screening focused on incorporation, including checks on Thai investors’ capital in higher-risk entities. The department says registrants could set up an entity outside the initial screening conditions, then later amend it to add foreign investment, foreign shareholding, or a director with signing authority. DBD describes Order 2/2569 as extending scrutiny to those amendments, rather than treating incorporation as the only checkpoint.
For applications involving foreign investment or a foreign national with signing authority, DBD says the order requires an investment explanation and three months of bank statements from both the Thai investor who paid the investment and the representative or juristic person receiving it. The release says this is intended to assess the investor’s actual capacity to invest.
Separate Department of Lands checks
A June 1 release from the Department of Lands’ Kabin Buri office describes separate land-transfer checks. For an individual transferee, it says a land transaction of THB 5 million or more, or a cash payment of THB 2 million or more, requires closer examination of the buyer’s funds, income, occupation, and financial position. The same release discusses corporate transactions separately, including scrutiny of companies with foreign shareholders or directors.
That DOL release predates DBD’s July 31 explanation. It does not establish a monthly review cycle, a quarterly reporting requirement, or that the DOL measures were caused by Order 2/2569. DBD’s July 31 release likewise does not describe a DBD–DOL data-sharing workflow for the new registration evidence.
Phuket relevance
DBD says there were 119,116 active Thai juristic persons with foreign shareholding between 0.01% and 49.99% as of its release. It also named Phuket and Krabi among the provinces where it will continue scrutiny of nominee-risk activity.
For a Phuket buyer considering a Thai-company structure, the immediate change is at the company-registration stage: a later change to foreign ownership or signing authority may trigger the same evidence requirements as the original filing. It is not a finding against a particular company, land parcel, or transaction, and none of the sources above reports that a DBD flag has affected a specific land transfer.
What remains unknown
- The DBD release does not set out how, or whether, Order 2/2569 evidence is shared with the Department of Lands during a land-transfer review.
- It does not announce a new shareholder-list disclaimer; this article makes no claim about one.
- The DOL release does not state how its transaction thresholds apply to every ordinary purchase by a Thai buyer.
For background on how nominee risk is assessed, see Houseviser’s guides to Thai company structures for property ownership and the Foreign Business Act. This article is not legal advice.