Country _ Name
Online banking services
FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).


API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.

Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.

BaaS – Bank as a Service/BaaP – Bank as a Platform:
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.


Attitude of the country towards online-banking services

The COVID-19 pandemic has especially accelerated digital adoption and digital disruption in the financial sector. This has meant structural improvements in opening up to digital and technological changes regarding online transactions, deemed to be essential for the future. This has also caused service enhancements from online banking providers as they compete to provide more efficient service to their customers while lowering their operating costs.

Legal affairs

Obligations and requirements to provide online-banking services described above

Licensed financial institutions – commercial banks, finance companies, and credit foncier companies – in Thailand may apply to the BOT for approval to provide online (i.e. internet or mobile) banking services. 

In 2020, the BOT introduced the “digital personal loan,” which is defined as a personal loan that enables business operators to utilise digital technology and alternative data to assess the borrower’s ability and willingness to repay the loan. However, this loan does not include the types of loans that use car registration as collateral. The key requirements for undertaking a digital personal loan business are as follows:
  • Business operators are expected to use technology and alternative data to determine the customer’s risk profile, based on their ability or willingness to repay. The alternative data that is used must be from a trusted source and must use a sensible hypothesis in assessing the customer’s credit profile. Business operators may comply with the BOT’s information-based lending guidelines.
  • Business operators must use electronic channels for both the provision and repayment of the loans. This may include disbursing and repaying by bank transfer, direct debit, or e-money to create a digital footprint in the financial sector for the customers.
  • Business operators must disclose relevant information to customers, including interest rates, fines, service fees, operating fees, outstanding loan tables, and any other related fees relating to the loan. This information must also be easily accessible for customers through electronic means (for example, by being hosted and easily accessible on the loan provider’s website).
  • The maximum loan amount is THB 20,000 (approx. USD 585), with a maximum credit period of six (6) months.
  • Business operators may not charge additional interest, fines, service fees, operating fees, or any other fees to cus
tomers for early repayment of a loan.
  • Business operators must have IT security risk management measures in place. This includes measures to protect data from unlawful collection, processing, use, and destruction. Business operators must also have a business continuity plan and an IT Disaster Recovery Plan. If the business operator will outsource their IT systems or connect their IT systems to third-party services in a way that involves the transfer of sensitive data (e.g. by using a cloud computing service), the third party must also have risk management and cybersecurity processes the meet the same standards.

  • Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area

    The BOT has also promoted and pushed for important financial infrastructure to support the development of products and services. This would be beneficial for business operators and financial institutions that plan to deploy technology for providing financial services. As new regulatory requirements and restrictions are continually being developed to respond to new online banking technologies, businesses should expect to see the legal and regulatory environment.

    Economic conditions

    Market size for online-banking services and biggest companies in this business area

    According to BOT records, the number of accounts using internet and mobile banking are increasing every year, with 29,850,113 accounts linked to internet banking and 62,788,691 linked to mobile banking in 2020.

    However, there is no publicly available information regarding the market share of the business operators and financial institutions that provide online banking services.

    Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area

    Online banking services are relatively new to the market and are still evolving. Important mechanisms for efficient growth of online banking businesses include value positioning, data (both financial and non-financial), customer base, financial structure, technology, and regulations.

    The BOT’s statistics on online banking transactions indicate that people in Thailand will enter into financial transactions via electronic means more than through traditional channels, which suggests that online banking business in Thailand is set for continuous growth over the coming years. 



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