Thailand introduces new 3-month bank statement requirement for company registrations from 1 January 2026.

On 1 December 2025, the Department of Business Development issued Order No. 2/2568, introducing stricter documentation requirements for certain company incorporations in Thailand. The Order has been published in the Royal Thai Government Gazette and will take effect on 1 January 2026.

The new rules change how Thai shareholders need to evidence their financial capacity when registering a company in specific foreign-related structures.

Companies within scope of the order

The requirement for Thai shareholders to submit financial evidence at the point of registration applies only in the following situations:

• Joint ventures where foreign shareholders hold less than 50 percent of the registered capital, such as the common 49 percent foreign and 51 percent Thai structure
• Thai companies with 100 percent Thai shareholding where a foreign national is appointed as an authorised director with signing or binding authority

Companies that fall outside these scenarios are not subject to the new financial evidence requirement.

The new 3-month bank statement requirement

Under the new Order, the DBD will no longer accept simple bank balance certificates as sufficient proof of capital. Instead, Thai shareholders must provide more comprehensive documentation to demonstrate genuine financial capacity.

The key requirements are as follows:

Three months of bank statements

Statements cover a continuous three-month period counting backwards from the date of the share subscription payment.

Transaction alignment

The statements clearly show a withdrawal or transfer that exactly matches the amount and date of the share subscription payment.

Verification of financial capacity

The transaction history demonstrates that the invested capital is properly sourced and genuinely belongs to the shareholder, rather than being a temporary deposit made solely for registration purposes.

Practical implications

This change reflects the DBD’s continued focus on addressing nominee shareholding arrangements and enhancing transparency in foreign-related structures. The new documentation standard may extend incorporation timelines, particularly where shareholders need time to ensure sufficient funds are maintained in their accounts for the required period.

Businesses planning to establish joint ventures or appoint foreign directors in Thai companies should review their proposed structure early and prepare the necessary financial documentation in advance to avoid delays.