Thailand checks for nominees when foreigners become company signatories

The DBD issued the order on 16 March 2026 to tackle the use of Thai nationals as nominees for foreign-owned businesses.

What changed

• Registering a change that results in a foreign national becoming an authorised signatory, alone or jointly, or that increases foreign directors' or partners' numbers or powers, now needs an investment confirmation letter.
• The directors signing the application must declare that all shareholders made genuine contributions and that no Thai national is acting as a nominee.
• The DBD may ask for further documents.
• Under section 36 of the Foreign Business Act, acting as a nominee carries up to three years' imprisonment, a fine of THB 100,000 to 1,000,000, or both.

Who is affected

Thai companies with foreign shareholders or directors, and the company secretaries who register director changes.

Sources

• Tilleke & Gibbins: Thailand introduces corporate signatory safeguards to crack down on nominees (31 March 2026)
• Law Plus: The DBD requires investment confirmation letter on registration of changes to partners or directors (April 2026)