Order 2/2569: The Current Bank-Statement Rule for Thai Shareholders
Three Central Registrar orders on foreign shareholding were issued between December 2025 and July 2026. Only the third, Order 2/2569, effective 1 August 2026, is current — and it requires three months of bank statements from Thai shareholders in any company with foreign co-investment, for both new registrations and later amendments.
The three orders, in order
Order 2/2568, signed 1 December 2025 and gazetted 22 December 2025 (Royal Gazette Vol. 142, Special Episode 397 Ng, page 60), took effect 1 January 2026. It required Thai shareholders — in companies where foreigners held under 50% of capital, or where a foreign national held signing authority with no foreign shareholding at all — to submit three months of bank statements showing the specific withdrawal or transfer that paid for their shares, matching both the amount and the date.
Order 1/2569, signed 16 March 2026 and gazetted 26 March 2026 (Vol. 143, Special Episode 82 Ng, page 54), took effect 1 April 2026. It covered a narrower scenario: a company that started out entirely Thai-held amending its registration to add a foreign partner or a foreign signing director. For that specific case, it required only a signed declaration — an Investment Confirmation Letter — not bank statements.
Order 2/2569, signed 14 July 2026 and gazetted 27 July 2026 (Vol. 143, Special Episode 182 Ng, page 75), took effect 1 August 2026, and its first clause expressly repeals both orders above. It folds establishment and amendment filings into one regime: the bank-statement test from Order 2/2568 now applies to both, and the Investment Confirmation Letter from Order 1/2569 is still required for the specific nominee-risk amendment scenarios it covers. Companies already registered before the order took effect get a one-year window to come into compliance.
The exact requirement, as written
The gazetted text requires, for any Thai partner or shareholder in a triggering company, "a bank-issued statement of account transactions covering the three months preceding the date of payment of the capital contribution or share price... which must show a withdrawal or transfer transaction consistent with the amount of the capital contribution or share price and the date such payment was made." In plain terms: the Thai money has to be shown moving, in the right amount, on the right date, from an account with real history behind it — not deposited and withdrawn the same week to satisfy a registration formality.
Where the blogs got it wrong
Two mistakes turn up repeatedly in commentary written before Order 2/2569 existed. First, several sources describe Order 1/2569 as "extending the bank-statement requirement to amendment filings" — it does not. Its own text requires only the signed declaration form, a lighter instrument; the bank-statement requirement wasn't extended to amendments until Order 2/2569, four months later. Second, some commentary frames these orders as a sweeping "DBD crackdown regulation." Precisely, they are orders of the Central Registrar — a bureau within the Department of Business Development acting under a specific 2006 ministerial regulation — not department-wide policy, and they don't themselves create a new criminal offence. The criminal exposure for nominee arrangements comes from the pre-existing Foreign Business Act, Section 36, which the orders reference rather than replace.
What this means for a Chiang Dao buyer
If you're structuring a Thai-majority company to hold land — the standard route where a foreign buyer takes a minority stake alongside a Thai partner — build the paper trail from day one. Your Thai partner's bank statements need to show genuine, sustained funds before the capital contribution is paid, not a same-day pass-through. If the structure changes later — a foreign director is added, shares transfer — that amendment now needs the same bank-statement evidence under the current order. This is not a box to tick after the fact; get it right from incorporation.