The Bank of Thailand (BOT) has released a set of draft regulations intended to enhance the supervision of retail payment systems deemed critical to the country’s financial infrastructure.
In a new consultation, the regulator sets out standards for identifying and overseeing systemically important retail payment systems (SIRPS), with comments to be submitted by May 2, 2025.
The move reflects the growing role of digital payments in Thailand’s economy, as well as the BOT’s goal of aligning its regulatory framework with international standards.
These include the Principles for Financial Market Infrastructures (PFMI) issued by the Bank for International Settlements (BIS) and the International Organisation for Securities Commissions (IOSCO).
The country’s digital payments landscape has expanded rapidly, and according to the central bank has become vital to the day-to-day transactions of consumers, merchants and the government alike.
The BOT warned that disruptions to major retail payment systems could have wide-reaching effects across the economy, prompting the need for more rigorous oversight.
According to the draft announcement, the regulator is aiming to ensure such systems are operated with stability, transparency and resilience, and that they also remain open, fair and competitive.
The criteria focus on making sure that safe and continuous services are maintained, as well as ensuring that user protection and systemic risks are managed effectively.
Key factors
The consultation covers three key regulatory documents: the Criteria for Assessing Systemically Important Retail Payment Systems; the Criteria for Supervising Retail Money Transfer Systems Classified as SIRPS; and the Guidelines for Supervising Services Provided via SIRPS.
Under the newly proposed rules, payment systems may be designated as SIRPS based on a mix of quantitative and qualitative indicators.
For example, quantitative thresholds include annual transaction values exceeding 10 percent of those processed via the BOT’s high-value Bahtnet system, significant market share in transaction volume, cross-border reach involving at least five countries or systems (with such activity accounting for at least 33 percent of annual volume), and critical connections to other financial market infrastructure.
Qualitative factors include the system’s coverage and user diversity, the importance of stakeholders served, the difficulty of system substitutability and the potential for wide-scale economic disruption if the system is compromised.
The BOT plans to review and update the SIRPS list at least every two years.
Key requirements
For systems classified as SIRPS, the BOT has set out rigorous governance and risk management requirements, stating that boards must be diverse and competent, with directors possessing expertise in areas such as payments, IT or financial infrastructure.
A 75 percent minimum attendance rate is expected, and independent directors have to be genuinely independent, meaning they must not have conflicts of interest such as being in management roles or having major shareholder influence.
In addition, their tenure should follow governance best practices to prevent undue concentration of power.
Firms are also required to ensure that their boards actively oversee compliance with BOT policies, especially those promoting interoperability and preventing fragmentation in Thailand’s payment infrastructure.
To support this, operators need to establish key subcommittees, such as audit and risk oversight committees.
Meeting minutes from boards and executive or risk committees will need to be submitted to the BOT within 15 days of approval, signalling a push for more transparency and regulatory visibility.
The draft also stresses the need for fair and transparent service agreements, pricing models and access regimes, and states that SIRPS operators need to ensure equitable access and avoid monopolistic behaviour.
It goes on to state that fees charged to market participants must be risk-based and disclosed to the BOT at least 15 days before any changes are made.
Who could this affect?
There are a variety of impactful players in the retail payments space in Thailand.
PromptPay, a real-time fund transfer service using national ID or phone numbers, is a key pillar of Thailand’s digital payments infrastructure.
In addition, the Interbank Transaction Management and Exchange (ITMX) system, which facilitates interbank transfers and ATM transactions, is also likely to be considered critical due to its transaction volume and reach.
Thai QR Payment, which allows interoperable QR-based payments across banks and wallets, is another likely candidate for SIRPS designation due to its ubiquity in retail settings.
And digital wallet providers such as TrueMoney, which supports a wide range of consumer payments, and 2C2P, a major payment gateway serving businesses and online retailers, may also come under closer scrutiny.