T&S Asset Management

Thailand drafts BNPL rules: all-in charges capped at 15% a year (effective rate)

Published Data as of ThailandRegulationBNPLUnsecured
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Key points

Implications for lenders

A Thai BNPL book would need every customer's ability to repay assessed and total charges kept within 15% a year (effective rate) as an effective rate, which may require repricing products that rely on fees or instalment mark-ups. Credit per person would be limited to THB 20,000 per person and terms to 6 months per item, so limit-setting and exposure tracking across a customer's purchases may need to change. Collection practices would also come under explicit fairness requirements.

Implications

ExecutivesModel BNPL products under the draft terms now: an all-in cap that counts fees and instalment mark-ups changes merchant-subsidy and fee structures.
InvestorsRevenue models built on instalment mark-ups or late fees face the most change; watch the final text after the comment period closes on 15 November.
OperatorsMap current products against the age, limit, tenor and effective-rate terms, and prepare affordability checks and separated purchase-credit journeys.

Facts

The draft: on 19 October 2026 a deputy government spokesperson announced that the Ministry of Finance (MOF) and the Bank of Thailand (BOT) had put draft rules on buy-now-pay-later (BNPL) credit out for public comment from 16 October to 15 November 2026, through the BOT website or the government's central law portal. The rules are a draft and not yet in force.

The terms: users must be at least 20 years 1 old. Credit is limited to THB 20,000 per person 2, with repayment of up to 6 months per item 3. Interest and related charges are capped at 15% a year (effective rate) 4; the cap is measured as an effective rate and includes fees and any increase in the product price caused by choosing to pay in instalments.

Conduct: providers must assess each customer's ability to repay, disclose interest, fees and a repayment schedule clearly, separate the decision to buy from the credit application, and collect debts in an appropriate and fair way. The reports of the announcement do not say which law the rules will be issued under, how existing balances above the limit will be treated, or whether providers must report to the credit bureau.

Analysis

Over time, the draft turns the BOT's earlier plan into concrete numbers. In September the BOT said it planned to license BNPL providers, with about 6 5 main providers expected to need a licence. The last published market size was THB 17.9 bn 6 across 4.91 m accounts 7 at end-2024, or about THB 3,650 8 per account. On those figures the proposed per-person limit sits well above the average balance, so the rate cap and the ban on instalment mark-ups may matter more to providers' revenue than the limit itself.

Across the region, Malaysia chose licensing and affordability checks rather than a price cap: its Consumer Credit Act regime requires BNPL providers to hold at least RM2 million 9 in equity and to assess affordability on credit above RM1,000 10. Thailand's draft instead combines a hard limit, a tenor limit and an all-in rate cap with an affordability assessment for every customer.

Counterpoints and uncertainties

This is a consultation draft: limits, the rate cap, the age threshold and the start date can change before the final rules, and the reports do not name the legal instrument. A hard cap and stricter checks could push some users toward unregulated lenders. The end-2024 market figures are the latest published and may understate current balances.

Key figures

  1. Draft minimum age for BNPL users: 20 years. Minimum user age in the MOF–BOT draft BNPL rules. BNPL users (draft, not in force). Basis date: 19 Oct 2026. Source: Thai PBS: public comment opened on draft BNPL credit rules until 15 Nov (2026-10-19, government spokesperson briefing)
  2. Draft BNPL credit limit per borrower: THB 20,000 per person. Maximum BNPL credit per person in the MOF–BOT draft rules opened for public comment on 16 October 2026. BNPL service providers (draft, not in force). Basis date: 19 Oct 2026. Source: Thai PBS: public comment opened on draft BNPL credit rules until 15 Nov (2026-10-19, government spokesperson briefing)
  3. Draft maximum BNPL repayment term: 6 months per item. Maximum repayment period per purchased item in the MOF–BOT draft BNPL rules. BNPL service providers (draft, not in force). Basis date: 19 Oct 2026. Source: Thai PBS: public comment opened on draft BNPL credit rules until 15 Nov (2026-10-19, government spokesperson briefing)
  4. Draft BNPL interest and charges cap: 15% a year (effective rate). Cap on interest plus related charges, as an effective annual rate including fees and any price mark-up for paying in instalments, in the MOF–BOT draft BNPL rules. BNPL service providers (draft, not in force). Basis date: 19 Oct 2026. Source: Thai PBS: public comment opened on draft BNPL credit rules until 15 Nov (2026-10-19, government spokesperson briefing)
  5. Main BNPL providers in scope of licensing: about 6
    Per press reports of the BOT Governor's remarks.
    . Approximate number of main BNPL credit providers expected to require a licence. BNPL credit providers. Basis date: 4 Sep 2026. Source: The Nation: Bank of Thailand plans mandatory BNPL licences under new rules (2026-09-04)
  6. BNPL credit outstanding: THB 17.9 bn (up 38% y/y). Outstanding buy-now-pay-later credit at end-2024. BNPL market. Basis date: 31 Dec 2024. Source: Thairath: BOT Plans Stricter BNPL Controls by End of 2026 (2026-09-07)
  7. BNPL accounts: 4.91 m accounts (up 99.9% y/y). Number of BNPL accounts at end-2024. BNPL market. Basis date: 31 Dec 2024. Source: Thairath: BOT Plans Stricter BNPL Controls by End of 2026 (2026-09-07)
  8. Average BNPL balance per account: about THB 3,650
    T&S calculation.
    . BNPL credit outstanding divided by number of accounts, end-2024. BNPL market. Basis date: 31 Dec 2024. Source: T&S calculation from Thairath (2026-09-07)
  9. Minimum shareholders' funds for a BNPL licence (SKP): RM2 million. Minimum shareholders' funds or total equity before SKP issues a BNPL licence. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  10. BNPL affordability-assessment threshold (SKP): RM1,000. BNPL credit above which providers must assess an individual consumer's affordability. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)

Sources

  1. Thai PBS: public comment opened on draft BNPL credit rules until 15 Nov (2026-10-19, government spokesperson briefing)
  2. Prachatai: MOF and BOT propose BNPL limit and six-month repayment (2026-10-19)
  3. MGR Online: MOF and BOT move to tighten BNPL rules (2026-10-19)
  4. The Nation: Bank of Thailand plans mandatory BNPL licences under new rules (2026-09-04)
  5. Thairath English: BNPL outstanding and accounts at end-2024
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A Japanese version of this article is available: 日本語版

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