Thailand DBD Steps Up Enforcement on Nominee Shareholding and Land Ownership
January 2026
The Department of Business Development (DBD) has significantly strengthened its regulatory enforcement to suppress illegal business activities, particularly those involving foreign ownership through Thai nominee shareholders and unlawful land ownership. As part of this initiative, the DBD is currently coordinating with 17 government agencies to inspect high-risk companies across key sectors, including tourism, real estate, e-commerce, hotels, agriculture, and construction. More than 46,000 entities nationwide have been identified for review.
A key focus of this enforcement drive is companies suspected of holding land or real estate through Thai nominee arrangements, especially in major economic and tourist areas. Violations may result in criminal penalties under the Foreign Business Act and land related laws. In addition, the authorities have implemented new regulatory measures, including stricter verification of directors and shareholders, requirements to submit financial evidence, and enhanced scrutiny of company registration processes.
Given that these increased enforcement measures are already in effect, we strongly recommend that businesses review their shareholding structures, directorship arrangements, and land-holding positions to ensure strict compliance with applicable laws.
This document is solely intended to provide an update on recent development in Thailand legislation and is not purported to provide a legal opinion, nor a legal advice to any person.