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Update: Fully online business registration took effect on 1 October 2026. Detailed procedures are subject to the rules issued by the Department of Business Development (DBD).

Thailand's Minister of Commerce Suphajee (ศุภจี) released her 90-day performance report on 24 August 2026. Two items in it bear directly on foreign-invested companies in Thailand: business registration will go fully online from 1 October 2026, and the crackdown on nominee shareholding (นอมินี) has been listed as one of the ministry's seven priority tasks going forward.

1. Which Two Lines of the 90-Day Report Foreign Companies Should Read

The bulk of the report covers trade results: in 90 days the Ministry of Commerce generated more than THB 145 billion (about RMB 31.9 billion) in trade; the "Thai Helps Thai" programme has cut costs by about THB 818 million (about RMB 180 million) since April B.E. 2569 and created THB 2.9 billion (about RMB 638 million) in economic value; more than 50,000 business owners received support; and intellectual property applications in B.E. 2569 reached 45,916, up 7.48% year on year.

For Chinese companies that already have, or are planning to set up, an entity in Thailand, however, the two lines that really matter are these: all types of business registration (จดทะเบียนธุรกิจ) will go fully online from 1 October B.E. 2569 (1 October 2026), and the seven follow-up tasks explicitly include enforcement against nominee shareholding.

2. What Going Fully Online Means

Moving the entire registration process online means that registration matters such as company incorporation and changes will shift from submitting paper documents at a counter to filing through an electronic system. The direct impact on companies has three layers:

First, documents become more standardised. Online systems are usually stricter than a manual counter about file formats, signing methods and shareholder identity documents, so there will be fewer situations where a missing document can simply be "provided on the spot".

Second, the audit trail becomes more complete. Every filing and every shareholder and capital contribution document submitted through the electronic system creates a traceable record, which links directly to the third point.

Third, it works hand in hand with nominee checks. Once registration data has been collected electronically, the technical barrier for the authorities to compare shareholding structures, sources of capital and related-party relationships drops sharply. This is also why "fully online" and "cracking down on nominees" appear in the same report.

It should be noted that the official report only specifies the timing and scope, namely "fully online from 1 October". It does not go into the detailed system procedures, transitional arrangements or whether paper submissions will be completely discontinued. These are subject to the implementing rules to be issued later by the Ministry of Commerce and the Department of Business Development (DBD).

3. Nominee Shareholders: Why It Deserves Serious Attention This Time

Thailand's Foreign Business Act sets clear limits on foreign shareholding and the scope of business. In some industries, foreign shareholding above 49% requires a Foreign Business License (FBL). In practice, a small number of companies get around this restriction by having Thai individuals hold shares in name only, commonly known as "nominee shareholders" or "nominee arrangements".

By putting nominee enforcement among its seven ministry-level priority tasks, alongside the digitisation of registration data from 1 October, the Ministry of Commerce is raising both the data foundation and the enforcement priority of supervision.

Another figure in the same report is worth reading alongside this: the DBD disclosed on 22 August that, as of 31 December B.E. 2568, there were 967,210 active juristic persons nationwide. That is the existing base that electronic screening will face, and it shows the difference in efficiency between systematic screening and manual spot checks.

It must be stressed that the authorities' consistent position on such matters is that data-matching results are used to identify leads, and do not amount to a finding of violation until a review has reached a conclusion. Companies need not panic, but with online registration in force since 1 October, it is genuinely necessary to complete a self-check as soon as possible.

4. Four Self-Checks Recommended Now

1. Shareholding structure: Check whether the current articles of association and shareholder register match the actual capital contributions, and whether the capital contribution evidence and proof of source of funds for Thai shareholders are complete.

2. Scope of business: Check whether the scope of business registered on the business licence matches the actual business, and whether the actual business falls within the restricted lists of the Foreign Business Act.

3. Validity of licences and permits: If the company holds special licences such as an FBL or a factory establishment permit, check their validity periods and whether annual reporting obligations have been fulfilled.

4. Registration updates: If details such as the address, directors or authorised signatories have changed without being registered, it is advisable to complete the updates before the system switchover.

Key Takeaways

1. All types of business registration in Thailand go fully online from 1 October 2026 (Commerce Minister's 90-day report).

2. The crackdown on nominee shareholding (นอมินี) is one of the Ministry of Commerce's seven priority tasks going forward.

3. As of the end of B.E. 2568, Thailand had 967,210 active juristic persons, the existing base for electronic screening.

4. According to the official position, data matching is used to identify leads and does not constitute a finding of violation until a review is concluded.

The detailed implementing rules are subject to later announcements by the Ministry of Commerce / DBD.

Z&X Tip

With fully online registration in force since 1 October, now is the time to complete a self-check of shareholding and scope of business. Z&X's company registration and licensing service line covers company registration with the Thai Ministry of Commerce (DBD), drafting of articles of association, verification of registered capital, Foreign Business License (FBL) applications, as well as full support for company information changes, deregistration and tax clearance. Whether a structure needs to be adjusted, and how, must be judged on the business substance of each case and is subject to the determination of the competent authorities.

Sources

• "ศุภจี" แถลงผลงาน 90 วัน พาณิชย์ สร้างมูลค่าการค้ากว่า 1.45 แสนล้าน พร้อมลุย 7 ภารกิจต่อ
Thai Ministry of Commerce | 2026-08-24
https://www.moc.go.th/th/gallery/category/detail/id/5/iid/2125

• กรมพัฒนาธุรกิจการค้า เผยยอดผู้ทำบัญชีเพิ่ม เร่งปั้นนักบัญชีรุ่นใหม่
Department of Business Development (DBD), Thailand | 2026-08-22
https://www.moc.go.th/th/gallery/category/detail/id/5/iid/2118