Author: Liang Yu
Editor: Zhao Yidan
At the forefront of the digital finance wave in Southeast Asia, Thailand is no longer content to follow — it is pushing "real-world asset tokenization" (RWA) from paper into reality with national will.
From the groundbreaking issuance of the world's first tokenized government bond, G-Token, to the "TouristDigiPay" program that allows tourists to pay for travel expenses directly with cryptocurrency; from traditional banks tentatively exploring real estate on the blockchain to the Securities and Exchange Commission (SEC), central bank, and anti-money laundering office constructing a "three-pillar" regulatory system — Thailand is conducting an unprecedented financial restructuring experiment under national leadership.
However, behind this ambition lies immense tension: as Thailand incorporates global platforms into its regulatory reach with "long-arm jurisdiction" clauses, can it truly balance "innovation" and "prudence"? How will this wave of tokenization, backed by national credit, impact traditional financial order and regional competitive dynamics?
This article deeply dissects the progress, controversies, and future games of Thailand's RWA ecosystem based on official policies, market data, and global comparisons.
The RWA Research Institute has honorably released a series of in-depth research reports titled "Global RWA Compliance Overview." This series aims to study the regulatory legal policies, major regional projects, protocol technology construction, and architectural design of cryptocurrencies in major regulatory countries/regions such as the United States, Hong Kong, Singapore, Dubai in the UAE, Thailand, and Germany, attempting to provide readers with profound and comprehensive insights.
This is the sixth article in our series.
1. Background and Current Status of RWA Development in Thailand
The rapid development of the digital economy in Southeast Asia has prompted countries to accelerate their layout in the fintech sector. As an important economy in the region, Thailand is actively exploring the integration path of digital assets and traditional financial systems through a series of policy adjustments and regulatory innovations. According to data from the Bank of Thailand, the country has a population of over 70 million, with a continuously growing proportion of internet users, providing a vast market for digital financial services. The tourism industry, as a pillar of Thailand's economy, generated $34.4 billion in tourism revenue in the first nine months of 2025, providing a natural testing ground for the application of RWA in tourism consumption scenarios.
In recent years, Thailand's digital asset market has shown a trend of shifting from retail-led to institution-led. Nirun Fuwattananukul, CEO of Binance Thailand, pointed out in the Bangkok Post that the new regulations proposed by the Thai SEC on October 9, 2024, allow institutional mutual funds and private equity funds to invest in crypto products, marking a maturation of the Thai market. Meanwhile, the tokenization of physical assets is becoming a major trend in Thailand. According to Tren Finance research, the RWA tokenization industry could grow 50 times by 2030, and traditional banks in Thailand are also beginning to explore converting conventional assets such as bonds, real estate, and stocks into blockchain-tradable digital assets.
The Thai government has shown a proactive attitude in promoting the development of digital assets. The successful issuance of the world's first tokenized government bond, G-Token, in 2025, and the "TouristDigiPay" program launched for the tourism industry, reflect Thailand's clear strategy of combining real-world assets with blockchain technology. These initiatives not only inject new vitality into Thailand's digital economy but also make it an important observation point for RWA development in Southeast Asia.
The systematic support from the Thai government for the digital economy has laid a solid foundation for its RWA development. According to the "Digital Thailand" strategy and the "Thailand 4.0" twenty-year development plan, Thailand is committed to achieving comprehensive digital transformation, aiming to join the ranks of developed countries by 2037. This grand strategic vision is reflected in specific quantitative indicators: the Thai government expects the contribution of the digital economy to GDP to reach 25% by 2027 and further increase to 30% between 2030 and 2037. The establishment of these specific goals provides clear policy expectations and development space for the digital asset field, including RWA.
In terms of governance structure, Thailand has undergone profound institutional restructuring. According to official documents, Thailand has established a National Digital Economy and Society Committee chaired by the Prime Minister, responsible for top-level policy formulation. At the same time, the Ministry of Digital Economy and Society (MDES) has replaced the former Ministry of Information and Communication Technology (MICT), significantly expanding its functional scope to better respond to the dual impact of digital technology on the economy and society. This institutional reform reflects the Thai government's determination to promote the development of the digital economy from a strategic height.
The rapid improvement of the legal environment is also noteworthy. Thailand has formulated and improved digital economy-related laws, including the Electronic Transactions Act, the Digital Economy and Society Development Act, the Cybersecurity Act, and the Personal Data Protection Act, within a short period, providing a relatively sound legal environment for innovative applications such as RWA. Particularly in terms of digital infrastructure, Thailand's investment is particularly significant. According to plans, Thailand was one of the first in the ASEAN region to launch 5G networks and invest in building submarine cable networks, aiming to become a strong internet and communication country in Asia. The improvement of these infrastructures provides the necessary technical support for the large-scale application of RWA.
2. Core Mechanisms of Thailand's RWA Regulatory Framework
Thailand's RWA regulatory system has developed over the years into a governance structure involving multiple agencies with clear levels. This structure centers on the Thai Securities and Exchange Commission as the core regulatory body, with the Bank of Thailand responsible for the stability of the monetary payment system, and the anti-money laundering office focusing on the prevention of financial crimes, together forming the three-pillar system of RWA regulation. Additionally, the Ministry of Finance, as the final issuing authority for digital asset licenses, holds decision-making power in the access phase. This multi-headed regulatory model ensures the effectiveness of specialized regulation while also bringing challenges in inter-departmental coordination.
(1) Coordination and Division of Labor Among Regulatory Agencies
The core feature of Thailand's RWA regulatory system is reflected in the collaborative governance structure among multiple agencies. According to official documents, this structure positions the Thai Securities and Exchange Commission (SEC) as the core regulator of the digital asset market, the Bank of Thailand (BOT) responsible for payment systems and traditional financial stability, and the anti-money laundering office (AMLO) focusing on the prevention of financial crimes, together forming the three major pillars of RWA regulation.
The Thai Securities and Exchange Commission is authorized as the chief regulator of the digital asset market under the Emergency Decree on Digital Asset Business 2018. Its responsibilities are quite broad, including formulating laws and regulations in areas such as digital asset trading, sales, and initial coin offerings (ICOs); approving and regulating digital asset exchanges, brokers, dealers, ICO issuers, and ICO platforms; conducting issuance approvals for ICO projects, requiring that issuances must occur through SEC-approved platforms; and requiring companies seeking to expand their digital asset business to obtain prior approval from the SEC. Notably, the SEC also bears secondary market regulatory responsibilities, including enhancing scrutiny of exchanges and issuing formal warnings and investigations for violations of anti-money laundering agreements. This comprehensive regulatory authority enables the SEC to play a core regulatory role in the RWA ecosystem.
The regulatory focus of the Bank of Thailand differs. As the guardian of payment systems and traditional financial stability, the BOT primarily oversees electronic payment services and issues licenses based on recommendations from the BOT. The BOT actively promotes the "National Electronic Payment Master Plan," encouraging the use of electronic payment methods such as PromptPay, EDC, and QR codes to facilitate Thailand's transition to a cashless society. In terms of risk control, the BOT restricts commercial banks from directly participating in cryptocurrency-related businesses, stipulating that direct or indirect investments in crypto assets by commercial banks or financial holding companies must not exceed 3% of their total capital. This prudent regulatory attitude reflects the BOT's balance between encouraging innovation and preventing financial risks.
The anti-money laundering office plays a key enforcement role in the RWA regulatory ecosystem. AMLO is primarily responsible for enforcing anti-money laundering and know-your-customer regulations to prevent financial crimes related to cryptocurrencies. Notably, AMLO requires local cryptocurrency exchanges to ensure that new customers must be physically present for verification before opening non-face-to-face accounts or conducting new transactions. This policy, implemented since May 2021, aims to accurately track the flow and source of cryptocurrencies to prevent criminal activities. AMLO's enforcement actions align with the SEC's regulatory requirements, aiming to ensure that Thailand's regulations meet the international standards set by the Financial Action Task Force.
The division of labor and collaboration among these three agencies reflects the Thai government's systematic thinking on digital economy risk management. In regulatory practice, the SEC focuses on the issuance and trading regulation of digital assets (including cryptocurrencies and tokens), while the BOT focuses on the stability of payment systems and macro-finance. In terms of compliance framework construction, the SEC is responsible for requiring its licensed entities (such as exchanges) to comply with AML/KYC regulations, while AMLO is responsible for stipulating and enforcing stricter customer identity verification processes to ensure the effectiveness of anti-money laundering efforts. This regulatory model, which combines division of labor and collaboration, provides a relatively stable and predictable regulatory environment for the development of RWA in Thailand.
(2) Evolution and Deepening of the Legal Foundation
The legal foundation of Thailand's RWA regulation is primarily built on two core laws: the Emergency Decree on Digital Asset Business and the Payment Systems Act. These two laws construct the legal framework for RWA from the dimensions of asset nature and payment processes.
The Emergency Decree on Digital Asset Business, enacted in 2018, is the foundational law for Thailand's digital asset regulation. This decree was issued on May 10, 2018, with the main purpose of regulating digital asset businesses, maintaining national economic stability, and protecting investors and the public. A key contribution of this law is the clear definition of digital assets as "any form of digital asset that can be traded or used for trading," specifically categorizing them into cryptocurrencies and digital tokens. According to the text of the decree, cryptocurrencies are defined as "electronic information units issued based on distributed ledger technology," while digital tokens are defined as "virtual assets representing rights in specific blockchain projects." This precise legal definition provides a clear legal basis for subsequent regulatory practices.
In terms of the licensing system, the decree establishes the SEC as the main regulatory authority for the digital asset market. According to the regulations, any entity engaged in digital asset business (including exchanges, brokers, dealers, and ICO portals) must obtain a license issued by the Ministry of Finance based on SEC recommendations. For ICO regulation, the decree explicitly states that the issuance of digital tokens must occur after the registration statement and prospectus draft become effective, and the issuance must be conducted through SEC-approved digital token portal service providers. This strict issuance regulation reflects the Thai government's cautious balance between encouraging innovation and protecting investors.
The "Emergency Decree on Digital Asset Business (No. 2)" effective April 13, 2025, represents a significant evolution in Thailand's digital asset regulation. The most notable provision of this decree is its "long-arm jurisdiction" policy for foreign digital asset service providers. According to Article 26/1 of the decree, any foreign platform that possesses any of the following characteristics is deemed to be providing services to users in Thailand and must apply for a digital asset license: operating content displayed entirely or partially in Thai; using a website domain with symbols representing Thailand, such as ".th" or "ไทย"; supporting transactions in Thai Baht or through Thai financial institutions; having terms of service that explicitly apply Thai law or resolve disputes in Thai courts; having a physical office in Thailand or arranging personnel to provide support services; and paying fees for services specifically targeting Thai users. This detailed identification standard significantly enhances the enforcement capabilities of Thai regulatory authorities.
The most distinctive clause of this decree is its "long-arm jurisdiction" policy for foreign digital asset service providers. According to Article 26/1 of the decree, any foreign platform that possesses any of the following characteristics is deemed to be providing services to users in Thailand and must apply for a digital asset license: operating content displayed entirely or partially in Thai; using a website domain with symbols representing Thailand, such as ".th" or "ไทย"; supporting transactions in Thai Baht or through Thai financial institutions; having terms of service that explicitly apply Thai law or resolve disputes in Thai courts; having a physical office in Thailand or arranging personnel to provide support services; and paying fees for services specifically targeting Thai users.
This "long-arm jurisdiction" policy means that many international platforms that previously operated in a gray area must face a clear choice if they wish to continue serving Thai users: either invest the cost to establish a physical presence in Thailand, apply for a license, and accept comprehensive regulation; or completely block Thai IPs and Thai-speaking users, exiting the market. This not only enhances the deterrent effect of Thai regulation but also raises higher requirements for the localization compliance strategies of global digital asset service providers.
On the other hand, the "Payment Systems Act" enacted in 2017 provides a legal framework for the payment aspects of RWA. This act came into effect on April 16, 2018, establishing a regulatory framework for Thailand's electronic payment sector, aiming to align regulation with international standards and ensure the efficiency, security, and public confidence of payment systems. According to the act, electronic payment businesses are divided into two categories: payment systems and payment services, and companies providing such services must obtain licenses or register. The act supports the Thai government's implementation of the "National Electronic Payment Master Plan," encouraging the use of electronic payment methods such as PromptPay, electronic data capture, and QR codes, which create favorable conditions for the application of RWA in payment scenarios.
(3) Access, Compliance, and Enforcement
In terms of compliance access, Thailand has set tiered capital requirements. According to the regulations, digital asset exchanges must have a minimum paid-up capital of 50 million Baht, digital asset brokers at least 25 million Baht, digital asset dealers at least 5 million Baht, and digital asset fund managers must have between 10 million to 25 million Baht depending on the type of service provided. This differentiated requirement reflects the Thai regulatory authorities' precise understanding of the risk characteristics of various businesses.
For violations, Thai regulatory authorities have established clear penalties. Non-compliance with Thailand's digital asset regulations may result in administrative fines of up to 5 million Baht (approximately $144,500), imprisonment for up to one year, or fines not exceeding 1 million Baht (approximately $28,900), or both. The lawsuit against OKX by the Thai Securities and Exchange Commission exemplifies the rigidity of its enforcement, as the lawsuit accused OKX of conducting digital asset business in Thailand without obtaining the necessary licenses and failing to implement adequate investor protection measures, including inadequate customer identification and anti-money laundering protocols.
3. Diversified Practices and Data Validation of RWA in Thailand
Thailand's practices in the RWA field exhibit diversification, with progress made in various areas from sovereign bonds to tourism payments and traditional asset tokenization.
Sovereign asset tokenization is Thailand's most prominent achievement. In 2025, the Thai Ministry of Finance successfully issued the world's first publicly offered tokenized government bond, G-Token, with a scale of 5 billion Baht, and listed it on licensed digital asset exchanges such as KuCoin Thailand. This innovative initiative leverages blockchain technology to enhance transaction transparency and operational efficiency while lowering the participation threshold for retail and institutional investors. The bond is offered in collaboration with institutions such as KuCoin and XSpring Digital, which provide subscription, redemption, and secondary market trading services. According to data disclosed by KuCoin Thailand within a week of issuance, the bond was oversubscribed, with a significant proportion of retail investors, confirming its design intention of "lowering the participation threshold." This not only strengthens the attractiveness of Thailand's capital market but also establishes its leading position in the global RWA tokenization practice.
In terms of innovation in tourism payment scenarios, Thailand launched the "TouristDigiPay" program targeting the tourism industry. This project is chaired by Thailand's Deputy Prime Minister and Minister of Finance Pichai Chunhavajira and is jointly promoted by multiple departments, including the Ministry of Finance and the SEC. According to the regulations, interested digital asset operators can submit applications within a specific time frame, and participants must collaborate with electronic money business operators. The program requires operators to convert cryptocurrency into Thai Baht at market exchange rates and settle with merchants in near real-time when tourists make payments, all within a regulated framework to ensure fund security and compliance. This design not only enhances payment convenience but also effectively anchors and transforms digital assets into real-world purchasing power, serving as a typical example of the RWA model. Considering that according to data released by the Tourism Authority of Thailand (TAT), Thailand received 35.54 million foreign tourists in 2024, a year-on-year increase of 26.27%, but still not recovering to pre-pandemic levels, this move can be understood as Thailand's attempt to seek breakthroughs in a fiercely competitive tourism market.
Traditional asset tokenization is also an important component of Thailand's RWA ecosystem. Traditional banks in Thailand are exploring the conversion of conventional assets such as bonds, real estate, and stocks into blockchain-tradable digital assets. However, this area faces more legal and technical obstacles. Particularly in real estate tokenization, it must overcome the restrictions of Thailand's "Foreign Business Act" on foreign investment and issues related to asset ownership registration. For small and medium-sized enterprises seeking financing, while tokenization is expected to enhance asset liquidity, its large-scale promotion remains questionable in the absence of clear legal guidance.
From a market structure perspective, Thailand's digital asset market is undergoing a shift from retail-led to institution-led. The Thai Securities and Exchange Commission proposed new regulations on October 9, 2024, allowing institutional mutual funds and private equity funds to invest in crypto products, similar to the U.S. spot crypto ETFs. The CEO of Binance Thailand pointed out that this not only legitimizes Bitcoin but also creates a mature ecosystem for the coexistence of traditional finance and crypto assets. This shift indicates that Thailand's RWA market may exhibit more institutional and professional characteristics in the future.
4. Challenges and Compliance Risks in Thailand's RWA Development
Despite significant progress in the RWA field, Thailand's development still faces multiple challenges and compliance risks.
First, the insufficient adaptability of traditional laws is a core obstacle. This challenge is particularly prominent in real estate tokenization. Thailand's "Land Act" requires that the transfer of real estate rights must be registered with the land department to be effective, while transaction records on the blockchain currently do not have equivalent legal validity. At the same time, the "Foreign Business Act" restricts foreign ownership of Thai land rights, making it exceptionally complex to sell property rights to global investors through tokenization, necessitating specialized legislation to break through the "digital assets representing physical asset rights" issue.
Second, the uncertainty of tax policies suppresses long-term capital investment. The uncertainty in Thailand's tax policies is a clear shortcoming compared to competitors like Singapore and the UAE. Singapore exempts long-term holdings of crypto assets from capital gains tax, while the UAE implements a zero tax rate in specific areas, whereas Thailand still relies on traditional tax interpretations, which may lead to risks of double taxation or unclear tax burdens in token issuance, trading, and staking. This uncertainty directly affects institutional investors, especially in their long-term capital allocation decisions.
Furthermore, cross-border regulatory coordination is another major challenge. Although Thailand has strengthened its control over foreign platforms through "long-arm jurisdiction" clauses, it is still in the early stages of regulatory coordination with other Southeast Asian countries (such as Singapore and Malaysia). For example, an RWA project approved in Singapore must fully comply with Thailand's SEC ICO regulations to sell to Thai residents, which is a complex process. Establishing regional regulatory mutual recognition or "passport" systems will be key to reducing compliance costs and promoting market liquidity, but this relies on higher-level international cooperation.
Finally, the coexistence of insufficient market liquidity and high compliance costs is a concern. Although sovereign projects like G-Token have attracted market attention, the capacity of Thailand's domestic digital asset market is relatively limited. For small and medium-sized innovative enterprises, meeting tiered capital requirements (such as the 50 million Baht paid-up capital for exchanges) and complex compliance processes (such as AMLO's face-to-face verification) constitute high entry barriers, which may suppress the diversity and innovative vitality of the ecosystem.
5. Horizontal International Comparison of Thailand's RWA Policies
According to the "Six-Dimensional RWA Policy Research Framework" published by China Galaxy Securities Co., Ltd., countries and regions worldwide can be divided into two main paths in RWA regulation: "strong regulation, safety first" and "innovation-oriented, pilot first." Within this framework, Thailand exhibits a unique hybrid characteristic — demonstrating an innovation orientation in areas such as sovereign asset tokenization while adhering to strict regulatory principles in cross-border regulation and platform access.
Compared to "safety-first" countries like the United States, the United Kingdom, and Japan, Thailand maintains relatively tight policy constraints in regulatory intensity but is more flexible. The U.S. insists on the application of securities laws to tokenized assets, with the SEC clearly requiring RWA issuances to be registered or exempted, with restricted circulation and complex platform operating license requirements. While Thailand also adheres to licensing management, it demonstrates greater practical flexibility through official projects like G-Token. Japan, although having a clear legal system for tokenized securities, maintains high tax rates for individual investors in the tax system, only gradually introducing a separate taxation reform to reduce it to a moderate level of 20% starting in 2025. Thailand has yet to form clear policies regarding RWA in taxation, and this uncertainty may affect long-term capital allocation willingness.
In comparison to "innovation-oriented" countries like Singapore and the UAE, Thailand appears slightly conservative in regulatory freedom. Singapore promotes multi-type RWA assets for on-chain settlement and cross-platform trading through "Project Guardian," implementing new stablecoin regulatory rules with clear rights and high adaptability. The UAE has established a zero capital gains tax system to create a low-cost experimental platform. Although Thailand has launched sandbox projects like TouristDigiPay, it still lags behind Singapore and the UAE in tax system optimization and the breadth of regulatory sandboxes. However, Thailand's direct participation in the tokenization of sovereign assets has created a unique market appeal.
Compared to regions like the EU and Hong Kong, which adopt a "compromise model," Thailand's regulatory logic is the closest. The EU gradually achieves standardized regulation through MiCA and DLT experimental systems while maintaining compliance consistency within the region; Hong Kong supports innovation in terms of tax systems, rights confirmation, and stablecoin pathways, but still maintains high-intensity control over licensing thresholds and circulation restrictions, reflecting an "open + strict access" compromise model. Thailand's regulatory style is particularly similar to that of Hong Kong, as both emphasize the principle of "licensing first, compliance prudently," whether it is the dual licensing regulation for virtual asset trading platforms or the ongoing promotion of a stablecoin issuance system. The core of their policies is to extend existing securities and payment regulatory logic to manage new asset forms.
From the global RWA regulatory landscape, Thailand has established a specific influence in Southeast Asia due to its pioneering advantage in sovereign tokenization. However, compared to regions like the EU, South Korea, and Hong Kong, which have built compliance frameworks for RWA, Thailand still has gaps in institutional systematization, legal clarity, and market predictability. While these regions maintain a prudent regulatory intensity, they have completed or are close to completing the reconstruction of regulatory structures for RWA assets, ensuring that key aspects such as token issuance, rights confirmation, circulation, and custody are governed by clear rules.
6. Rational Outlook on Thailand's RWA Compliance Prospects
Thailand's RWA compliance ecosystem presents a unique development path between shortcomings and achievements. From a policy trend perspective, the Thai government is gradually improving digital financial infrastructure through measures such as the issuance of virtual bank licenses and sustainable disclosure roadmaps. According to the Bank of Thailand's plan, the first batch of virtual banks will be approved to provide services in 2025, which is expected to promote competition, broaden lending channels, and reduce financing costs for businesses and individuals. At the same time, Thailand follows international trends in sustainable disclosure, gradually adopting ISSB standards, which raise higher requirements for the transparency and credibility of RWA products.
For market participants, operating within Thailand's RWA ecosystem requires adherence to the following principles: foreign platforms should carefully assess the "long-arm jurisdiction" clause; if they meet the characteristics of serving Thai users, they should apply for a license in advance to avoid litigation risks similar to those faced by OKX; investors should pay attention to sovereign asset models like G-Token, which have higher legal certainty and regulatory support, while cautiously avoiding legal gray areas, especially in sensitive areas like nominee structures; local enterprises can leverage sandbox testing opportunities to gain experience in innovative projects like TouristDigiPay, but they should also develop exit mechanisms to address policy uncertainties after the pilot period ends.
Future Path and Regional Competitive Outlook
From a global competitive perspective, the advantages and limitations of Thailand's RWA development are equally evident. Its advantages lie in the demonstration effect of government-led projects, the natural application scenarios brought by the tourism industry, and a relatively clear licensing management system. Limitations are reflected in the insufficient adaptability of traditional laws, an unoptimized tax environment, and the need to test cross-border coordination capabilities. Whether Thailand can establish a leading position in Southeast Asia's RWA competition depends on its ability to maintain regulatory rigidity while providing sufficient innovative flexibility.
In summary, Thailand has gained a certain first-mover advantage in the RWA field through a path of "strict regulation through legislation + sandbox innovation." From G-Token to TouristDigiPay, Thailand has demonstrated different driving models of sovereign institutions and market demand in RWA development. However, compliance costs and legal connections remain key factors determining the success or failure of Thailand's RWA. If Thailand can further clarify tax policies, improve the rights confirmation mechanism for traditional assets on-chain, and strengthen cross-border regulatory cooperation, it is expected to play a more important role in the regional RWA ecosystem. Conversely, if legal uncertainties persist and market liquidity remains insufficient for an extended period, current innovations may remain superficial and fail to achieve substantial industrial breakthroughs.
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