Draft BNPL rules cap credit at 20,000 baht and costs at 15%

Buy now, pay later (BNPL) accounts in Thailand grew from about 600,000 in 2021 to almost 5 million in 2024, according to central bank data cited in a Bangkok Bank Bnomics column. Now the credit a shopper can use may be capped at 20,000 baht.

Thailand's Finance Ministry and the Bank of Thailand (BOT) are taking comments on draft BNPL rules from 16 October to 15 November 2026. The draft lets each lender, or all lenders in one business group combined, give a shopper up to 20,000 baht, with up to six months to repay each purchase.

Interest and all fees together may not exceed 15% a year, and none of the rules is in force yet.

SV News sums up what the draft changes for people who pay in instalments in apps, for sellers and for lenders, and how to comment before the hearing closes.

A 20,000-baht limit, six months to repay and a 15% cost cap

The hearing holds two drafts: one makes BNPL a licensed business, and the other sets the operating rules.

The first is a Finance Ministry notice under Revolutionary Council Announcement No. 58, and the second is a BOT notice, according to the BOT hearing document. The BOT notice sets out the following:

• Credit limit: each lender may give each shopper up to 20,000 baht in total. If a business group has several lenders, credit from the whole group combined must stay within that limit, but credit from lenders outside the group does not count.
• Repayment term: each purchase must be repaid within six months.
• Total cost: interest, penalties, charges, service fees and other fees together may not exceed an effective rate of 15% a year. That includes fees charged by partners and any higher price for choosing to pay in instalments.
• Paying off early: no fee is allowed. After a missed payment, though, lenders can still add collection costs and default interest.
• Borrowers: they must be 20 or older, and lenders may use alternative data instead of proof of income to judge whether they can repay.
• No cash: the credit cannot be withdrawn, transferred or turned into cash or e-money, and lenders must have controls to stop shoppers repaying BNPL with credit cards or other loans.

Put simply, if the instalment price is higher than the full price, the extra counts as part of the cost of borrowing and must fit inside the 15% cap.

The BOT says the cap should not raise costs much for customers of lenders already charging within the Civil and Commercial Code's interest limit.

Checkout would default to paying in full

Shoppers and sellers would see the biggest change at checkout.

The draft's consumer protection annex, which Thansettakij also summarised, would require lenders to do five things:

• Default: set payment to a full, non-credit option, such as a bank account or debit card.
• Next bill: show the total BNPL amount due on the next bill, including this order, and ask the shopper to confirm.
• Itemised price: show the price, delivery, interest, fees and discounts separately.
• No pressure: drop countdown timers and repeated prompts that push people to take credit.
• Higher limits: raise a credit limit only when the shopper opts in.

Lenders also could not block a borrower from a platform, or cut other benefits, to collect a debt.

Lalida Persvivatana, a deputy government spokeswoman, said people "must understand the costs and debt obligations before choosing to pay in instalments", because several small instalments at once can add up to more than they can afford, Thai PBS and the Bangkok Post reported.

The rules cover BNPL on large marketplaces

The draft applies to marketplace platforms under three tests.

• Transactions: more than 100 million baht a year in transactions from services in Thailand.
• Users: users in Thailand above 5% of the population, based on average monthly use.
• Related platforms: if a marketplace meets either test above, platforms in the same company or business group count too.

Business-to-business (B2B) platforms are excluded, and so is a shop's own website that sells only its own goods. A platform that has met the tests stays in scope even if its numbers later fall. The draft names no platform.

Compare that with the 2022 royal decree on digital platforms enforced by the Electronic Transactions Development Agency (ETDA). It treats a platform as large once users pass 10% of the population, or yearly revenue passes 300 million baht from one type of service or 1 billion baht from all services.

The BNPL test halves that user share and counts transaction value instead of revenue.

Lenders would need a licence and report to the credit bureau

Lenders and fintechs have several things to prepare.

An unlicensed BNPL lender would have 60 days after the rules take effect to apply to the Finance Minister through the BOT, and could keep trading while it waits. It would need paid-up capital of at least 50 million baht, with 180 days to top up if it falls short.

The BOT would also review a working first version of the product, known as an MVP, from the credit risk model to IT systems. Banks and finance companies would not need this licence, and firms already licensed for personal loans would count as licensed and only notify the BOT.

The BOT's operating rules would start 90 days after its notice takes effect, and membership of and reporting to the National Credit Bureau after 270 days. BNPL loans made before the rules take effect keep their terms until repaid.

One reason for the rules: some platform lenders are unsupervised and report no data to the BOT, the hearing document says. Meanwhile BNPL loans grew from 6.8 billion baht in 2021 to almost 18 billion baht in 2024, more than 2.5 times (Thansettakij).

In August 2026, Thansettakij reported from a briefing by a BOT senior director for model review and financial institution risk analysis that the central bank was worried about young people using BNPL for low-priced goods. The same report put household debt at 85.9% of GDP.

Comments close on 15 November, with rules expected this year

Anyone who wants to comment on the draft has until 15 November 2026.

Comments go through the BOT website or the central law portal. Thai PBS Policy Watch reported that the rules are expected to be issued within 2026, and the Finance Ministry draft is already dated November 2026, with only the day left blank.

The next thing to watch is publication in the Royal Gazette. Each notice takes effect the next day, which also starts the 60-day window for unlicensed lenders to apply.

FAQ

How much can a shopper borrow under the draft BNPL rules?

Up to 20,000 baht from any one lender, or from all BNPL lenders in one business group combined, with six months to repay each purchase. The draft does not make lenders count credit a shopper holds with providers outside the group.

Does the 15% cap include fees?

Yes. It covers interest and all fees, including partner fees and any higher price for paying in instalments. Collection costs and default interest may be added only after a missed payment.

Which platforms are covered?

Marketplace platforms with more than 100 million baht a year in transactions from services in Thailand, or average monthly users above 5% of the population, plus platforms in the same company or group. B2B platforms and a shop's own website that sells only its own goods are outside the draft.

When do the rules take effect?

Not yet. Comments close on 15 November 2026, and Thai PBS Policy Watch reported that the rules are expected to be issued within 2026. Each notice would take effect the day after Royal Gazette publication, with the BOT's operating rules applying 90 days later.

Sources

• Bank of Thailand: การเปิดรับฟังความคิดเห็นต่อแนวทางการกำกับดูแลธุรกิจสินเชื่อส่วนบุคคลซื้อก่อน จ่ายทีหลัง (BNPL)
• Bank of Thailand: เอกสารรับฟังความคิดเห็น แนวทางการกำกับดูแลธุรกิจสินเชื่อส่วนบุคคลซื้อก่อน จ่ายทีหลัง (PDF)
• Bangkok Post: Central bank seeks feedback on Buy Now, Pay Later rules
• Thai PBS: เปิดรับฟังความเห็นร่างเกณฑ์คุมสินเชื่อ "ซื้อก่อน จ่ายทีหลัง" ถึง 15 พ.ย.
• Thai PBS Policy Watch: จ่อคุม ซื้อก่อน ผ่อนทีหลัง รายละไม่เกิน 2 หมื่น ดอกเบี้ย 15%
• Thansettakij: เปิดเกณฑ์คุม 'ซื้อก่อนจ่ายทีหลัง' จำกัดวงเงิน 2 หมื่น ผ่อนไม่เกิน 6 เดือน
• Thansettakij: BNPL โตแรงในไทย 'ซื้อก่อน จ่ายทีหลัง' ทางออกหรือจุดเริ่มต้นหนี้ครัวเรือน?
• Thansettakij: ธปท.ถอดบทเรียน CLICX คุมเข้มสินเชื่อ จ่อจัดระเบียบ BNPL สกัดหนี้เสีย
• ETDA: Royal Decree on the Operation of Digital Platform Service Businesses That Are Subject to Prior Notification, B.E. 2565 (2022), English translation