Five Cabinet Decisions That May Affect Your Thailand Operations

Cabinet meeting of 12 May 2026 — what corporate, trade, and financial-services clients should review now

1. Your services centre may no longer need Foreign Business approval. 

The Cabinet approved a Ministerial Regulation exempting eight categories of business from Foreign Business Committee approval, including telecommunications, financial-centre operations, personnel and IT management services, and domestic debt collection. Thai entities currently sitting under BOI promotion or a Foreign Business Licence solely to operate in one of these categories may be eligible to restructure into a simpler vehicle once the regulation is published in the Royal Gazette. The firm has advised clients on the Foreign Business Act framework since the Act's enactment in 1999; we will publish a structural-implications note once the final regulation is gazetted.

2. Foreign ownership of capital-markets services is opening. 

Within the same package, four exemptions cover the financial sector: custodian services, securities lending, securities-secured lending, and futures contract agency or advisory. This is the broadest financial-sector FBA exemption package since the 2008 capital-markets reforms. Foreign-controlled banks, asset managers, and securities operators that have structured around these activities should reassess.

3. Your ASEAN-Japan certificates of origin require re-verification. 

The Cabinet approved Thailand's signature of the amended Annex 2 to the ASEAN-Japan Comprehensive Economic Partnership, updating Product-Specific Rules of Origin from HS 2017 to HS 2022. The update covers 5,612 product categories with 371 new PSRs. Joint endorsement by the ASEAN-Japan parties is scheduled for 15 May 2026, with implementation following. Exporters using AJCEP preferences should verify that their certificates classify under the new HS 2022 schedule.

4. Agricultural commodity futures trading is being unblocked. 

A companion Royal Decree exempts forward agricultural commodity trading and the related Thai-side delivery of agricultural goods from the Foreign Business Act's List Three restrictions. Groups sourcing or selling agricultural commodities through Thailand, including via the Agricultural Futures Exchange of Thailand, will see structuring options expand once the Royal Decree publishes.

5. The U.S. tariff pause expires in September. 

Thailand's February 2026 exports rose 9.9% year-on-year to USD 29.4 billion, with electronics and AI-related upgrades leading the recovery. The Ministry of Commerce continues to monitor the U.S. Reciprocal Tariff environment, with the 150-day pause expiring in September 2026. Exporters reliant on the U.S. market should plan tariff re-escalation scenarios over the next four months.

Where we can help.

For clients reviewing whether existing Thai structures remain optimal under the Foreign Business Act reform or the ASEAN-Japan update, our partners are happy to schedule a thirty-minute strategy call. Our corporate practice has tracked the Foreign Business Act framework through every amendment since 1999, and works across the partnership on both structural restructuring and trade-compliance questions.

Sources: Cabinet Resolution dated 12 May 2026; Royal Gazette publication pending