Thailand's Digital Compliance Trail: How TDAC, TM.30 and 90-Day Reporting Now Connect

For many years, a foreign employee's compliance records in Thailand existed in three separate places. The arrival card was held at the port of entry. The TM.30 notification of residence, where filed, was held at the local immigration office. The 90-day report was held elsewhere again. The three records were rarely compared, and an omission in one seldom affected the others.

โดย Narut Siriphattrasophon, Suwanan Chongcharoen·13 สิงหาคม 2569·ใช้เวลาอ่าน 4 นาที

The arrival record is now digital. 

Since 1 May 2025, every foreign national entering Thailand by air, land or sea has been required to submit the Thailand Digital Arrival Card (TDAC) online prior to arrival, in place of the paper TM.6. Submission opens three days before entry and is free of charge on the official government site, a point employers are advised to communicate to travelling staff, as unofficial third-party sites charging fees are common. Since June 2026, the official THIM application permits submission by mobile telephone. The legal duty derives from Section 18 of the Immigration Act B.E. 2522 (1979), read with the 2025 announcements that withdrew the former paper arrangements. The significant development is that the arrival record is now created digitally, is current, and is available to the authorities on demand.

The residence notification is enforced in practice. 

Section 38 of the Act has always required the possessor of premises to notify immigration within twenty-four hours of a foreign national taking up residence. The statutory fine is modest. The operative sanction today is procedural: immigration offices expect the TM.30 record to be in place before processing the matters that concern the foreign national. Since 14 May 2025, visa and work permit applications for BOI-promoted companies must be accompanied by the TM.30 receipt. In practice, an extension application without a corresponding TM.30 record is not refused; it does not proceed until the record is completed and the fine discharged.

The 90-day report verifies both. 

Section 37(5) of the Act requires a foreign national remaining in the Kingdom beyond ninety consecutive days to report their address at ninety-day intervals. The online reporting channel operates only where the underlying records are in order: it rejects submissions made outside the prescribed fifteen-day window, after the due date, or where the address on file does not correspond with the TM.30 record. A rejected or late report cannot be remedied online. It requires attendance in person and payment of a fine of THB 2,000, or up to THB 5,000 where the matter has proceeded to arrest.

The direction of policy. 

The government has stated its intention to connect these databases. The Cabinet materials accompanying the July 2026 entry measures describe the TDAC as an instrument of screening and verification, and record the continuing effort to link the relevant agencies' systems. It would be inaccurate to describe the present arrangement as a single integrated system; the integration is progressing rather than complete. Employers would nonetheless be prudent to plan on the basis that it will be completed, as the consequences of the existing connections are already apparent at the extension counter.

Two further enforcement matters complete the picture. The limit of two visa-exempt entries per calendar year at land borders is not a new rule; it dates from December 2016. What is new is its consistent enforcement, formalised in measures issued in November 2025. Overstay, in addition to the familiar fine of THB 500 per day capped at THB 20,000, carries automatic re-entry bans that increase with the duration of the overstay, from one year to ten.

Recommendations for employers.

 The three records should be treated as a single file, as the authorities now treat them. Where an employee changes residence, the TM.30 should be refiled before any other application is attempted. The compliance calendar should track 90-day reporting dates alongside visa dates, with reports filed within the prescribed window, online where the records are consistent and in person where they are not. Employers should confirm which of their personnel report at the One Stop Service Center, which relocated to One Bangkok in March 2025, and which report at their local immigration office. Finally, when the revised visa-exemption rules presently awaiting publication in the Royal Gazette take effect, the compliance trail should be expected to begin at the border rather than at the first extension.

None of these obligations is onerous. They are, however, no longer forgiving of inattention. A file that is correct at the outset proceeds without difficulty; a file with a gap does not proceed at all. In our experience, the employers who encounter difficulty under the present arrangements are not those with genuine problems, but those whose records lacked a single responsible owner. Assigned that owner, the compliance trail becomes an asset: contemporaneous proof, available on demand, that the company's personnel are precisely where they are permitted to be.

Disclaimer: This publication is intended for general informational purposes only and does not constitute legal advice. The information contained herein should not be relied upon as a substitute for specific legal counsel. For advice tailored to your circumstances, please contact Dej-Udom & Associates directly.

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