Nominee Owners Under Scrutiny: Company Checks in 2026

New information has emerged on company checks in the crackdown on nominee owners in Thailand. According to MGR Online, the Department of Business Development has singled out a nominee-ownership risk group and sent summonses for explanations to companies, with some already submitting documents and others asking for extra time to respond. For business and property owners, the key difference here is between suspicion and proven violation: a company being placed in a risk group does not in itself establish its guilt, and targeted summonses relate to the check described and do not mean a new mandatory procedure for all Thai companies with foreign shareholders or for every foreign owner of property.

Current as of publication.

What is known

The MGR Online report was published on November 7, 2026. This is the publication date, not a confirmed date for the checks.

According to the report, 84 companies are involved in the check. Of them, 36 were placed in the nominee-ownership risk group and 2 more in the group for foreigners doing business without a license. The Department sent summonses for explanations to 38 companies from these groups.

As of the report:

• 7 companies submitted explanations and documents;
• 20 companies asked to extend the deadline for explanations by 1 month;
• 11 companies have not yet submitted documents.

A request for an extension does not mean an extension has been granted. The report also states that foreign participation in the companies in the nominee-ownership risk group is less than 50%. This share alone does not prove a violation.

Crackdown on nominee owners: land and financial checks

To assess your situation, it helps to distinguish rights to land, a building and an apartment; this is covered in the article “property laws in Thailand”. New information about companies and earlier land statistics relate to different groups of data.

Earlier, at a press conference on October 19, 2026, the prime minister reported 1,397 legal entities suspected of holding land on behalf of foreigners. They hold 2,360 plots with an estimated value of about 14.01 billion baht, according to a statement from the Public Relations Department.

Completing investigations by December 2026 is named as a priority for the authorities. This is the agencies’ work plan; it does not set a deadline for owners to submit documents. The estimated value of the plots does not mean the amount that will ultimately be confiscated.

Separately in the official description of the interagency operation, it is stated that more than 10 agencies took part, 3 target sites were searched, and financial flows and taxes were checked. This operation is not equated with the new group of companies.

How company document checks have changed

The Nation reported that from August 1, 2026, measures were introduced requiring Thai shareholders and directors to provide bank statements to check the movement of money and the reality of investments. This report does not establish a universal group of obligated companies or a single period for bank statements.

According to a legal review published by the Australian-Thai Chamber of Commerce, the order of the Central Office for the Registration of Partnerships and Companies took effect on August 1, 2026, consolidating and replacing earlier measures of the Department of Business Development. Information about the order is presented here based on that review.

The law firm Herbert Smith Freehills Kramer notes that additional documents depend on the circumstances. Examples include bank statements, explanations of the source of funds, and confirmations that no nominee arrangements exist.

Put simply, the focus is on whether investments are real. A single shareholder entry does not explain the origin of their funds.

What to do

If you have received a request, discuss its contents with an independent Thai lawyer. For guidance, see the article on choosing a lawyer when buying property.

Prepare questions for the consultation:

• Do the documents match the actual ownership structure?
• What confirms the shareholders’ investments and payment for shares?
• How is the movement of funds recorded?
• Who receives the ultimate benefit?
• What rights are registered for the land, building or apartment?
• Are bank statements and explanations of the source of funds needed, for what period, and in relation to which request?

This is preparation for a conversation with a lawyer. As Herbert Smith Freehills Kramer notes, the set of additional documents depends on the circumstances; this list of questions does not establish a mandatory set of documents required by the government.

Do not automatically change shareholders or re-register property without assessing the circumstances. First, understand the request and the actual ownership structure.

This article does not replace legal advice. Requirements may change; whether the measures apply to your situation should be checked against official guidance and with an independent Thai lawyer.