Thailand’s tourism sector is advancing into the digital era with the launch of TouristDigiPay, a regulatory sandbox initiative that allows foreign tourists to top up e-money wallets with various assets, including cryptocurrencies, other digital or tokenized assets, and traditional assets such as cash or possibly via telegraphic transfers (TT), converting them into Thai Baht for seamless electronic payments utilizing Thailand’s widespread QR payment scheme.
Announced on 18 August, 2025, by the Securities and Exchange Commission (SEC) Thailand, in collaboration with the Ministry of Finance, the Anti-Money Laundering Office (AMLO), and the Ministry of Tourism and Sports, this 18-month pilot project is subject to stringent Know Your Customer (KYC) and Anti-Money Laundrering Office (AMLO) regulations to ensure compliance with existing financial requirements by the BoT. The program attracts a broad range of tourists, including digital nomads, potentially holders of the Destination Thailand Visa (DTV), and all visitors seeking convenient payment options, with potential for broader rollout to other visitor categories in the future, enhancing access to Thailand’s QR payment and providing infrastructure for all tourists, who were previously excluded from such convenience.
What is TouristDigiPay?
TouristDigiPay is an innovative initiative designed to provide foreign tourists with an e-wallet for visiting Thailand, enabling them to top up e-money wallets with various assets, such as cash, cryptocurrencies (e.g., Bitcoin, Ethereum), which are then converted into Thai Baht for electronic payments using the QR code-based transactions that are widely accepted across Thailand. The program operates under a regulatory sandbox overseen by the SEC Thailand and the Bank of Thailand (BoT), ensuring strict compliance with financial regulations. It does not permit direct payments with assets or cash; instead, funds are converted into Baht and held in e-money wallets for spending at merchants nationwide, from large retailers to small vendors.
With a trial period of 18 months starting in Q4 2025, TouristDigiPay aims to enhance Thailand’s competitiveness as a global tourism and digital finance hub by catering to all tourists, including those using traditional payment methods like cash or TT, digital nomads, and DTV visa holders, with the potential to expand to other visitor categories.
How TouristDigiPay Works
TouristDigiPay enables foreign tourists to deposit funds from various sources, whether traditional finance or crypto, into accounts managed by SEC-licensed asset operators (for digital or tokenized assets) or BOT-regulated financial institutions (for traditional instruments like cash or TT). It is not certain if the same provider could take both traditional and crypto at this point. These assets are converted into Thai Baht at market rates and credited to a BOT-regulated e-money wallet for use in electronic payments. The process includes:
- Fund Deposit: Tourists can deposit cryptocurrencies, tokenized assets, cash, or funds via TT. Digital assets are transferred to the operator’s platform and verified. Cash deposits may be made through partnered banks or authorized agents (e.g., 7-Eleven counters), while TTs are processed via bank accounts, subject to standard banking verification.
- Conversion to Baht: Assets or funds are converted into Thai Baht through licensed operators or banks, with funds credited to a linked e-money wallet.
- Payment Usage: Tourists use the e-money wallet for payments via QR code scans or other electronic methods at merchants across Thailand, facilitated by payment gateways like PromptPay. Direct payments with assets or cash are prohibited; only Baht from the e-money wallet is accepted.
- Spending Limits: Monthly caps are set at 50,000 THB (≈$1,429) for transactions at small retail merchants and 500,000 THB (≈$14,286) for transactions at merchants with card terminals (e.g., hotels, restaurants). These limits apply at the vendor level, meaning they restrict the amount a tourist can spend per month at each type of merchant, not the total spending across all vendors.
For example, a tourist could spend up to 50,000 THB at one small merchant and another 50,000 THB at a different small merchant, and up to 500,000 THB at a hotel, within the respective vendor categories.
This process ensures accessibility for all tourists, by integrating with Thailand’s widely adopted QR payment system that is available everywhere from high end retailers to street-stalls, making it convenient for both tech-savvy and traditional travelers.
Expected Providers for TouristDigiPay
While the SEC and BOT have not yet released a definitive list of providers, TouristDigiPay requires participation from SEC-licensed asset operators for digital assets and BOT-regulated banks or e-money providers for both digital and traditional financial instruments like cash or TT. PromptPay, as a payment gateway, facilitates the QR transactions but is not an end-user provider; instead, traditional banks and e-money platforms are expected to serve as the primary interfaces for tourists. Based on our knowledge of Thailand’s financial ecosystem, several providers are expected to participate:
Digital Asset Operators
- Gulf Binance: The local entity for Binance, one of the leading global exchanges, Binance is a leading SEC-licensed cryptocurrency platform and a likely candidate due to its robust infrastructure and support for Thailand’s crypto initiatives, as noted by its CEO, Nirun Fuwattananukul.
- Bitkub: Thailand’s largest crypto exchange, Bitkub is SEC-licensed and well-positioned to handle digital asset-to-Baht conversions.
- Satang: An SEC-regulated exchange, Satang could support tourists’ digital asset deposits.
- Upbit Thailand: With its focus on secure transactions, this regulated platform is another potential participant, and like the others listed above already provides a crypto “off-ramp” to KYC verified users.
Traditional Banks
- SCB (Siam Commercial Bank): SCBX, through its fintech arm SCB 10X, is a key player in Thailand’s digital finance landscape. SCB 10X’s Rubie Wallet, tested during the Ethereum Foundation’s Devcon 2024 in Bangkok (November 5–25, 2024), converts USD-pegged stablecoins to THBX (Thai Baht stablecoin) for QR payments via PromptPay. Developed under a BOT and SEC sandbox with partners like InnovestX, Fireblocks, Elliptic, Circle, and Base, SCBX is highly likely to participate in TouristDigiPay, potentially extending Rubie Wallet to support digital assets, cash, or TT for all tourists. SCBX’s banking infrastructure also supports cash deposits and TT processing.
- Kasikornbank (KBank): KBank’s TAGTHAi Easy Pay e-wallet supports QR payments via the Prepaid PAY&TOUR card for international tourists, currently handling traditional currency top-ups. KBank is well-positioned to integrate with TouristDigiPay to accept cash, TT, or digital assets, leveraging its PromptPay-enabled infrastructure.
- Krungthai Bank: With a virtual banking license and partnerships with AIS and PTT Group, Krungthai could offer e-wallet services, supporting cash, TT, or asset-based top-ups through its PromptPay integration.
- Bangkok Bank: A major bank with strong mobile banking and PromptPay integration, Bangkok Bank could participate, handling cash or TT top-ups alongside digital assets.
- Other Commercial Banks: Banks like TMBThanachart, UOB Thailand, or Krungsri, with PromptPay and mobile banking capabilities, may join if partnered with SEC-licensed operators or equipped to handle cash/TT deposits.
E-Money Providers
- TrueMoney: A BOT-regulated e-money provider, TrueMoney is widely used for QR payments via PromptPay and is a strong contender for integration with TouristDigiPay, potentially handling cash deposits at retail points like 7-Eleven.
- ShopeePay: Operated by SeaMoney, ShopeePay is a BOT-regulated platform with broad merchant acceptance and PromptPay integration.
- Rabbit LINE Pay: This e-money platform, popular for QR payments via PromptPay, may also participate.
Role of PromptPay and Inclusivity for All Tourists
PromptPay serves as a payment gateway facilitating QR transactions. Traditional banks like SCBX, KBank, and others, along with e-money platforms, will act as the primary providers, offering e-wallets that support digital assets, cash (via branches, ATMs, or agents like 7-Eleven), and TT (via international bank transfers).
This ensures the e-wallet is accessible to all tourists aligning with Thailand’s goal of enhancing payment convenience. The BOT’s planned “Tourist Wallet” is expected to streamline these top-up options, integrating both modern and traditional methods.
Pre-consultation with operators began in August 2025, and the SEC and BOT are expected to announce confirmed providers closer to the Q4 2025 launch.
Documentary Requirements for TouristDigiPay
Participation in TouristDigiPay requires compliance with stringent Know Your Customer (KYC) and Customer Due Diligence (CDD) requirements, as mandated by AMLO and aligned with global anti-money laundering (AML) and counter-terrorism financing (CFT) standards. Below are the key documentary requirements.
For Foreign Tourists
Identity Verification Documents:
- Valid Passport: A government-issued passport is required to verify the tourist’s identity and confirm their status as a non-resident visitor.
- Proof of Temporary Residence: Documents such as a visa (including the DTV) or entry stamp may be required to verify the tourist’s temporary stay, as the program is initially exclusive to foreign tourists, as well as a hotel booking or potentially other verification of address.
- Asset or Fund Source Information: For digital or tokenized assets, tourists must disclose the source wallet address, verified using blockchain forensic tools. For cash or TT, proof of funds (e.g., bank statements, TT receipts, or cash deposit confirmations) may be required.
Account Setup with Regulated Providers:
- Tourists must register with an SEC-licensed asset operator (for digital/tokenized assets) and/or a BOT-regulated bank or e-money provider (for cash/TT), submitting personal details and identity documents during onboarding.
- The e-money account must be linked to the same name as the asset or funding account to ensure traceability.
Declaration of Asset or Fund Source:
- Tourists must provide information on the origin of their deposited assets or funds, such as transaction histories, proof of acquisition (e.g., exchange records, token issuance documents, bank statements, or TT receipts), to comply with AMLO’s AML/CFT guidelines.
Spending Limits Acknowledgment:
- Tourists must acknowledge monthly spending caps (50,000 THB for small merchants, 500,000 THB for larger merchants) at the vendor level during account setup, though no separate document is required.
For Asset Operators, Banks, and E-Money Providers
Licensing and Partnership Documentation:
- Operators must hold a valid SEC license for digital/tokenized assets or a BOT license for banking/e-money services and provide proof of good standing.
- A partnership agreement between asset operators, banks, or e-money providers is required, detailing integration for asset-to-Baht conversions or cash/TT processing.
AML/CFT Compliance Framework:
- Operators and banks must submit an AML/CFT policy, including KYC/CDD procedures, transaction monitoring, and blockchain forensic tools (for digital assets) or equivalent verification methods (for cash/TT).
- Transactions exceeding 450,000 THB require a detailed report to the SEC or BOT, including the purpose and supporting documentation.
Exit Strategy Plan:
- Operators and banks must provide a plan for winding down services at the end of the 18-month sandbox, ensuring consumer funds are protected.
Application for Sandbox Participation:
- Businesses must submit an application to the SEC or BOT, including operational plans, risk management protocols, and proof of compliance with capital requirements, with reviews completed within 60 days.
Regulatory Framework and Safeguards
TouristDigiPay operates within a tightly controlled regulatory sandbox to balance innovation with consumer protection. Key safeguards include:
- Prohibition on Direct Payments: Assets or cash cannot be used directly; only converted Baht in e-money wallets is accepted.
- Spending Limits: Vendor-level caps of 50,000 THB for small merchants and 500,000 THB for larger merchants prevent misuse.
- No Cash Withdrawals: Cash withdrawals from e-money accounts are prohibited until account closure to reduce AML risks.
- Transaction Restrictions: High-risk businesses, as identified by AMLO, are excluded from accepting payments.
- Verification: Operators and banks must use blockchain forensics for digital assets or equivalent methods for cash/TT, with mandatory reporting to AMLO and the SEC/BOT.
The SEC has introduced exemptions, such as waiving suitability/knowledge tests for tourists and modifying advertising rules.
Challenges and Opportunities
TouristDigiPay presents significant opportunities but also faces challenges:
- Usability Hurdles: The KYC process and QR payments may deter less tech-savvy tourists. Multilingual support and simplified onboarding could help.
- Privacy Concerns: Stringent KYC/AML requirements may raise privacy issues, as noted in online discussions.
- Market Potential: By supporting digital assets, cash, and TT for QR payments via PromptPay, the program attracts all tourists, including digital nomads, DTV visa holders, and traditional travelers, with potential for broader rollout, boosting tourism revenue.
For businesses, participating in the sandbox offers a first-mover advantage, allowing operators and banks to tap into a growing market.
Conclusion
Thailand’s TouristDigiPay initiative is a groundbreaking step toward integrating digital assets, cash, and telegraphic transfers into the tourism economy, offering all foreign tourists, including digital nomads, DTV visa holders, and traditional travelers, a secure and regulated e-wallet for visiting Thailand. By topping up with various assets or funds for QR-based payments in Thai Baht via PromptPay, the program enhances accessibility to Thailand’s payment infrastructure. Compliance with KYC/CDD requirements, including passport verification, proof of temporary residence, and asset or fund source documentation, is non-negotiable due to stringent AMLO regulations. Traditional banks like SCBX, with Rubie Wallet experience, and others like KBank are poised to play a key role, alongside digital asset operators like Gulf Binance, the local entity for Binance. By understanding these requirements and leveraging the scheme’s opportunities, stakeholders can position themselves at the forefront of Thailand’s digital finance revolution.
It will be interesting to see how the no-cash withdrawals stipulation will work as when tourists leave, they will be expecting to be able to redeem unused funds.
For guidance on navigating the TouristDigiPay sandbox or ensuring compliance with SEC Thailand regulations, contact FOSRLaw’s expert team today.
