Thai Private Credit: SRT and the Non-Bank Lending Build-Out

Questions this report answers

What changed in 2025? The Royal Decree of 5 June 2025 brought more than 3,000 non-bank vehicle hire-purchase and leasing operators under Bank of Thailand supervision via the Financial Institutions Business Act B.E. 2551 per Chambers and Partners. The framework took effect on 2 December 2025. Pre-2025, vehicle hire-purchase and leasing were excluded from specific consumer-finance regulation; the new framework formally extends BOT supervisory authority over a structurally large non-bank-lender population. The structural implication is significant: institutional-investor due-diligence on Thai non-bank lenders now has supervisory-disclosure to anchor on, and SRT-securitisation transparency improves materially.^{[1, 2]}

What's the non-bank lending universe? Per Norton Rose Fulbright and Statista: vehicle hire-purchase (largest segment, now BOT-supervised), personal loan (regulated by Ministry of Finance under BOT supervision; digital personal loan capped at THB 20K🔒 / 6-month tenure since BOT's September 2020 framework), peer-to-peer lending (BOT 2019 crowdlending regulations), BNPL (still emerging; not specifically regulated), and securities-backed lending (early 2025 SET signalled disclosure of pledged shares recorded in TSD). Major SET-listed operators include KTC, AEONTS, ASK, TISCO, SAWAD, MTC.^{[3, 5, 6]}

What's SRT and how does securitisation work in Thailand? Per Vinod Kothari Consultants: Special Rights Trust (SRT) is the dominant Thai securitisation vehicle for leasing receivables. SRT structure was historically accessible to entities not under BOT regulatory umbrella — leasing and hire-purchase companies — which explains why most Thai securitisation transactions historically came from these operators. Post-2 December 2025, the SRT-securitisation playbook will operate under tighter BOT-supervised transparency. Expect 2026 securitisation issuance volume to slow short-term as operators adjust to the new compliance regime; structural growth resumes once the regulatory regime stabilises.^{[4, 7]}

What are the security-interest mechanics? Per Thanathip and Partners and Baker McKenzie: Thai security interest framework includes mortgage (over real property), pledge (over movable property delivered to the secured party), and business-collateral (over receivables, inventory, and other business assets under the Business Security Act). Foreign-investor lenders face additional considerations under the Foreign Business Act B.E. 2542 and licensing-or-exemption requirements; Nishimura and Asahi's foreign-companies guide is the standard reference. Real-estate financing for foreign buyers and developers has additional restrictions per Lexology.^{[7, 10, 8, 9]}

Executive summary

Thai non-bank lending reached a structural regulatory inflection in 2025. The Royal Decree of 5 June 2025 brought more than 3,000 non-bank vehicle hire-purchase and leasing operators under Bank of Thailand supervision via the Financial Institutions Business Act B.E. 2551, effective 2 December 2025 per Chambers. Pre-2025, this large operator population was excluded from specific consumer-finance regulation; the new framework formally extends BOT supervisory authority and changes the institutional-investor due-diligence baseline.^{[1, 2]}

The non-bank-lending universe is structurally diverse. Vehicle hire-purchase is the largest segment (now BOT-supervised); personal loan operates under Ministry of Finance licensing with BOT supervision and includes the September 2020 digital-personal-loan framework (THB 20K🔒 cap / 6-month tenure / alternative-data underwriting); P2P / crowdlending operates under BOT's 2019 framework; BNPL is still emerging without specific regulation; securities-backed lending operates within SET pledged-share disclosure framework signalled in early 2025. Major SET-listed operators span KTC (credit cards), AEONTS (hire-purchase), ASK (vehicle leasing), TISCO (banking-and-leasing), SAWAD and MTC (title loans).^{[3, 5, 6]}

The Special Rights Trust (SRT) is the dominant Thai securitisation vehicle for leasing receivables per Vinod Kothari. Pre-2025, SRT-securitisation operated largely outside BOT supervisory eye because leasing and hire-purchase operators were not under BOT regulation. Post-2 December 2025, the SRT-securitisation playbook will operate with BOT-supervised transparency. The 2026 expectation is short-term issuance slowdown as operators adjust to compliance burden; structural growth resumes thereafter. For institutional foreign-investor private-credit funds, the new framework actually improves due-diligence quality; for existing securitisation issuers, compliance cost rises but secondary-market trading liquidity may improve.^{[4, 2]}

Non-bank lending categories and 2025 regulatory framework