Stricter financial and tax compliance checks are creating uncertainty for foreign residents and legitimate businesses in Thailand.
PATTAYA, Thailand – Thailand’s visa extension system is facing growing concerns following reports that certain commercial banks have refused to issue account certification letters required for immigration applications, while immigration authorities are intensifying their examination of bank statements, tax compliance records and the genuine business activities of companies employing foreign nationals.
On 3 November 2026, my legal team in Phuket reported considerable confusion at the local Immigration Office, where applicants were being asked to provide additional financial and tax documentation. Around the same time, a foreign resident contacted me after his bank refused to issue the certificate required for his visa extension. He asked whether I, as a lawyer, could certify his bank balance instead.
This raises a fundamental question: What happens when Immigration requires a document that a bank refuses to issue?
Bangkok Bank and Krung Thai Bank: difficulties obtaining immigration certificates
In July 2026, a foreign resident in Phuket reported that Bangkok Bank refused to issue a bank certification letter because his account did not contain THB 800,000, although he intended to qualify for a retirement extension through monthly income rather than the deposit method.
A similar incident was reported in Pattaya during August and September. A foreign resident receiving overseas transfers of at least THB 65,000 per month reportedly experienced difficulties obtaining the required documentation from Bangkok Bank. He subsequently opened an account with Kasikornbank, which issued the necessary certificate. However, Immigration still required financial evidence relating to his previous Bangkok Bank account.
In October, another foreign resident reported that Krung Thai Bank refused to issue a certification letter for a marriage-based extension because his account held less than THB 800,000, despite the general deposit requirement for that immigration category being THB 400,000.
Although these incidents are individual reports rather than confirmed nationwide banking policies, they raise serious questions about inconsistencies between immigration requirements and banking procedures.
The Immigration Bureau’s circular of 18 June 2026
On 18 June 2026, the Immigration Bureau issued Circular No. 0029.161/W3242, establishing guidelines for examining foreign nationals applying for temporary permission to remain in Thailand, particularly to prevent unlawful Thai nominee arrangements in business operations and land ownership.
The circular was discussed in an analysis published by Forvis Mazars Thailand on 30 October 2026, which highlighted increased scrutiny of shareholder structures, actual business control, financial statements and genuine business operations.
Separately, Central Partnership and Company Registrar Order No. 2/2569, effective 1 August 2026, introduced stricter verification of investment funding in company registrations involving nominee risks. In relevant cases, Thai shareholders may be required to provide bank statements covering the preceding three months.
These measures demonstrate the authorities’ increasing emphasis on financial transparency and the economic substance of businesses. However, the DBD requirements must not be confused with immigration rules, and the June circular has not been verified as imposing identical bank statement or tax documentation requirements on every visa category.
Tax compliance is becoming central to visa extension scrutiny
For companies employing foreign nationals, immigration checks extend beyond company registration certificates and work permits. Corporate financial statements, annual corporate income tax returns (PND 50), monthly payroll withholding tax returns (PND 1), social security contributions and evidence of genuine employment are important components of the examination.
Where inconsistencies arise, immigration officers may seek additional evidence to compare declared salaries, tax filings and actual payments. For example, a company may declare a foreign manager’s salary of THB 50,000 per month, while its payment records and tax filings cannot be reconciled.
Similarly, a company may report sufficient Thai employees to meet immigration requirements but be unable to demonstrate that those employees genuinely work for the business. Such discrepancies may lead to further examination or an inspection of the business premises.
Nevertheless, a company operating at a loss, maintaining a modest bank balance or legitimately amending previous tax returns should not automatically be classified as a nominee operation. The relevant facts must be examined fairly and in their entirety. The more concerning issue is whether businesses are being given sufficient advance notice when additional financial and tax documentation is required.
Fighting nominee companies must not penalise legitimate businesses
I fully support decisive action against nominee companies, sham employment arrangements and immigration fraud. However, stronger enforcement must be accompanied by clear, consistent and workable procedures.
If Immigration demands a bank certificate that the bank refuses to issue, or requests additional tax records without sufficient prior guidance, who should bear responsibility for the resulting delays and potential consequences?
A lawyer may review financial records and provide a professional legal opinion but cannot automatically replace a bank-issued certificate with a document carrying equivalent authority. The Immigration Bureau and commercial banks should therefore coordinate their procedures and clearly identify the documentation required for each immigration category.
The effectiveness of immigration enforcement should not be measured by the number of additional documents demanded, but by its ability to identify unlawful activity without imposing unnecessary burdens on those who comply with the law.
Thailand has every right to combat visa abuse and unlawful nominee arrangements. Equally, foreign residents and legitimate business operators deserve an immigration process that is transparent, predictable and fair.
