By Khemmapat Trisadikoon, Senior Researcher, Thailand Development Research Institute and Wichayada Amponkitviwat, Researcher, Thailand Development Research Institute.
At a glance
- MSMEs drive Thailand’s economy—accounting for 99.5% of enterprises and nearly 70% of employment—yet face severe financing constraints. In response, the Bank of Thailand launched its “Three Opens” reform to enable data-driven lending and improve credit access.
- Implementation is restricted by three main challenges: the absence of a legal framework for cross-sector data sharing, a lack of interoperable data infrastructure between public and private entities, and inadequate digital identification mechanisms for businesses,
- To build an inclusive digital finance ecosystem, Thailand must enact primary legislation recognising a formal Consumer Data Right (broadly comparable to the UK’s Open Banking framework), establish central data-sharing architecture, and standardise digital business authentication.
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Micro, small, and medium-sized enterprises (MSMEs) constitute the backbone of Thailand’s economy. In 2025, Thailand had approximately 3.31 million MSMEs, accounting for 99.5% of all enterprises, the majority of which were microenterprises. MSMEs also accounted for 69.2% per cent of total employment, underscoring their central role in sustaining jobs and livelihoods across the country. Their economic contribution is equally significant: in 2024, MSMEs generated approximately THB 6.48 trillion out of Thailand’s total GDP of approximately THB 18.57 trillion, representing 34.9%—or roughly one-third—of the national economy. These figures demonstrate that the financial viability of MSMEs is not merely a concern for individual businesses, but a matter of national employment, economic growth, and resilience.
Despite their importance to the Thai economy, many MSMEs continue to face constraints in accessing finance, which is essential for maintaining business operations and supporting business expansion. According to the OECD’s Financing SMEs and Entrepreneurs 2026, these constraints stem from insufficient financial information for credit assessment and credit-risk evaluation, a lack of collateral, and the relatively small loan amounts typically requested by MSMEs. These factors may cause the costs incurred by financial institutions in assessing and monitoring credit risk to exceed the returns generated from lending.
To address these constraints, the Bank of Thailand (BOT) has pursued financial-sector reform under the “Three Open” policy, comprising Open Data, Open Infrastructure, and Open Competition. The policy aims to promote a more open and competitive financial ecosystem while encouraging the use of data-driven lending to improve MSMEs’ access to finance more effectively.
Three Open: Reshaping Thailand’s Financial Landscape
The Three Open policy seeks to reshape Thailand’s financial landscape across three interconnected dimensions: increasing the number and diversity of financial service providers, strengthening the infrastructure used to support credit guarantees, and expanding access to the data required for credit assessment and credit-risk evaluation. Together, these measures are intended to enable financial institutions to assess MSMEs’ repayment risk more effectively, without relying solely on conventional financial information.
1. Open Competition
Open Competition seeks to address the high cost of small-ticket lending, which often makes such lending commercially unattractive to traditional financial institutions. It does so by expanding and redefining the roles of two groups of financial service providers.
a. The first group consists of new market entrants, particularly virtual banks. These include ACM Holding Co., Ltd.; a consortium comprising Krung Thai Bank Public Company Limited, Advanced Info Service Public Company Limited, and PTT Oil and Retail Business Public Company Limited; and a consortium comprising SCB X Public Company Limited, WeTechnology Limited, and KakaoBank Corp. These new providers are expected to serve customer groups that have traditionally been underserved by commercial banks, including low-income earners and self-employed workers who lack conventional proof of income and may previously have been denied credit.
b.The second group consists of existing market participants whose roles are being reconsidered, particularly non-bank financial institutions offering small business loans, such as Nano Finance, and digital personal loans, such as Digital P-Loans. The relevant authorities are currently reviewing existing regulatory requirements relating to deposits, cards, payment transactions, and front-end fees. The aim is to enable MSMEs to access financial services at reasonable and fair prices without bearing excessive costs.
2. Open Infrastructure
Open Infrastructure seeks to address MSMEs’ limited access to acceptable collateral through the SME Credit Boost measure. The measure establishes a central fund mechanism to compensate commercial banks for part of the risks associated with extending new loans to MSMEs in targeted industries (tourism, healthcare, processed agriculture, automotive, electronics, and trade, including businesses in supply chains and logistics) and to businesses seeking to enhance their competitiveness through digitalisation, sustainability, and innovation. Under this measure, participating banks are assigned a predetermined risk-compensation quota, which functions as a contingent loss-sharing arrangement funded through a temporary reduction in commercial banks’ contributions to the Financial Institutions Development Fund (FIDF). Compensation is not paid upfront but may be claimed if eligible loans subsequently become non-performing. This arrangement enables banks to assess and approve loans more quickly and flexibly, without having to wait for guarantee approval on a case-by-case basis, as under conventional credit-guarantee programmes administered by the Thai Credit Guarantee Corporation. The measure is therefore expected to expand MSMEs’ access to credit by easing collateral constraints while also reducing the risks borne by financial service providers.
3. Open Data
Open Data lies at the heart of Thailand’s financial landscape reform. It seeks to address the information constraints affecting MSME credit assessment through the Your Data initiative, which promotes consent-based data sharing between financial service providers and their customers. Under the rules established by the Bank of Thailand, the initiative covers both financial data—including information on deposit accounts, payments, loans, and taxation—and non-financial data, particularly records of utility use and payment. Access to these broader categories of data is intended to enable financial service providers to assess loan applications and creditworthiness more accurately, thereby expanding MSMEs’ opportunities to access formal sources of finance.
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Your Data, Your Financial Health: Beyond Access to Credit As the core mechanism of the Open Data policy, the Bank of Thailand’s (BOT) “Your Data” 1) Improving Access to Credit via alternative data, and 2) Supporting Personal Life Finance Management to enable broader financial planning, savings, and investment (with future connectivity planned for capital markets, insurance, and real estate). Ultimately, the BOT seeks to move beyond basic credit access by leveraging data as a tool to strengthen overall financial capability and long-term economic security. |
Challenges and Policy Recommendations for Thailand’s Financial Landscape Reform
The Three Open policy provides an important foundation for reforming Thailand’s financial system through a combination of short- and long-term initiatives and measures. Nevertheless, its implementation continues to face several significant legal and institutional constraints.
1. The Absence of an Overarching Legal Framework for Cross-Sector Data Sharing
Data sharing under the “Your Data” initiative is currently restricted by a fragmented regulatory environment. While governed by Bank of Thailand (BOT) rules, these mandates apply strictly to financial service providers under its direct supervision. Data exchanges with other public entities, such as the Revenue Department, rely heavily on bilateral memoranda of understanding (MoUs). However, because tax legislation restricts direct disclosure and automated transfer channels remain non-existent, customers are forced to manually request and submit their own tax records to financial providers.
Furthermore, the BOT lacks the authority to compel private entities outside its regulatory jurisdiction—such as utility, insurance, and e-commerce providers—to share potentially useful data. Although Thailand has adopted a royal decree governing data sharing among public authorities, its scope is strictly limited to public-sector bodies and cannot be extended to the private sector.
This fragmented architecture highlights a fundamental legal gap: Thailand’s regulatory framework does not yet recognise a formal consumer data right that empowers individuals and businesses to mandate secure, direct data transfers between authorised entities.
Thailand should therefore develop legislation or other regulatory mechanisms that facilitate cross-sector data sharing and enable individuals and businesses to make effective use of data generated through their activities. The core principle of such legislation should be the recognition of a consumer data right, broadly comparable to the approach adopted under the United Kingdom’s Open Banking framework. In this regard, the Ministry of Digital Economy and Society should work with relevant sectoral regulators and stakeholders to develop primary legislation governing data sharing across both the public and private sectors.
2. The Absence of Cross-Sector Data-Sharing Infrastructure
Data exchanges among entities regulated by the BOT are conducted according to common standards established by the central bank, thereby supporting secure and reliable connectivity within the regulated financial sector. Effective data-driven lending, however, also requires access to information generated outside the financial sector. Thailand currently lacks common standards and a central mechanism for cross-sector data exchange, which restricts the interoperability of data held by different public and private entities.
The Ministry of Digital Economy and Society should therefore develop central data infrastructure capable of supporting common data standards, interoperable data-transfer systems, consent-management mechanisms, and cybersecurity requirements. Such infrastructure would facilitate effective data exchange between public authorities and private-sector entities. Its development should involve cooperation among sectoral regulators in establishing common technical standards, governance arrangements, and shared oversight mechanisms.
3. Digital Identification and Authentication for Juristic Persons
Juristic persons—such as companies and registered partnerships that are legally recognised as separate legal entities—present more complex identification and authentication requirements than natural persons. The identification and authentication of juristic persons are more complex than those of natural persons because they require verification of both the identity of the authorised representative and the scope of that representative’s legal authority. Existing digital identification systems cannot yet be applied directly and comprehensively to these requirements. As a result, MSMEs registered as juristic persons continue to face limitations when authorising data sharing and conducting digital transactions.
Thailand should therefore develop a standardised and effective digital identification and authentication system for juristic persons that provides functionality comparable to that available to natural persons. This will require cooperation among relevant authorities, including the Department of Business Development under the Ministry of Commerce and the Electronic Transactions Development Agency. A reliable Digital ID system for juristic persons would enable authorised representatives to provide legally valid consent and support secure and efficient data sharing and digital transactions.
Conclusion
The Three Open policy and the Your Data initiative reflect a broader transition in Thailand’s financial system—from a narrow emphasis on expanding access to credit towards a more comprehensive focus on financial health. By using data as a tool, these initiatives are intended to enable MSMEs not only to access finance, but also to plan their finances and make economic decisions more effectively. Within the ASEAN context, this approach is consistent with the growing development of Open Finance and the digital economy, both of which increasingly treat data as a foundation for financial innovation. If Thailand can establish a comprehensive legal framework, common standards, and effective data infrastructure, it will be better positioned to strengthen the competitiveness of its MSMEs and enhance the country’s role in ASEAN’s emerging digital financial ecosystem.
Acknowledgements
This article builds on research conducted as part of a broader study of Thailand’s data-sharing legal framework. The authors would also like to thank the Bank of Thailand and the Electronic Transactions Development Agency (ETDA) for their valuable insights obtained through interviews conducted for this article.
The views and recommendations expressed in this article published on August 2026 are solely of the authors and do not necessarily reflect the views and position of the Tech for Good Institute.
