However, establishing a rehabilitation centre in Thailand involves more than registering a company and renting suitable premises. Depending on the services provided, investors may need to consider foreign ownership restrictions, Board of Investment promotion, healthcare establishment licences, professional licensing, building approvals, hotel regulations and immigration requirements.

This guide outlines the main legal and regulatory steps foreign investors should consider before launching a rehabilitation centre in Thailand.

1. Define the Rehabilitation Centre’s Business Model

To start, the first and most important step is to define exactly what services the centre will provide.

The term “rehabilitation centre” may refer to several different business models, including:

• physical rehabilitation and physiotherapy;
• post-operative recovery;
• neurological or injury rehabilitation;
• elderly or dependent-person rehabilitation;
• mental health recovery programmes;
• wellness and lifestyle rehabilitation;
• residential health programmes;
• addiction or substance-dependency treatment; or
• non-medical wellness retreats with accommodation.

The legal classification depends on the actual activities provided rather than the name used in marketing materials.

A centre providing diagnosis, medical treatment, physiotherapy, nursing care or services performed by licensed healthcare professionals may be treated as a healthcare establishment under Thai law. The Private Healthcare Establishments Act broadly covers premises organised for medical practice, professional healthcare services and treatment by regulated healthcare professionals.

By contrast, a centre offering only general wellness activities, fitness, nutrition coaching, meditation or non-medical lifestyle programmes may fall under a different regulatory framework.

Investors should therefore confirm the legal classification before signing a long-term lease, constructing facilities or purchasing medical equipment.

2. Establishing a Thai Company

Most rehabilitation projects are operated through a Thai limited company.

The company registration process normally includes:

1. reserving the company name;
2. preparing the company’s objectives;
3. determining its shareholding structure;
4. registering the memorandum and incorporation documents;
5. appointing directors and determining signing authority;
6. registering the company with the Department of Business Development;
7. completing tax and VAT registrations where applicable; and
8. registering employees for social security.

The company objectives should be carefully drafted to cover the intended activities, such as healthcare services, rehabilitation services, accommodation, food and beverage operations, consultancy, equipment procurement and related wellness services.

Overly broad or inaccurate company objectives may create difficulties when applying for operational licences.

3. Foreign Ownership and the Foreign Business Act

A company is generally treated as foreign under Thailand’s Foreign Business Act where foreign individuals or foreign entities hold 50% or more of its shares.

Many service businesses are restricted under the Act. A foreign-majority rehabilitation or healthcare services company may therefore require an appropriate legal basis to operate, such as:

• a Foreign Business Licence;
• a Foreign Business Certificate following BOI promotion;
• protection under an applicable treaty; or
• a business structure that is not classified as foreign under the Act.

The Department of Business Development administers foreign business permissions and distinguishes between licences issued under the Foreign Business Act and certificates issued to businesses operating under BOI or other statutory privileges.

Using Thai shareholders merely as nominees to circumvent foreign ownership restrictions is unlawful and may expose the company, its directors and shareholders to investigation and penalties.

The ownership structure should reflect genuine investment, decision-making authority and commercial participation.

4. Can a Rehabilitation Centre Obtain BOI Promotion?

A qualifying health rehabilitation centre may apply for investment promotion from the Thailand Board of Investment.

Read more of BOI’s guideline here

Under the BOI Investment Promotion Guide 2026, the activity “Health Rehabilitation Center” is listed under healthcare services. A qualifying project must:

• have minimum investment capital of at least THB 30 million, excluding land cost and working capital;
• use medical technology for medical treatment and health rehabilitation;
• provide continuous rehabilitation programmes; and
• include overnight treatment.

The BOI category expressly excludes narcotic drug therapy.

This means that a small wellness retreat or non-medical residential programme will not automatically qualify as a BOI-promoted health rehabilitation centre. The project must demonstrate a substantive medical rehabilitation operation supported by relevant technology, treatment systems and an integrated residential programme.

BOI Incentives

Under the current BOI classification, a health rehabilitation centre falls within incentive category B. The current BOI healthcare materials list health rehabilitation centres among eligible medical and healthcare service projects, although category B generally does not provide a corporate income tax exemption.

Depending on the approved project and applicable BOI conditions, non-tax incentives may include:

• permission for foreign ownership of the promoted business;
• permission to bring foreign experts and skilled personnel into Thailand;
• support for visas and work permits;
• permission to own land for the promoted activity, subject to BOI approval and conditions; and
• exemption or facilitation relating to certain imported machinery, where applicable.

BOI promotion should therefore be assessed not only as a tax incentive but also as a potential solution for foreign ownership, land use and expatriate employment.

5. Preparing the BOI Application

In addition, a BOI application for a rehabilitation centre should generally explain:

• the nature of the medical rehabilitation services;
• target patient groups;
• treatment and rehabilitation programmes;
• medical technology and equipment;
• number and type of patient rooms;
• overnight rehabilitation arrangements;
• staffing structure;
• qualifications of healthcare professionals;
• source of investment funds;
• projected revenue and operating costs;
• construction and implementation timeline;
• benefits to Thailand;
• employment of Thai personnel; and
• transfer of knowledge or professional expertise.

The BOI will evaluate the substance of the project rather than relying solely on the company’s registered business objectives.

Investors should prepare the operational and licensing strategy before filing the BOI application. Material changes to the business model after approval may require further notification or amendment.

6. Healthcare Establishment Licence

Where the rehabilitation centre provides medical treatment or regulated healthcare services, the operator will normally need approval under Thailand’s healthcare establishment laws.

Private healthcare establishments in Thailand are supervised by the Department of Health Service Support under the Ministry of Public Health. Licensed establishments can be verified through the Department’s official private healthcare establishment database.

The licensing process may require:

• an operator’s licence to operate the healthcare establishment;
• a licence for the person responsible for managing the establishment;
• floor plans and approved use of the premises;
• details of treatment rooms and patient facilities;
• lists of medical equipment;
• waste-management systems;
• infection-control procedures;
• emergency response arrangements;
• agreements with qualified healthcare professionals; and
• inspection by the competent authority.

For projects outside Bangkok, applications and regulatory coordination will generally involve the relevant Provincial Public Health Office.

The premises should not be finalised solely on commercial grounds. The building must also be capable of meeting the technical, healthcare and safety requirements applicable to the intended licence.

7. Licensed Medical and Healthcare Professionals

A rehabilitation centre cannot rely only on foreign practitioners or general wellness staff where the services constitute regulated healthcare practice.

Depending on the programme, the centre may need appropriately licensed personnel such as:

• physicians;
• nurses;
• physical therapists;
• occupational therapists;
• psychologists or psychiatrists;
• pharmacists;
• Thai traditional medical practitioners; or
• other regulated healthcare professionals.

Thai law recognises a number of regulated healthcare professions, including medicine, nursing, pharmacy, physical therapy and Thai traditional medicine.

Foreign professional qualifications are not automatically recognised in Thailand. A foreign practitioner may also need professional recognition, an appropriate visa and a work permit before providing services.

Foreign founders should distinguish between managing or investing in the business and personally practising a regulated healthcare profession.

8. Residential Accommodation and Hotel Licensing

Many rehabilitation centres offer accommodation as part of a continuous residential programme.

The project must determine whether the rooms are legally classified as:

• inpatient healthcare accommodation;
• accommodation forming part of an approved rehabilitation programme;
• long-term residential accommodation; or
• hotel or short-term guest accommodation.

If rooms are marketed or provided to the general public on a short-term basis, a hotel licence may be required. A healthcare licence does not necessarily authorise the operator to run a separate hotel or resort business.

Where the project combines a rehabilitation centre with a wellness resort, hotel, restaurant or commercial spa, the activities may need to be separated operationally and licensed independently.

This distinction should be addressed at the design stage because healthcare premises and hotel premises may be subject to different requirements concerning room layouts, accessibility, fire safety, staffing and building use.

9. Building, Land Use and Construction Approvals

Before purchasing or leasing land, the investor should conduct legal due diligence covering:

• land title and ownership;
• registered mortgages and encumbrances;
• legal access to the property;
• servitudes;
• zoning restrictions;
• environmental restrictions;
• construction permissions;
• permitted building use;
• height and setback restrictions;
• wastewater treatment;
• fire safety;
• accessibility; and
• restrictions affecting coastal or hillside land.

These issues are particularly important in Koh Samui, where many attractive project sites are located on hillsides, near coastal areas or in locations with complex access and development restrictions.

A building previously used as a villa, hotel or private residence may not automatically be suitable for use as a healthcare establishment.

Where renovations or a change of building use are required, the necessary approvals should be obtained before commencing operations.

10. Other Licences and Registrations

Depending on the project, additional approvals may include:

Food and Restaurant Operations

A centre preparing meals for patients, guests or the public may require local food-premises approvals and compliance with food hygiene requirements.

Spa and Health Establishment Services

Massage, spa and certain wellness services may require a health establishment licence under the Health Establishment Act.

Medical Devices and Medicines

The procurement, storage, dispensing, importation or sale of medicines and medical devices may trigger Thai Food and Drug Administration requirements.

Alcohol Licence

A hotel, restaurant or hospitality component serving alcohol must obtain the appropriate alcohol sales licence and comply with restrictions on sale times and advertising.

Signage and Advertising

Local signage tax and signage permissions may apply. Medical and healthcare advertising is also subject to specific controls and should not contain misleading treatment claims.

Personal Data Protection

Rehabilitation centres process sensitive health information. They should implement appropriate consent forms, privacy notices, access controls, retention policies and security measures under Thailand’s Personal Data Protection Act.

11. Visas and Work Permits for Foreign Founders

Foreign shareholders do not automatically have the right to work in Thailand.

A foreign founder who actively manages the centre, signs operational documents, supervises staff or provides services will generally require an appropriate visa and work permit.

Possible routes may include:

• a Non-Immigrant B visa and standard work permit;
• BOI-supported visa and work permit privileges;
• a long-term resident visa, where eligibility requirements are satisfied; or
• another category appropriate to the individual’s role and circumstances.

BOI-promoted companies may receive immigration facilitation for approved foreign experts and skilled personnel. However, BOI promotion does not mean that every foreign shareholder will automatically qualify.

For this reason, the company should prepare an organisational chart identifying which foreign personnel are genuinely required and why their experience cannot immediately be replaced by local personnel.

12. Recommended Legal Roadmap

A foreign investor establishing a rehabilitation centre in Thailand should normally proceed in the following order:

Business and Regulatory Assessment (Phase 1)

• define the rehabilitation services;
• determine whether services are medical or non-medical;
• identify the target patients;
• review the proposed accommodation model;
• assess BOI eligibility;
• identify foreign ownership restrictions; and
• prepare a preliminary licence matrix.

Corporate and Investment Structure (Phase 2)

• incorporate the Thai company;
• structure the shareholding;
• prepare shareholders’ and investment agreements;
• establish director authority;
• register appropriate company objectives; and
• file the BOI application where appropriate.

Property Due Diligence and Design (Phase 3)

• review the land title or lease;
• assess zoning and building use;
• prepare healthcare-compliant layouts;
• coordinate architectural and engineering requirements; and
• avoid binding construction commitments before regulatory confirmation.

Operational Licensing (Phase 4)

• apply for the healthcare establishment licence;
• appoint the licensed operator and medical professionals;
• obtain hotel, food, spa or other related licences;
• register medicines or medical devices where required; and
• prepare regulatory policies and patient documentation.

Immigration and Launch (Phase 5)

• obtain visas and work permits;
• hire and register employees;
• implement data-protection procedures;
• prepare patient and service agreements;
• review advertising materials; and
• complete pre-opening inspections.

Common Mistakes Made by Foreign Investors

In practice, common problems include:

• assuming that every wellness or rehabilitation concept qualifies for BOI promotion;
• signing a property lease before confirming that the premises can be licensed;
• using nominee Thai shareholders;
• marketing medical treatments before receiving the required licence;
• employing foreign therapists without professional recognition or work permits;
• treating patient accommodation as ordinary hotel accommodation;
• combining medical, hotel, restaurant and spa activities without separate licensing analysis;
• underestimating the minimum investment and medical-technology requirements for BOI promotion; and
• describing an addiction-treatment facility as an ordinary BOI health rehabilitation centre despite the BOI exclusion for narcotic drug therapy.

Conclusion

Thailand offers significant opportunities for professionally structured rehabilitation and healthcare projects, particularly in destinations such as Koh Samui that combine international connectivity, hospitality infrastructure and a strong wellness market.

However, the regulatory structure must be designed around the actual services from the beginning. Company registration, foreign ownership, BOI promotion, healthcare licensing, property use, accommodation, professional qualifications and immigration requirements are closely connected.

Therefore, foreign investors should complete a legal and regulatory feasibility review before purchasing land, entering into a long-term lease or commencing construction.

Lex Bangkok assists foreign investors with company establishment, BOI applications, foreign business compliance, healthcare and hospitality licensing, property due diligence, commercial agreements, visas and work permits, and ongoing regulatory matters in Thailand.

This article provides general information only and does not constitute legal advice. Licensing requirements depend on the project’s specific services, location, premises and operational structure.

Frequently Asked Questions