A family office in Thailand is a structure that manages the wealth of a high-net-worth family as a whole, from investments to tax, succession and family governance. Thailand has no dedicated family office licence. Instead, the Securities and Exchange Commission (SEC) looks at each activity the office performs. Its September 2026 guidance explains where that line falls.
The SEC published an explanatory article on 28 September 2026, “7 Things to Know: Opportunities and Approaches for Family Office Services in Thailand”. It confirms an activity-based approach: tax, legal and administrative work sits outside SEC licensing, while investment advice and discretionary portfolio management may require an investment advisory or private fund management licence. A single-family office serving only its own family can fall outside licensing. Advice to no more than 15 investors in any 12-month period can be exempt, if the provider does not hold itself out as an investment adviser.
What Is a Family Office in Thailand?
The SEC describes a family office as the systematic management of a wealthy family’s assets that goes beyond portfolio construction. Its scope can include tax and legal planning, estate planning, risk management, family governance and philanthropy. The form and scope of each office depend on the needs of the family it serves.
The guidance is the SEC’s first structured explanation of the subject. According to a global law firm publication, it follows SEC Circular Letter No. 47/2569 of 9 September 2026 on the promotion and supervision of family office businesses. The SEC states that it supports a Thai family office ecosystem alongside investor protection and professional standards.
Is There a Family Office Licence in Thailand?
No. The SEC states that there is no specific licence for operating a family office business. It applies activity-based regulation instead. The SEC supervises only activities that relate to the capital market and meet the elements of a securities business. Other services may fall under other authorities and other laws.
As a result, the label “family office” decides nothing on its own. What matters is what the office does for each client. Tax planning, legal advice, document management and administrative support do not require an SEC licence. Investment recommendations and portfolio decisions are assessed separately.
Single-Family and Multi-Family Offices
The SEC distinguishes two service models. The distinction shapes the licensing analysis, but it does not settle it. The table summarises how the guidance describes each model.
| Model | Who it serves | Licensing position in the guidance |
|---|---|---|
| Single-family office (SFO) | One family or one family’s group of companies, not offered to the public and not carried on as an ordinary business | Can fall outside SEC licensing when it handles internal family affairs only |
| Multi-family office (MFO) | Several families, sharing staff and systems | Serving several families does not by itself trigger a licence; the activities performed decide |
The SEC notes that an SFO offers privacy and control over decisions, while an MFO spreads costs across several families. Neither model is a licence category in itself.
Which Family Office Activities Need an SEC Licence?
Two capital market activities draw the SEC’s attention. Investment advice on securities, given to a client who keeps the final decision, falls within investment advisory business. Managing a client’s securities portfolio with discretion falls within private fund management. Both are securities businesses under the Securities and Exchange Act B.E. 2535.
Investment advisory
Personalised securities recommendations, where the client decides, require an investment advisory licence unless an exemption applies. The two exemptions named in the guidance are the 15-investor exemption and advice given only to institutional investors. The definition of institutional investor comes from SEC Notification No. KorThor. 1/2560.
Private fund management
Where the office makes investment decisions, sends trading orders or rebalances the portfolio on the client’s behalf, the SEC treats the service as private fund management. A licence is required if the office carries on that activity as an ordinary business or offers it widely to the public. The investment advisory exemptions do not cover discretionary management.
Penalty for unlicensed securities business
Section 90 of the Securities and Exchange Act requires a licence to carry on a securities business. Under Section 289, a breach is punishable by imprisonment of two to five years and a fine of two hundred thousand to five hundred thousand baht, plus a daily fine for each day the breach continues.
The 15-Investor Exemption for a Family Office in Thailand
An office giving investment advice can avoid the investment advisory licence if it advises no more than 15 investors in any 12-month period. Two further conditions apply: it must not hold itself out as an investment adviser, and it must not carry on the service as an ordinary business. Each condition is assessed on the facts.
- Counting: the limit counts investors who receive advice, so a family group cannot simply be treated as one investor.
- Public marketing: advertising investment advisory services to the public on a website may defeat the exemption, even with only five clients.
- Fees: charging for the advice does not, by itself, remove the exemption. The SEC looks at promotion, remuneration and continuity of service together.
Administrative Coordination Without a Licence
An unlicensed office may still support a family’s investments administratively. The guidance lists collecting portfolio data, preparing reports, coordinating outside service providers and tracking the status of transactions. These tasks must remain purely administrative.
The boundary is strict. The office must not analyse, recommend or exercise discretion, and it must not receive or relay trading orders for the client. The only exception is work assigned by a licensed business operator. Accordingly, clients send their trading instructions directly to the licensed firm.
Three Ways a Family Office in Thailand Can Work With Licensed Firms
The SEC sets out three models for offering a complete service through cooperation with licensed firms. Each one allocates responsibility differently.
- Unlicensed coordinator. The family office handles administration only. The client places trading orders with the licensed business operator directly.
- Outsourcing by a licensed firm. A licensed firm assigns part of its front, middle or back office work to the family office, within the firm’s scope and control. The licensed firm remains responsible to the client and to the SEC.
- Licensed adviser as broker’s agent. A family office holding an investment advisory licence may pass on orders when a securities broker appoints it as agent. The client confirms each order personally.
Family Office in Thailand: Fees and Conflicts of Interest
Payments between a family office and licensed firms are permitted. The guidance names referral fees, revenue sharing and ongoing service fees as examples. However, every arrangement must be transparent and must manage conflicts of interest.
Before a client decides to use a service, the licensed business operator must disclose the business relationship, the type and method of calculating remuneration, and its effect on the advice. The SEC adds that the family office should also disclose which operators pay it fees or other benefits.
Structuring a Family Office in Thailand
The guidance turns a vague label into a set of separate questions. For each service, the family and its advisers can ask who gives advice, who decides, who handles orders and who is paid by whom. The answers show whether the office stays outside SEC licensing, relies on an exemption, partners with a licensed firm or needs its own licence.
Three practical consequences follow. First, the service agreement and the office’s public marketing must match the role it actually plays. Second, an office that grows from one family to several should review its activities again, because the exemption conditions may stop applying. Third, succession tools such as a Thai will for foreigners sit outside SEC licensing and are governed by other laws.
The family office guidance also sits within a wider reform of Thai capital market rules. For recent changes to the statute itself, see our note on Thailand Securities Act amendments.
Frequently Asked Questions
Do I need a licence to set up a family office in Thailand?
Is a single-family office regulated by the SEC?
How does the 15-investor exemption work?
Can a family office pass client orders to a broker?
Is the SEC family office guidance binding law?
Conclusion
A family office in Thailand needs no licence of its own, but its investment activities do not escape regulation. The SEC’s September 2026 guidance draws the line by activity: administration, tax and legal work stay outside, while advice and discretionary management need a licence, an exemption or a licensed partner. Therefore, mapping each service before launch protects the family and the office. Our financial services licensing and compliance team advises on these structures. The SEC publishes its guidance on the SEC website, and the Act is available from the Office of the Council of State.
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