According to Tilleke & Gibbins, on 25 August 2026 the Ministry of Interior ordered provinces to screen companies suspected of holding land for foreigners and to pursue them in two tracks.
According to law firm Tilleke & Gibbins, on 25 August 2026 Thailand's Ministry of Interior sent an urgent circular letter to all provincial governors with enhanced enforcement guidelines against nominee land ownership. Under the Land Code, foreign nationals are generally prohibited from owning land, and some have used Thai nominees, individuals or Thai-registered companies, to hold it for them. The circular builds on an earlier one from April 2023.
The circular introduces three measures. Provincial fact-finding committees must add representatives of specialised investigative agencies, such as local police superintendents, giving them wider access to shareholding, tax, immigration and financial records. Provincial Land Offices must actively screen companies and partnerships that show risk indicators of acting as nominees, and refer the results to the committees.
Enforcement can then follow two tracks: if a company is classified as a foreign national under the law, the governor sets a deadline for it to dispose of the land; if it was set up specifically to hold land for a foreigner, land officers must file a criminal complaint and follow the case to final judgment. Tilleke & Gibbins describes this as a continued escalation that exposes both foreign nationals and the Thai persons and professionals who facilitate such arrangements. This is a summary of a law firm's note, not legal advice; take Thai legal advice before any purchase structure.