DBD Order 2/2569: the August 2026 order that replaces the source-of-funds rules — and why 'in-person shareholder verification' never became law

Does a Thai property-holding company now have to send a shareholder to appear in person before the DBD? No — not under the general documentation rules. What changed on 1 August 2026 is that the Central Partnership and Company Registration Office issued Order 2/2569, which repeals and consolidates the two orders that governed source-of-funds checks earlier in 2026 into a single instrument covering both new incorporation and later amendments.

What Order 2/2569 requires, effective 1 August 2026

• Thai shareholder bank statements — three months of statements from each Thai shareholder or partner's own account, showing withdrawals or transfers matching the exact amount and date of their capital contribution.
• Receiving-account statements — bank records for the company's own account, showing it actually received the subscription funds from each shareholder named.
• An Investment Explanation Letter — a prescribed DBD form tracing the flow of funds from each Thai shareholder to the company's receiving account.
• Who it applies to — any partnership or limited company where foreigners hold under 50% of registered capital, or any company with no foreign shareholder that appoints a foreign national as an authorised (co-)signing director. It covers new incorporations and amendment filings that introduce a foreign minority investor or a foreign authorised signatory.

What it replaces

• Order 2/2568 (effective 1 January 2026) required three-month bank statements from Thai shareholders at incorporation only. Repealed and folded into Order 2/2569.
• Order 1/2569 (effective 1 April 2026) required a written Investment Confirmation Letter whenever an amendment increased foreign control. Repealed and folded into Order 2/2569, which renames the document an Investment Explanation Letter and now pairs it with bank-statement evidence at the amendment stage too — a step Order 1/2569 did not itself demand.

Practically, this means a single filing standard applies from 1 August 2026 regardless of whether you're forming a new 49/51 structure or amending an existing one, and it now reaches the company's own receiving account, not just the paying shareholder's. See The DBD's 2026 source-of-funds rules for the detail of the two orders this one supersedes, and The Land Department's 2026 audit of existing landholding companies for how this paperwork feeds the wider compliance review.

Where the 'in-person verification' story came from

A draft order put out for public consultation between 29 February and 13 March 2026 would have gone further: requiring Thai partners in certain amendments — a partnership's foreign stake crossing above 50%, or a company appointing its first foreign authorised director — to appear in person, present valid ID, and sign a sworn statement denying nominee conduct. Commentary at the time expected this to take effect around 1 April 2026, alongside what became Order 1/2569.

It didn't happen that way. The order actually enacted on 1 April 2026 dropped the in-person, sworn-statement mechanism entirely in favour of the written Investment Confirmation Letter described above — later folded into Order 2/2569's Investment Explanation Letter. As of this writing, no enacted DBD order requires shareholders or directors in a standard 49/51 structure to physically appear before the registrar to prove genuine investment.

Where in-person appearance genuinely is required

• AMLO watchlist match (Order 3/2568, effective 1 January 2026) — if a shareholder, partner or director appears on an Anti-Money Laundering Office watchlist notified to the DBD, that person must appear in person with unexpired ID before the filing is accepted.
• State Welfare Card holder as director or major shareholder (Order 5/2568, effective 1 January 2026) — if the registrar's system flags an incorporation where a low-income welfare-card holder (annual income under ฿100,000) is named as a director or major shareholder in a company with high registered capital, the filing is suspended pending in-person verification.

These two triggers are narrow, automatic, and unrelated to the general bank-statement and Investment Explanation Letter requirements under Order 2/2569 — they fire only on a specific risk flag, not on every 49/51 filing. If your company and its shareholders don't match either flag, the compliance burden under the current rules is documentary, not an appearance.