36,277 foreign-linked companies, 8 priority provinces: how Thailand's 2026 nominee-monitoring network actually works

How many companies has Thailand's nominee-shareholding review actually screened, and does it reach Koh Phangan? As of August 2026, two separate but coordinated tracking systems both name Surat Thani — the province Koh Phangan and Koh Samui sit under — as a priority area, and for the first time officials have put hard national numbers on the exercise.

The DBD's first national count

On 18 August 2026, Department of Business Development director-general Poonpong Naiyanapakorn disclosed that the DBD, cross-referencing its own registry against Department of Lands title data, had reviewed 144,706 legal entities nationwide and identified 36,277 as foreign-linked landholders. These split into two risk tiers: 31,516 companies with foreign ownership at or below the 49% cap, which now face verification that the Thai majority shareholding reflects a genuine investment rather than a nominee front, and 4,761 companies with foreign ownership above 49% — an outright breach of the Foreign Business Act cap — facing the stricter track. Roughly 35,154 of the flagged entities cluster in 16 named provinces, including Surat Thani, Phuket, Chon Buri and Chiang Mai. This builds on the AI-assisted IBAS screening already reviewing existing landholding companies; see The Land Department's 2026 audit of existing landholding companies for how that system flags a company in the first place.

The Land Department's parallel 8-province framework

Separately, the Department of Lands runs its own standing-review system: Provincial Land Offices check monthly for any company where a foreigner holds shares or a director seat, and report results quarterly to the central department, with immediate reporting required if a company crosses the foreign-control thresholds mid-cycle. As of mid-2026, that system names 8 priority provinces for the heaviest monitoring load: Phuket, Surat Thani, Mae Hong Son, Chiang Mai, Krabi, Chon Buri, Rayong and Chanthaburi. Every land office in these provinces was required to complete a baseline review of its existing company-landholder database by 26 June 2026, before settling into the routine monthly-check cycle.

The penalties sit on top of losing the land, not instead of it

A company flagged as a nominee structure still faces the land-focused consequence already covered elsewhere on this site: Land Code Section 96 lets the Director-General order the land sold within 180 days to a year (see Section 94 forfeiture amendment for the proposal to remove even that sale-proceeds entitlement). Separately, the company and the individuals who set it up face their own direct fines under the Land Code: Section 112 fines a juristic person up to ฿50,000 for the underlying illegal acquisition, and Section 113 fines a Thai national who acted as an agent for a foreigner up to ฿20,000, or up to 2 years' imprisonment, or both. Losing the land and paying these fines are separate exposures — a forced sale doesn't settle the criminal liability.

Why Surat Thani sits on both lists

Koh Phangan and Koh Samui fall under Surat Thani province for land registration and company jurisdiction, which is why both the DBD's national hotspot list and the Land Department's 8-province monitoring framework name it independently. In practice that means a company holding land on Koh Phangan is reviewed twice over: once through the DBD's registry-side screening of shareholding patterns, and again through the Provincial Land Office's monthly land-and-company cross-check. See Buying a villa already held by a Thai company for what that means specifically for a buyer looking at company-held inventory on the island, and A Thai company for property: when it makes sense, when it's toxic for the narrow cases where the structure still holds up.

None of this changes the underlying law — the 49% foreign-ownership cap and the ban on nominee shareholding were always the rule. What August 2026's disclosures confirm is that the monitoring machinery behind that rule is fully operational and producing hard numbers, not sitting as an unenforced directive on paper.