Real-estate-backed digital tokens in Thailand: what SiriHub and RealX actually give an investor

Can buying a digital token give a foreign investor real estate exposure in Thailand without the usual ownership restrictions? Not in the way it might sound. Since 2021, Thailand's Securities and Exchange Commission has licensed a small but growing market of "investment tokens" backed by specific buildings — Sansiri's SiriHub and Origin Property's RealX are the two best-known examples. They're real, regulated, and open to foreign buyers. But a token is a claim on the company that holds the building, not a claim on the building itself, and that distinction is exactly why it doesn't touch the Land Code or the Condominium Act at all.

The legal basis: the Emergency Decree on Digital Asset Businesses B.E. 2561

Thailand's SEC regulates this market under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018), which licenses digital-asset businesses across categories including exchanges, brokers, dealers, fund managers and ICO portals. A public offering of an investment token must run through an SEC-approved ICO portal, and secondary trading happens on a licensed digital asset exchange — the Thai Digital Assets Exchange (TDX), SEC-authorized to operate since September 2022, is where both SiriHub and RealX list. The SEC requires the underlying property to be complete and free of disputes before an offering can go live.

Two examples already operating

• SiriHub (Sansiri, 2021). Backed by the Siri Campus office building in Bangkok, raising roughly ฿2 billion from investors who receive quarterly income distributions tied to the building's rental performance. A second offering, SiriHub2, has since followed the same model.
• RealX (Origin Property, debuted on TDX 25 September 2023). Backed by three luxury residential projects in central Bangkok (361 condo units), priced at roughly ฿182 per token with a stated ฿300,000 per-investor cap at launch. Token holders receive a quarterly share of net rental income for the first five years, plus a potential share of the price gain on the underlying units after year six.

What a token actually gives you — and what it doesn't

The structure is what makes this legally possible for foreign buyers in the first place: what gets tokenized isn't the property directly, it's the special-purpose company (SPV) that holds registered title to it. An investor's token represents a fractional economic claim on that SPV — its rental income and, potentially, its sale proceeds — not a name on a Chanote or a condo unit register. The SPV itself is the one that has to comply with Thai ownership law, meaning the Condominium Act's 49% foreign quota and the Land Code's ban on foreign land ownership keep applying exactly as they would to any other Thai property owner — a token doesn't create a workaround, it sits one legal layer above the restriction entirely.

A retail investment cap that was lifted for this specific category

Thailand's SEC generally caps a retail investor at ฿300,000 per single token offering, a standard investor-protection limit for higher-risk digital token products. A rule change published in the Royal Gazette on 16 January 2024 removed that cap specifically for real-estate-backed and infrastructure-backed tokens, letting retail investors put more than ฿300,000 into a single offering in this category — a materially lighter-touch regime than for a typical crypto ICO, reflecting the SEC's view that an income-producing, SEC-vetted building is a different risk profile from a speculative token.

Distinct from a Thai REIT — and from owning a villa outright

This isn't the same vehicle as the Thai REIT already covered on this site. A REIT is a listed trust unit under a different law (the Trust for Transactions in Capital Market Act B.E. 2550), trading daily on the Stock Exchange of Thailand across a diversified portfolio you don't choose. An investment token is tied to one specific building you do choose, but trades — if at all — on a much thinner, newer secondary market with a shorter track record than an SET listing. Both existing token offerings are Bangkok office or condo projects; no Koh Phangan or Surat Thani asset has been tokenized to date, so this is background knowledge on an indirect investment route, not yet a way to gain exposure to island real estate specifically.

None of this replaces the direct-ownership question this site otherwise focuses on. A token never gives you a villa to live in, rent out under your own name, or protect with a registered lease or superficies the way the standard foreign-ownership routes do — it's income exposure to someone else's building, not a property of your own.