Thailand’s land-nominee crackdown: when can land have to be sold?

On 19 October 2026, Thailand’s Department of Special Investigation (DSI) reported its participation in a briefing on action against nominees, compulsory disposal and higher-risk landholdings. It described inquiries into controllers, beneficial owners and related assets. This was an enforcement announcement. It did not enact a new Land Code that day or order every landowning company to sell.^{[Official source]}

When can disposal proceedings arise?

Section 94 of the Land Code concerns land acquired by a foreigner unlawfully or without permission. The competent authority fixes a disposal period of at least 180 days and no more than one year; failure to dispose within it permits official disposal. Section 96 addresses ownership on behalf of a foreigner or a juristic person under sections 97 or 98, authorises disposal and applies section 94 with the necessary adaptations. The applicable provision, decision-maker and actual deadline require review of the findings, authority and formal documents. There is no universal countdown from the news date.^{[Official source][Official source]}

A foreign shareholder alone does not establish nominee ownership, and a nominal Thai majority does not automatically establish legality. Review the landholder’s eligibility under land law, actual funding and control. Do not substitute the Foreign Business Act’s definitions for the Land Code analysis. Genuine operations and any landholding permission need supporting evidence; the permitted holder, use and continuing conditions must match the present position.

First distinguish an information request from a disposal decision

Keep the complete document, attachments, envelope and actual receipt record. Identify the issuing authority, reference, addressee, land parcel, legal basis, requirements and response date. An inquiry or request for documents differs from a formal disposal decision. Check any objection, administrative or court remedy and its deadline against each document; the heading alone does not determine the procedure.

Build a record of how the land was acquired

• Land: title and registration records, acquisition documents, purchase contract, payments, mortgages and other encumbrances.
• Company: current and historical shareholders, actual capital contributions, resolutions, signing authority and share transfers.
• Funding and use: purchase-money sources, loans and repayments, bank records, operations and actual land use, together with any genuine landholding permission.

Link each dated record to the parcel, payer, recipient and shareholder. Identify missing periods and obtain records through lawful channels. A recent company affidavit does not replace the funding evidence at acquisition; a personal assurance or nominal loan document may not explain the arrangement. A prospective buyer of a landholding company should review that history before deciding to proceed.

Plan the response and avoid making the position worse

Have a Thai lawyer assess the procedural stage, evidence gaps and response before comparing explanations, objections, remedies or lawful disposal. If a transfer is contemplated, review the buyer’s eligibility, security interests, contracts and taxes. Rushed shareholder changes, renaming the owner, backdated loans or fabricated contributions do not resolve the historical facts.

An investigation does not itself establish a conviction or confiscation. Land disposal, possible criminal liability and civil contractual consequences require separate analysis. A condominium interest, building, land lease and company shares are also different rights; rules for one should not simply be applied to another.

How THAIHOUSING can assist

Once an engagement is confirmed, conflicts checked and scope agreed, THAIHOUSING can arrange review by Thai lawyers of the notice, land, corporate and funding records, identify missing evidence and assess responses, disputes and disposal options. Representation and individual procedures require separate confirmation. Findings and official decisions cannot be guaranteed.

Frequently asked questions

Related services

• Foreign investors holding land in Thailand: what to check first
• Land due diligence
• Property transactions and rights arrangements

Last checked: 20 October 2026. The reported event and publication date were 19 October. The cited official materials were checked; each matter still requires review of the acquisition, notice and evidence.