Close supervision and monitoring by the Bank of Thailand would obstruct virtual banks from expanding their loan portfolios aggressively in the first five years of operations, even though they are likely to offer small-ticket, unsecured personal loans below 10,000 baht, analysts say.
The rollout of Thailand's virtual banks serves the central bank's goal of enhancing access to funding for underserved and underbanked customers while creating fair competition without leading to high levels of borrower indebtedness, said Weerapat Wonk-urai, an analyst at CGS International Securities (Thailand).
Following the launch of Clicx Bank earlier this month, the two remaining virtual banks are expected to commence operations in the second half of the year to fulfil the central bank's financial inclusion objective.
Given their low-overhead model, virtual banks are well positioned to gradually drive market competition and spark innovation that better meets users' needs at lower costs.
According to Mr Weerapat, virtual banks must go through a restricted phase in the first 3-5 years, with the central bank closely monitoring the operations of the newly licensed virtual banks during this period.
Virtual banks must have a paid-up capital of at least 5 billion baht on the day of business commencement. The level of paid-up capital will gradually increase to at least 10 billion baht before they exit the restricted phase and commence full-fledged operations.
"A virtual bank's business model needs approval from the Bank of Thailand," he noted. "With close supervision and monitoring by the central bank, we believe a virtual bank is unlikely to grow its loan portfolio aggressively in the first five years of operation."
Tris Rating, meanwhile, views Thailand's digitally mature market as posing another challenge for newly licensed virtual banks.
"In Thailand, incoming virtual banks face a mature landscape," the credit rating agency said in its recent research, adding that incumbent operators are already technologically sophisticated and deeply integrated into the daily lives of consumers, making digital convenience "the norm rather than a differentiator".
This maturity is evident in 186.3 million combined registered mobile/internet banking accounts as of March 2026, roughly 2.8 times the national population of about 66 million, a gap reflecting multi-bank account holding rather than unique users.
"In this environment, competitive advantage hinges less on user base size than on AI-driven risk underwriting capable of distinguishing financially stressed informal-sector workers from creditworthy applicants," Tris said.
Success then depends not on chasing every new technology but on selecting and adapting tools to address risk and customer behaviour and deliver measurable value, it noted.
CGS expects virtual banks to offer small ticket size unsecured personal loans below 10,000 baht, underwriting them using alternative data and data analytic tools.
Other loan products for a virtual bank are likely to be 'Buy Now, Pay Later' products and lock phone loans, which are loans for the purchase of smartphones, where the device is locked and cannot be used if a customer fails to repay the loan.
Virtual banks may also offer credit card products to qualified customers but will highly likely cap the credit line at a small amount, Mr Weerapat said.
