DBD Puts 36,277 Foreign-Linked Companies Holding Land Into Its Screening Pool, and Condominium Holdings Are Next

The DBD Has Turned Its Whole Register Into a Nominee Screen, Not Just a Raid Target List #

What Did the DBD Actually Disclose on 18 August? #

• How the 36,277 Companies Split by Risk
• What Happens Next With Condominiums
• The Lawful Channel Is Growing Too
• What This Means If You Hold Property Through an At-Risk Company
• The Better-than-Freehold™ Solution
• FAQ Section
• Related Terms
• Expert Guidance

How the 36,277 Companies Split by Risk #

The DBD split the 36,277 by shareholding shape. Most hold modest land. A meaningful minority holds a great deal of it.

Group A, 31,516 entities, holds foreign shareholding of no more than 49%, mostly limited companies plus 146 partnerships and 737 public limited companies.¹ The DBD calls this group higher risk, because a Thai-majority shareholding on paper proves nothing about who funded it. Within it, 20,537 hold a single land title, but 3,865 hold more than ten rai each. Not just back-garden holdings.¹

Group B, 4,761 entities, holds foreign shareholding above 49%, many lawful under industrial-estate or Board of Investment privileges around Chon Buri and Rayong.¹ Geography matters too: 35,154 sit in sixteen provinces, Bangkok and five neighbours plus ten tourism centres including Phuket and Chiang Mai.¹ Director-General Poonpong Naiyanapakorn's test was blunt: "If a venture is genuinely jointly funded by foreign and Thai investors and foreigners hold no more than 49%, it is lawful. But if the entire foreign investment comes from foreign capital and Thais do not genuinely co-invest, or if Thais hold 51% as nominees, the details must be investigated and legal action taken."¹

What Happens Next With Condominiums #

After land, condominiums are the second dataset, and the concern is familiar: companies using Thai nominees to buy units beyond the foreign quota, then renting or reselling them.

The DBD is still waiting on the Department of Lands; 2,120 records are already earmarked.¹² The Ministry of Commerce has given no timetable. The Condominium Act caps foreign ownership at 49% of aggregate floor area, not unit count, so a few large units absorb the quota fast.

The Lawful Channel Is Growing Too #

None of this closes the door on legitimate investment. The DBD also reported 736 foreign investors approved under the Foreign Business Act in the first seven months of 2026, up 26%, carrying THB 219.208 billion, up 37%.³ Singapore, Japan and China led the inflow. Not property money, but the point stands: the lawful route is open while disguised shareholding is under review. Our Thailand property market analysis covers where that leaves pricing.

What This Means If You Hold Property Through an At-Risk Company #

Being counted in the 36,277 is not a finding against your high-risk property-owning company. But the DBD has already matched its register once, and will do so again for condominiums. The funding trail, not the ratio on the register, is the actual test now. It does not disappear because no raid comes.

The stakes are severe, and paired. Sections 36 and 37 of the Foreign Business Act carry up to three years and a THB 100,000 to 1,000,000 fine, reaching nominee and foreign beneficiary alike, plus court dissolution.⁴ Land Code section 94 lets the Land Department order disposal within 180 days to one year.⁵ Divestment typically takes eight to sixteen weeks, a span Better-than-Freehold™ expects to cut to under four as it scales. Our guide to nominee company risks sets out where exposure sits.

The Better-than-Freehold™ Solution #

Anyone deciding how to hold property now should notice what the DBD's test rewards: structures with no Thai funding to defend. Compliance comes first. Better-than-Freehold™ holds no Thai company; nothing for a screen to flag. Security follows: a 30-year lease, an option agreement, a mortgage and a share pledge, recorded at the Land Office. Benefits complete the picture, ending at succession without Thai probate.

FAQ Section #

Related Terms #

• Nominee Company Risks in Thailand - how nominee exposure arises
• Foreign Business Act Thailand - the statute behind nominee offences
• Thailand Property Market Analysis - how enforcement is shaping supply
• Anti-Money Laundering Act Thailand - the wider enforcement framework

Expert Guidance #

Immediate Action Required #

Establish, honestly, whether the Thai shareholders in your company genuinely funded their stake. Don't wait for a letter; the data match already happened once. Contact the Better-than-Freehold™ advisory team for a confidential compliance assessment.

Long-term Security Strategy #

Move toward a structure where that question never needs answering. A registered lease-based structure removes the funding trail the DBD now screens for nationwide.

Conclusion #

The number that matters is not 36,277. It is 123,542, the DBD's full count of land-holding companies, matched against every foreign-linked entity at once. Enforcement that once moved island by island is now a standing national screen. Owners inside it can still choose their timing. Later, that choice may not be theirs.

References #

This article is provided for general information only and does not constitute legal, tax, or investment advice. Laws and enforcement practices change; obtain advice tailored to your situation before acting.