The Bank of Thailand (BOT) on February 21, 2026 activated a new supervisory framework for Systemically Important Retail Payment Systems (SIRPS), designating PromptPay as the first payment system subject to the regime. The move represents a significant regulatory milestone: Thailand becomes the first ASEAN country to apply formal macroprudential-style oversight to a retail instant payment system.

Why This Matters

PromptPay is no longer just a popular payment service - it is now classified as critical national financial infrastructure. With registrations exceeding 90 million (in a country of 72 million people) and daily transaction volumes above 74 million, a PromptPay outage would have systemic consequences for Thailand's economy. The SIRPS designation acknowledges this reality and imposes obligations to match.

The classification mirrors approaches taken by other jurisdictions. The Bank of England designated Faster Payments as a recognised payment system years ago, and India's RBI exercises direct oversight of UPI through NPCI. But Thailand's framework is notable for being codified as a distinct regulatory category with explicit operational requirements, rather than relying on general central bank powers.

What SIRPS Requires

The framework imposes several operational mandates on the SIRPS operator (National ITMX, the interbank switch that runs PromptPay) and all direct participants (commercial banks and payment service providers connected to the system):

Service availability: The SIRPS must target availability levels comparable to international payment infrastructure benchmarks. The framework mandates the ability to recover operations within two hours of a disruption - a recovery time objective that aligns with CPMI-IOSCO principles for systemically important financial market infrastructures.

Business continuity: The operator must maintain a comprehensive business continuity plan covering both IT and non-IT aspects, reviewed annually. This extends beyond typical disaster recovery to include scenario planning for cascading failures across dependent systems.

Risk management: Formal tools and controls to monitor credit, settlement, liquidity, and operational risks. This is particularly relevant given PromptPay settles through BAHTNET (Thailand's RTGS system), creating a direct link between retail payment flows and the high-value settlement layer.

Participant oversight: Direct SIRPS participants must supervise any indirect participants they onboard, ensuring compliance with service agreements and business rules throughout the chain.

PromptPay's Scale

PromptPay's growth trajectory underscores why the BOT acted. Launched in 2017, the system now handles:

Over 90 million registrations (14% year-on-year growth) More than 74 million daily transactions Cross-border QR payment links with Singapore, Vietnam, Japan, Cambodia, Malaysia, Indonesia, China, Hong Kong, and Laos

The platform has fundamentally shifted Thai consumer payments. Online payment volumes surged 13.5% year-on-year as of mid-2025, while credit and debit card usage declined - reflecting a clear shift toward mobile-first, account-to-account payments.

Cross-Border Implications

PromptPay's ASEAN cross-border QR payment network is the most extensive bilateral linkage programme of any instant payment system globally. The SIRPS framework brings these international connections under formal supervisory scope. As Thailand expands cross-border corridors, the framework provides a regulatory foundation for managing the additional complexity of international instant payment flows.

What Practitioners Should Do

Banks operating in Thailand: Review compliance with SIRPS participant obligations, particularly around indirect participant supervision and business continuity requirements. Payment service providers: Assess whether current service agreements meet the new framework's standards. International firms with Thai payment flows: Monitor whether the SIRPS framework affects settlement timing or availability commitments.

Sources: Bank of Thailand - PromptPay; Thailand Introduces Systemically Important Payment System Framework, Starting With PromptPay - Mondaq/Tilleke & Gibbins; Thailand's Digital Payment Revolution - The Nation Thailand.