Introduction
Thailand has emerged as one of Southeast Asia’s most progressive and mature jurisdictions for real estate tokenisation. With a digital asset regulatory framework dating to 2018, a Securities and Exchange Commission (SEC) that has actively approved major tokenisation projects, and a government committed to positioning Bangkok as a regional digital asset hub, the country offers both regulatory clarity and commercial momentum .
The numbers demonstrate real-world viability. RealX, a landmark project backed by three Park Origin condominium towers in Bangkok, raised approximately THB 2.4 billion (USD ~68 million) through the sale of 13.19 million tokens . Sansiri’s SIRIHUB project raised THB 2 billion in 2021, followed by SIRIHUB2 which closed at THB 2.49 billion with 6% fixed annual returns . These are not pilot experiments or sandbox trials—they are live, regulator-approved, commercially significant offerings traded on licensed Thai exchanges .
Yet this momentum operates within clear legal boundaries. Cryptocurrency is not legal tender in Thailand, and the Bank of Thailand prohibits its use for everyday payments, including property transactions. Token holders gain only economic rights through Special Purpose Vehicles (SPVs) or trusts—not legal title to land recorded with the Land Department . The Condominium Act’s 49% foreign ownership cap and Foreign Exchange Transaction Form (FET) requirements remain in force.
The open‑source SQMU standard—where 1 token equals 1 verified square metre of property, built on auditable ERC‑1155 smart contracts—is designed to operate within this framework. By anchoring each token to a measurable physical unit, SQMU enhances transparency and supply determinism while remaining fully compatible with Thailand’s SPV‑based tokenisation model. When combined with the SQMU WordPress plugin, the deployment of compliant tokenisation infrastructure becomes accessible to property owners and developers.
This article analyses Thailand’s real estate tokenisation regulatory framework, examines the landmark RealX precedent as a model for SEC approval, and demonstrates how the SQMU standard can be implemented in compliance with Thai law. For a comprehensive regulatory analysis, refer to the Thailand real estate tokenisation guide. For technical deployment details, see the open‑source SQMU implementation.
Thailand’s Regulatory Framework for Tokenised Real Estate
Thailand’s approach to digital assets involves multiple regulatory bodies with distinct mandates working in coordination.
Securities and Exchange Commission (SEC)
The SEC is the primary regulator for digital assets under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018) . The SEC’s jurisdiction covers digital asset exchanges, brokers, dealers, ICO portals, custodial wallet providers, fund managers, and advisors .
The SEC has demonstrated a progressive yet prudent approach, approving major real estate tokenisation projects while maintaining rigorous standards for disclosure, governance, and investor protection . As of 2025, the SEC has authorised 12 exchanges, 13 brokers, three dealers, and nine ICO portals .
The SEC publishes annual strategic plans to guide market development. The 2026–2028 plan prioritises asset tokenisation and regulated cryptocurrency ETFs, aiming to expand the digital asset market from its current THB 950 billion (USD ~27 billion) size .
Bank of Thailand (BOT)
The Bank of Thailand is the central bank, responsible for monetary policy, payment systems, and financial stability. The BOT does not recognise cryptocurrency as legal tender and has strongly discouraged its use for everyday payments, including property transactions .
Businesses facilitating unlicensed crypto payment arrangements face criminal penalties, including imprisonment of up to five years and fines reaching THB 2 million. Property transfers connected to digital asset payments may face delays, voidance, or financial investigation .
However, the BOT launched an Enhanced Regulatory Sandbox on 14 June 2024, allowing financial service providers to test distributed ledger technologies and smart contracts for programmable payments in a controlled environment . The SEC revised Regulation 5/2565 to exempt participants in the BOT’s sandbox from restrictions on facilitating payments .
Ministry of Finance
The Ministry of Finance serves as the licensing authority for digital asset businesses; the SEC evaluates applications before the Ministry grants licenses . The Ministry has driven Thailand’s digital asset hub ambitions through strategic tax policy :
- Indefinite VAT exemption on cryptocurrency and digital token trading (from early 2024)
- Five-year personal income tax exemption (2025–2029) on gains from trades conducted on licensed domestic platforms
- Corporate income tax and VAT exemptions for investment token issuers
Land Department
The Land Department administers land registration and title transfers under the Civil and Commercial Code and the Condominium Act. For tokenised real estate, token holders gain only economic rights through SPVs or trusts—not legal title to land recorded with the Land Department .
Primary Legislation and Rules
Emergency Decree on Digital Asset Businesses B.E. 2561 (2018) establishes Thailand’s foundational digital asset framework. It distinguishes between “cryptocurrencies” and “digital tokens,” creates separate categories of regulated activity, and introduces licensing requirements for business operators .
Key SEC updates include:
Anti-Money Laundering and Tax Framework
Digital asset business operators are treated as financial institutions under Thailand’s Anti-Money Laundering Act. They must implement customer due diligence measures, including enhanced procedures for high-risk clients, and report suspicious transactions to the Anti-Money Laundering Office .
The tax regime for digital assets has been substantially improved:
The Landmark RealX Precedent
RealX represents the most significant real estate tokenisation project in Thailand to date and serves as a model for SEC approval .
Key facts:
- Raised approximately THB 2.4 billion from the sale of 13.19 million tokens at THB 182 each
- Underlying assets: three Park Origin condominium towers in Bangkok (Phrom Phong, Phayathai, Thonglor)
- Token structure: investors receive quarterly yields of 4–5% for the first five years, followed by payouts tied to condo sales as tokens are redeemed and burned
- Trading began September 2023 on TDX, a licensed Thai exchange
- SEC approval required disclosure, governance standards, and baht-denominated payouts on licensed exchanges
Token structure:
- Tokens represent economic rights to rental income and capital appreciation from the three properties
- Legal title to the properties is held by SPVs, not token holders directly
- Investors receive quarterly yields in Thai Baht on licensed exchanges
- At the end of the term, tokens are redeemed and burned as properties are sold
Precedent value for the industry:
- Establishes SEC approval as commercially achievable
- Validates the SPV-based economic rights model
- Demonstrates investor appetite for tokenised real estate
- Proves the workflow: SEC application → ICO portal → exchange listing → secondary trading
Regulatory lessons from RealX:
- SEC approval required comprehensive disclosure documents similar to traditional securities offerings
- Baht-denominated payouts on licensed exchanges demonstrate that crypto assets can be bridged to fiat
- Governance standards for token holder protection are enforced
For SQMU-based projects, RealX provides a proven template that can be adapted. The open-source SQMU standard adds supply determinism (1 token = 1 m²) and onchain transparency to this established model.
Complementary projects—SIRIHUB (THB 2 billion, 2021) and SIRIHUB2 (THB 2.49 billion, 6% fixed annual returns)—further demonstrate the market’s maturity . Collectively, Thailand’s real estate-backed token market has reached THB 4.93 billion (USD ~141 million) .
Token Classification Under Thai Law
Under the Emergency Decree and SEC regulations, real estate tokens are classified as digital tokens—specifically, investment tokens where value depends on the future performance of the underlying real estate assets .
Key classification considerations :
- Digital tokens are regulated as a distinct asset class, separate from cryptocurrencies
- Tokens that confer economic rights to property income and appreciation are classified as investment tokens
- Token issuance requires SEC approval or must be conducted through an SEC-approved ICO Portal
- Secondary trading must occur on SEC-licensed exchanges (TDX or approved alternatives)
| Role | License Type | Number Licensed (2025) |
|---|---|---|
| Digital Asset Exchange | License | 12 |
| Digital Asset Broker | License | 13 |
| Digital Asset Dealer | License | 3 |
| ICO Portal | License | 9 |
| Custodial Wallet Provider | License | 2 |
Offshore Operator Extraterritorial Obligations
Amendments to the Emergency Decree in 2025 extended licensing obligations extraterritorially, requiring offshore operators who “target” users in Thailand to obtain relevant licences. Targeting is broadly defined as engaging in any of the following activities :
- Using Thai language on websites or customer service offerings
- Using a “.th” or “.ไทย” domain
- Accepting or processing Thai Baht payments
- Applying Thai laws for user agreements
- Advertising specifically to Thai residents
- Establishing an office in Thailand and hiring Thai staff
Foreign operators engaging in such activities are required to obtain a licence from the SEC or partner with a licensed domestic entity prior to offering services to Thailand-based residents. Failure to comply may result in criminal penalties, including imprisonment for two to five years and/or fines between 200,000 and 500,000 Baht .
Real Estate Law and the SPV Model
Thai law imposes a fundamental constraint on real estate tokenisation: token holders gain only economic rights, not legal title to land or buildings. Under the Civil and Commercial Code, digital tokens are classified as non-corporeal objects (Section 138)—assets without physical form that can be bought, sold, exchanged, leased, or used as collateral. However, the relationship between token holders and the underlying asset pool exists solely as civil contractual arrangements, differing fundamentally from statutory ownership documents such as land title deeds or condominium unit title certificates that are directly recognised by law .
For compliant real estate tokenisation, the following structure is required :
- A Thai SPV (limited company) or trust holds legal title to the property
- Token holders subscribe to shares or trust units in the SPV
- The SQMU ERC‑1155 contract represents these shares digitally
- Tokens confer economic rights: rental income, capital appreciation, and sale proceeds
- Legal ownership remains with the SPV, not token holders
- Onchain token holdings are mirrored in the SPV’s share register
The RealX project demonstrates this structure in practice: token holders receive quarterly yields and eventual payout from property sales, but they are not direct co-owners of the condominium units. The SPV holds title to the three Park Origin towers, and token holders have contractual claims against the SPV .
Condominium Act Requirements
The Condominium Act B.E. 2522 (1979) governs foreign ownership of condominium units :
- Foreign ownership is limited to 49% of total unit area in any condominium project
- Foreign buyers must remit foreign currency into Thailand
- Payment must be documented with a Foreign Exchange Transaction Form (FET)
- Title transfer requires registration with the Land Department
For tokenisation, this means that if tokens are sold to foreign investors, the 49% cap applies at the SPV level if the SPV owns condominium units. The token offering must track foreign ownership proportion, and issuance must stop when the 49% threshold is approached .
Foreign Ownership Compliance
Tokenised projects must implement compliance mechanisms to enforce foreign ownership caps :
| Requirement | Implementation |
|---|---|
| Foreign ownership tracking | Smart contract tracking of token holder nationality |
| KYC/AML | Mandatory identity verification for all token holders |
| FET documentation | Required for foreign currency remittances |
The SQMU open‑source contract’s whitelist functionality can be configured to enforce nationality‑based restrictions, with a mechanism to pause issuance when the 49% threshold is reached.
The ICO Portal Pathway
Public token offerings in Thailand must use SEC-approved ICO Portals . This requirement is critical for compliant issuance.
ICO Portal functions:
- Conduct due diligence on the issuer and the project
- Prepare and submit offering documents to the SEC
- Manage the token sale process
- Ensure KYC/AML compliance for investors
- Maintain ongoing reporting
Approved ICO Portals include:
- XSpring Digital (first SEC-authorized ICO portal for real estate tokens)
- Other SEC-licensed portals
The SIRIHUB and SIRIHUB2 offerings were conducted through XSpring Digital, demonstrating the portal’s capability for substantial raises .
Why the ICO Portal model is important for SQMU:
- The SQMU standard can be integrated into the ICO Portal workflow
- The portal handles SEC compliance, reducing the issuer’s burden
- Tokens can be listed on licensed exchanges after the offering
For SQMU‑based projects, the path is: engage an SEC-approved ICO Portal, integrate the SQMU WordPress plugin for the public interface, deploy the SQMU ERC‑1155 contract, and list on a licensed DAX.
Tokenisation Routes Available in Thailand
Three primary routes exist for tokenising real estate in Thailand :
| Route | Timeline | Legal Entity | Regulator | Investor Access | Best For |
|---|---|---|---|---|---|
| Local ICO Portal | 6–8 weeks | Thai SPV | SEC Thailand | Domestic + diaspora | Thai developers |
| Regional Fund (Singapore/HK) | 8–12 weeks | Singapore/HK SPV | MAS (SG) or SFC (HK) | Regional institutional | Cross-border capital |
| Offshore Issuer + Geo‑Block | 2–4 weeks | Offshore entity | Offshore jurisdiction | Global (excl. Thailand) | International issuers |
How SQMU Aligns with Thailand’s Regulatory Framework
The SQMU standard offers a compliant technical foundation for real estate tokenisation in Thailand. By anchoring each token to a verified square metre of property, it enhances transparency, supply determinism, and investor protection, directly supporting SEC and BOT objectives .
1. Measurement-Based Transparency
- Property area is recorded in token metadata, along with title deed reference and surveyor’s certification hash.
- 1 SQMU = 1 verified square metre aligns with Thailand’s existing property measurement conventions.
- When the SQMU token is minted, total supply for that token ID is set and locked, preventing any action that could increase supply later without a contract‑level override.
2. Alignment with SPV Model
- The SQMU standard’s 1 m² = 1 token rule maps directly to SPV share capital.
- Tokens represent economic rights, not legal title—consistent with Thai law.
- SQMU’s ERC‑1155 multi-token architecture allows a single contract to represent multiple properties held by the same SPV.
3. Compliance Features
- Whitelist controls enforce KYC and nationality‑based restrictions (enforcing 49% foreign ownership cap).
- Onchain audit trail allows regulators to inspect investor compliance.
- Transfer restrictions enforce lock‑up periods or jurisdictional caps.
- Metadata stores property details, SPV information, and regulatory references.
4. Integration with ICO Portal Workflow
- The SQMU WordPress plugin can be configured to work with SEC-approved ICO Portals.
- Post‑offering, tokens can be listed on licensed exchanges (TDX or alternatives).
5. Supply Determinism as Investor Protection
- Fixed supply tied to verified area prevents dilution.
- Investors can independently verify token backing; open‑source code allows public inspection.
- The blockchain is the ultimate source of truth for token holder balances.
6. Cross‑Chain Options for Rental Payments
- SQMU ownership tokens may remain on permissioned or compliant chains.
- Rental rights could be separated onto public chains for efficiency, with reference back to ownership tokens.
The open‑source nature of the SQMU standard allows the SEC and auditors to inspect the smart contract code directly, verifying that supply is fixed, whitelist controls are correctly implemented, and no hidden functions violate Thai law. This transparency is a distinct advantage over proprietary systems .
Practical Implementation with SQMU in Thailand
For property owners, developers, or platforms ready to tokenise Thai real estate, the following steps provide a structured approach:
Step 1: Engage Local Legal and Regulatory Advisors
Work with a Thai law firm experienced in digital asset regulations, property law, and tax compliance. Key tasks: conducting due diligence on property title and area certification, forming the SPV (Thai limited company) and drafting constitutional documents, and preparing SEC disclosure documents.
Step 2: Select Tokenisation Route
Most SQMU‑based projects targeting Thai investors will use the Local ICO Portal route: engage an SEC-approved ICO Portal (e.g., XSpring Digital), prepare offering documents with the portal, and comply with SEC disclosure and governance standards.
Step 3: Property Tokenisation
- Certify the property’s area with a licensed surveyor.
- Verify title deed and ensure no encumbrances.
- Confirm foreign ownership compliance with Condominium Act 49% cap.
Step 4: SQMU Contract Deployment
- Set up WordPress with the SQMU plugin.
- Connect wallet and select the chosen EVM chain (Avalanche C‑Chain, Arbitrum, or Base).
- Deploy SQMU ERC‑1155 contract with the guided wizard (supply = certified area).
- Create token ID for the property; lock supply at property area.
- Configure compliance features: whitelist control, foreign ownership caps, transfer restrictions.
Step 5: SEC Approval and ICO Portal Integration
- Work with the ICO Portal to submit offering documents to the SEC.
- Conduct KYC/AML checks on all token holders.
- Approve the offering for primary sale.
Step 6: Token Distribution
- Conduct primary sale via the ICO Portal and the
AtomicSQMUDistributorcontract. - Accept payment in Thai Baht (via on‑ramp) or approved cryptocurrencies (BTC, ETH).
- Ensure foreign ownership tracking throughout the sale.
Step 7: Secondary Market Listing
- List tokens on SEC-licensed Digital Asset Exchange (e.g., TDX).
- Enforce ongoing compliance: periodic audits, investor reporting, AML monitoring.
Step 8: Taxation and Reporting
- Leverage tax exemptions: VAT exemption, 5‑year capital gains tax holiday.
- File required reports with SEC, Land Department, and Revenue Department.
Implementation Timeline
| Phase | Activities | Duration |
|---|---|---|
| Weeks 1–2 | Legal structuring, SPV formation, property certification | 2 weeks |
| Weeks 3–4 | Token contract deployment, ICO Portal engagement | 2 weeks |
| Weeks 5–6 | SEC review and approval (via ICO Portal) | 2–4 weeks |
| Weeks 7–8 | Primary sale execution | 1–2 weeks |
| Ongoing | Secondary trading, compliance reporting | Continuous |
Total: 8–12 weeks to live tokenised property on licensed Thai exchange.
SQMU-Powered Tokenisation in Thailand: Example Structure
Consider a condominium in Bangkok with 500 m² of total area, sold in fractional ownership via tokenisation.
Token structure:
- Property area: 500 m² → SQMU supply: 500 tokens (1 token = 1 m²)
- Token price: tied to appraisal per m² (e.g., THB 200,000 / token if property appraised at THB 100 million)
- Total raise: THB 100 million
Legal structure:
- Thai SPV holds legal title to the condominium units
- SQMU token holders have economic rights to rental income and appreciation
- Foreign investors allowed up to 49% of token supply (245 tokens)
Allocation:
- Sell tokens through SEC-approved ICO Portal
- KYC/AML screening for all token holders
- Whitelist enforcement to track foreign vs. Thai ownership
Post‑offering:
- Tokens trade on licensed Thai exchange (TDX or others)
- Quarterly rental yield distributed in Thai Baht
- SQMU contract enforces transfer restrictions
The open‑source SQMU contracts provide the technical backbone for this structure, ensuring supply determinism and investor protection. The WordPress plugin enables the issuer to manage the token offering through a familiar content management system.
Comparison of Implementation Approaches
| Aspect | Local ICO Portal | Regional Fund (SG/HK) | Offshore Issuer |
|---|---|---|---|
| Timeline | 6–8 weeks | 8–12 weeks | 2–4 weeks |
| Legal entity | Thai SPV | Singapore/HK SPV | Offshore entity |
| Regulator | SEC Thailand | MAS (SG) or SFC (HK) | Offshore jurisdiction |
| Investor access | Domestic + diaspora | Regional institutional | Global (excl. Thailand) |
| Best for | Thai developers | Regional capital | Global reach |
SEC 2026–2028 Strategic Plan: Future Opportunities
The SEC’s newly published three‑year strategic plan (2026–2028) contains several key initiatives relevant to real estate tokenisation :
Asset tokenisation expansion:
- Extending the tokenisation of real‑world assets (RWA) beyond real estate to other asset classes
- Establishing clearer regulatory frameworks for secondary trading of tokenised assets
Regulated cryptocurrency ETFs:
- Allowing local issuance of crypto ETFs tracking digital assets
- Supporting fund investment in tokenised securities
Licensing and investor protection:
- Clarifying digital asset licensing pathways
- Strengthening AML/CFT surveillance for cross‑border transfers—an area where SQMU’s open‑source transparency provides a distinct advantage
- Introducing digital asset service provider tiered licensing
Alignment with SQMU:
The SEC’s focus on RWA tokenisation creates a favourable environment for the SQMU standard. The open‑source, transparent, supply‑deterministic nature of SQMU aligns with the SEC’s emphasis on investor protection. The SEC has already demonstrated approval of real estate tokenisation through RealX, and the 2026–2028 plan signals continued expansion .
For SQMU‑based projects, this means the regulatory window is open, and participation in the first wave of compliant tokenisation offers a significant first‑mover advantage.
Conclusion
Thailand offers one of Southeast Asia’s most mature, proven, and accessible regulatory frameworks for real estate tokenisation. With major projects such as RealX (THB 2.4 billion), SIRIHUB (THB 2 billion), and SIRIHUB2 (THB 2.49 billion) already live on licensed exchanges, the model is validated. The SEC’s 2026–2028 strategic plan signals continued expansion, while the tax environment—indefinite VAT exemption and a 5‑year capital gains tax holiday—favours investment .
The open‑source SQMU standard is designed to operate within this framework. Its core principles—1 token = 1 verified square metre of property, supply determinism, onchain transparency, and ERC‑1155 multi‑token architecture—align with the SEC’s disclosure, governance, and investor protection requirements . The SQMU WordPress plugin reduces deployment complexity to weeks, not months.
For property owners, developers, and platforms seeking to tokenise Thai real estate, the path is now clear: engage licensed professionals, form an SPV, work with an SEC‑approved ICO Portal, deploy the SQMU standard, and distribute tokens on a licensed exchange.
Explore the open‑source SQMU code, install the WordPress plugin, and contact consulting servicesfor guidance on SEC compliance, ICO Portal engagement, and SPV structuring.
The future of real estate tokenisation in Thailand is not theoretical—it is already being built, and SQMU is ready to be its foundation.
Further Reading
- Real Estate Tokenisation in Thailand: Regulatory Framework and Legal Analysis
- Open Source Real Estate Tokenisation: The SQMU Standard
- SQMU Standard: Real Estate Tokenisation by the Square Metre
- WordPress Real Estate Tokenisation Plugin – One‑Click SQMU Deployment
- r3nt: A Structured Framework for Tokenised Rental Contracts
- How Distribution, Investor Access, and Market Making Drive Tokenised Real Estate Platforms
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