Since March 2026, the Thailand Board of Investment (BOI) has introduced a significant change to its project monitoring requirements. Companies holding a BOI promotion certificate are now required to submit progress reports on a quarterly basis, replacing the previous schedule of bi-annual submissions in February and July.
With reporting now more frequent and the window between deadlines significantly narrowed, companies that have not already reviewed their internal compliance processes should do so promptly.
Scope of the New Requirement
The quarterly reporting obligation applies during the implementation phase of a promoted project, that is, from the date the promotion certificate is issued until the BOI operating licence is obtained. Once a company has received its operating licence, this particular reporting requirement no longer applies.
Reports must be submitted through the BOI’s e-Monitoring system within 60 days of the end of each quarter. The reporting schedule and corresponding deadlines are as follows:
- Q1 (January to March): deadline 31 May
- Q2 (April to June): deadline 31 August
- Q3 (July to September): deadline 30 November
- Q4 (October to December): deadline 28 February of the following year
The first deadline under the new system is 31 May 2026, covering the period from January to March 2026.
Why Does This Matter?
While the reporting frequency has changed, the BOI’s penalty framework has not, and the timeline within which those penalties can be triggered has compressed considerably. Missing a single reporting deadline may result in the suspension of BOI rights and benefits, including the processing of visa and work permit applications for foreign employees. If two consecutive deadlines are missed, the BOI promotion may be revoked permanently.
Under the previous twice-yearly schedule, two missed deadlines represented a full year of non-compliance before revocation became a risk. Under the new quarterly structure, that same threshold can be reached in as little as six months. For companies that have relied on informal tracking or treated reporting as a benign administrative process, this procedural change warrants a re-examining of internal processes.
What Should BOI Promoted Companies Do Now?
For companies that already hold a BOI promotion certificate, the transition to quarterly reporting is automatic. Any previous conditions referencing the February and July reporting schedule have been updated by the BOI without requiring a formal amendment to the promotion certificate. No application or notification to the BOI is required in connection with this change alone.
However, companies should ensure that their internal compliance calendars, outsourced service providers, and any relevant personnel are all operating under the new quarterly schedule rather than the previous one.
Given that the first quarterly deadline falls on 31 May 2026, companies in the implementation phase of a promoted project should take practical steps without delay. This includes confirming access to the BOI e-Monitoring system, identifying who within the organisation is responsible for preparing and submitting progress reports, and ensuring that the relevant data is being captured on an ongoing basis.
Companies that have delegated this function to an external service provider should confirm that the provider is aware of the new schedule and is prepared to meet quarterly, rather than twice-yearly, submissions.
More broadly, this change is a reminder that BOI promotion carries ongoing compliance obligations throughout the implementation phase, not only at the point of application. Companies that treat BOI compliance as a one-time exercise risk falling into difficulty as their projects progress.
The BOI’s move to quarterly progress reporting reflects a broader trend toward more active and frequent oversight of promoted projects. While the change does not alter the substantive requirements of BOI promotion, it does increase the cadence at which companies must demonstrate compliance and the speed at which penalties can accrue.
Companies with existing promotion certificates should therefore treat the 31 May 2026 deadline as an immediate action point and use it as an opportunity to put more robust reporting processes in place for the remainder of the year.
This article is provided for general information purposes only and does not constitute legal advice. While care has been taken to ensure accuracy at the time of writing, laws and administrative practices may change. Specific advice should be sought for individual circumstances.
For legal advice regarding BOI compliance, promotion certificates, or related corporate matters in Thailand, please contact our team at [email protected].
