Thailand’s Entertainment Complex Bill: what the casino legalization plan would have meant for PSPs and investors

Thailand’s draft Entertainment Complex Bill was designed to legalize casinos only inside large integrated resort projects, with very high capital and licensing thresholds. For PSPs, acquirers, and suppliers looking at high-risk markets, the point is simple: this was never going to be a low-friction entry market, even before politics pushed the timetable off the rails.

1. Under the cabinet-approved framework from early 2025, casino operators would have needed to be Thai-registered limited companies or public limited companies with at least 10,000 million THB in paid-up capital, about 290 million USD. That alone filters the market down to a small set of well-capitalized players.
2. The casino floor would have occupied only a fraction of each integrated resort. The rest of the complex would have had to include at least four other non-gaming businesses, such as hotels, shopping centers, sports stadiums, or amusement parks. In other words, the license was tied to a broader tourism project, not a standalone gaming box.
3. The proposed license structure was expensive and long-dated: 30 years, renewable for periods of up to 10 years. The initial issuance fee was set at 5,000 million THB, with an annual fee of 1,000 million THB and a renewal fee of 5,000 million THB.
4. Politically, the project lost momentum in late 2025. Leadership turbulence inside the governing coalition, a shift toward a more conservative government approach, and strong opposition from the Thai Senate forced the plan into pause mode.
5. Legislators, religious groups, and civil society organizations raised concerns about gambling addiction, money laundering risks, and broader social consequences. The Senate then recommended that any future casino legalization be decided by public referendum, and parliament was dissolved in December 2025, effectively freezing major policy decisions until a new administration could stabilize in 2026.

For high-risk payment companies, the takeaway is not that Thailand was “open” or “closed” in some clean binary sense. The structure described here points to a market that, even if reopened, would likely favor large, heavily regulated operators inside integrated resorts — the kind of setup that usually means stricter onboarding, heavier monitoring, and a more cautious approach from banks and PSPs.