Proposed Super License System for Hotel Businesses in Thailand
1. Background
The Office of the Public Sector Development Commission (OPDC) has made further progress on the proposed “Super License” system, as confirmed in a recent update by the Deputy Government Spokesperson. This article builds on our earlier coverage (Accommodation Reform: Proposed Super License and Stronger Guest Protections) regarding the proposed Accommodation Act B.E. …. (“the Accommodation Act”) and on our analysis of the Draft Act on Facilitation in the Consideration of Licenses and Provision of Services to the Public B.E. …. It examines the proposed licensing framework, the application procedures, the legislative status, and the implications for hotel operators and investors in Thailand.
2. Licensing Framework
2.1 Primary License (the “Super License”)
It is proposed that hotel business licenses for Type 1, Type 2, Type 3 and Type 4, as classified under the Ministerial Regulation Prescribing Types and Criteria for Hotel Business Operations B.E. 2551 (2008) issued by the virtue of the Hotel Act B.E. 2547 (2004), be designated as the primary license under the Super License system. An operator applying for the primary license may also apply for secondary licenses covering other activities associated with hotel operations, as specified in the Royal Decree that will be issued by the virtue of the Accommodation Act.
2.2 Secondary Licenses
Licenses and authorizations required under specific legislation for activities associated with hotel operations are proposed to be designated as secondary licenses. Operators may consider applying for one or more of them together with their Super License application. The proposed categories are:
- Businesses that may be hazardous to health (public health law): hotels and other temporary accommodation, fitness centers, swimming pools, theaters, entertainment activities, amusement parks, bowling alleys, game arcades, beauty salons, golf courses, laundry services and EV charging stations.
- Liquefied petroleum gas (LPG) storage facilities: licenses or notifications for consumer facilities under fuel control law.
- Entertainment establishments: licenses under entertainment establishment law.
- Karaoke businesses: licenses under film and video law.
- Liquor sales: licenses under excise tax law.
- Tobacco sales: licenses under excise tax law.
- Zoos: licenses to establish and operate a zoo under wildlife conservation law.
- Structures encroaching on rivers or waterways: licenses for construction activities not subject to an Environmental Impact Assessment (EIA) report.
Whether each activity is ultimately included as a secondary license will depend on its relevance to hotel operations, the authority granted under the applicable legislation, and the relevant licensing requirements.
3. Application and Licensing Procedures
To improve licensing efficiency, eliminate procedural duplication and reduce the administrative burden on operators, it is proposed that all applications be submitted and processed through an electronic system.
3.1 Submission of Applications
The Department of Provincial Administration is proposed to act as the receiving authority for Super License applications and for any accompanying secondary license applications.
3.2 Verification of Applications and Supporting Documents
Once the Department of Provincial Administration has verified that the applications and supporting documents are accurate and complete, it will forward them to the agencies responsible for the respective secondary licenses. Each agency will then review the application within its statutory powers and duties.
3.3 Integrated On-Site Inspections
Where an on-site inspection is required before a license can be granted, the relevant licensing authorities are expected to coordinate their inspections and, where practicable, conduct them jointly in a single visit. The Department of Provincial Administration will coordinate the process, set the inspection date and time, and notify the relevant agencies in advance.
3.4 Issuance of the License
Upon approval, a single Super License is proposed to be issued, specifying the activities for which the license holder has obtained the relevant secondary licenses and is authorized to operate.
3.5 Refusal of the Super License
If the Department of Provincial Administration refuses to grant the Super License, all secondary license applications submitted in the same application will be deemed refused. An applicant wishing to appeal must submit the appeal electronically to the relevant licensing authority. The criteria, procedures and time limits for filing and considering appeals will be governed by the applicable legislation.
Where the refusal concerns only a secondary license, the applicant may proceed with the remaining secondary license applications without appealing the refusal.
3.6 Validity Period
A secondary license may be granted the same five-year validity period as the primary license. To obtain this, the applicant must notify the Department of Provincial Administration at the time of application and pay the fees for the full five-year validity period of each relevant secondary license.
4. Legislative Status
The OPDC is currently drafting the proposed Accommodation Act. A public consultation on the principles of the Super License system for hotel businesses is open from 19 October to 17 November 2026.
No timeline for enactment of the Accommodation Act has been announced. The Deputy Government Spokesperson has, however, recently given an update on the initiative as can be found here.
5. Recommended Actions for Operators and Investors
- Participate in the public consultation: Hotel operators and other interested stakeholders are encouraged to submit comments on the principles and details of the proposed Royal Decree through the official consultation portal.
- Review existing licenses and business plans: Existing operators should monitor how their current licenses and approvals will be treated under the new framework. Investors should assess their business plans against the licensing classifications and requirements that are ultimately adopted.
6. Key Takeaways
- Single and coordinated process: Type 1–4 hotel licenses are proposed to serve as the primary license, allowing operators to apply for related secondary licenses in one process.
- Broad secondary scope: Secondary licenses would cover hotel-related activities such as health-hazardous businesses, entertainment establishments, karaoke, liquor and tobacco sales, zoos and certain structures encroaching on rivers or waterways.
- Centralized administration: The Department of Provincial Administration would be the single point for receiving applications and coordinating with the licensing authorities.
- Expected benefits: The initiative aims to simplify licensing procedures, shorten processing times and reduce costs for hotel operators.
Author: Panisa Suwanmatajarn, Managing Partner.
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