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BOT Notification 4/2568

BOT 4/2568 Is Live. Is Your Mobile Banking App Ready?

Notification 4/2568 sets minimum Mobile Banking security standards for every financial institution under the Financial Institutions Businesses Act: one user account on one device, face comparison on high-value transfers, no links in SMS or email, and controls on the app, the device, and the data. We break down each control and show you how to prove it holds before your next BOT examination.

4/2568
Notification
1:1
Account to Device
฿50K
Face Check From
฿5K
Risky-OS Daily Cap
Get Mobile Banking Assessment
Understanding the Regulation

What is BOT Notification 4/2568?

The Bank of Thailand issued Notification 4/2568 under sections 39 and 41 of the Financial Institutions Businesses Act. It targets unauthorized payment fraud, where a criminal installs malware, takes control of a user's device or app, and transfers money without consent. It replaced the 2019 Guiding Principles for Mobile Banking Security (ว. 1922/2562).

One user account per Mobile Banking app at each institution, used on one mobile device only (clause 5.3.1(3))
Face comparison with presentation attack detection for transfers of ฿50,000 or more, each time daily transfers reach another ฿200,000, and any raise of the daily limit to ฿50,000 or more (clause 5.3.1(4))
No links of any kind in SMS or email, unless the user asks, one request at a time (clause 5.3.1(1), Q&A item 2)
No service on rooted or jailbroken devices, on tampered apps, or while risky accessibility, remote-control, or screen-overlay apps run (clauses 5.3.2(2.3), (3.1), (3.2))

Reference: BOT Notification No. 4/2568, clause 5.3

Who Falls Under BOT 4/2568?

4/2568 applies to every financial institution under the Financial Institutions Businesses Act (clause 4) that offers Mobile Banking to individual users. Specialized financial institutions and e-money licensees fall under other BOT rules.

Financial institutions under the Financial Institutions Businesses Act, such as commercial banks, that offer withdrawal, transfer, or payment through a Mobile Banking app to individuals
Institutions whose Mobile Banking runs inside another provider's app (app-in-app): the controls still apply (Q&A item 1)
Institutions with more than one Mobile Banking app: the one-account, one-device limit applies to each app (Q&A item 6)
Outside 4/2568: specialized financial institutions, which follow BOT Notification 5/2566 on IT risk, including its yearly penetration test
Outside 4/2568: e-money licensees, whose apps follow BOT Notification 18/2568
Core Security Mandates

The 4/2568 Controls in Six Groups

The notification sets controls in two parts: preventing unauthorized payment fraud (clause 5.3.1) and securing the Mobile Banking service (clause 5.3.2). We group them into six areas.

One Account, One Device, Safe Devices

Each user gets one user account per Mobile Banking app at each institution, used on one device only (5.3.1(3)). The app must not run on rooted or jailbroken devices (5.3.2(3.1)). Institutions must avoid serving devices on operating systems that a recognized body such as TB-CERT flags as risky; where they still serve them, they must warn users and cap transfers at ฿5,000 a day (5.3.2(3.3)).

Face Comparison and Transfer Limits

Face comparison with presentation attack detection, such as liveness detection, is required for transfers of ฿50,000 or more, each time daily transfers reach another ฿200,000, and any raise of the daily limit to ฿50,000 or more (5.3.1(4)). Daily withdrawal and transfer caps follow user risk groups; BOT gives a ฿50,000 daily cap for users under 15 as an example, with a controlled exception process (5.3.1(5)).

Link Rules

No links in SMS or email, in any form, including URL text that cannot be clicked, images, and QR codes (5.3.1(1), Q&A item 2). On social media, no links that ask for login or personal data such as usernames, passwords, OTPs, PINs, ID numbers, or dates of birth. A link may go out when the user asks, one request at a time, with a note that it was sent only on request.

Fake Apps and Risky Apps

Institutions must monitor official app stores such as Google Play and the Apple App Store for fake or impersonating apps and respond in time, with a response process for fakes outside those stores (5.3.1(2)). The app must not run while another app behaves riskily: unneeded accessibility services, remote control, or hiding or stealing screen content (5.3.2(3.2)).

App Integrity and Patch Timelines

Check the app for tampering at every launch and block modified copies (5.3.2(2.3)). Obfuscate source code (2.5), stop serving old app versions (2.2), request only the permissions the app needs and review them on significant change (2.1), and secure sessions against hijacking (2.4). New vulnerabilities must be closed within a suitable time or by the deadline BOT sets (5.3).

Data and Channel Protection

Avoid storing sensitive data on the device; where you must, encrypt it with an international-standard method and destroy it after use (5.3.2(1.1)). Mask passwords and blur the screen when the app is minimized (1.2). Use a secure protocol with certificate pinning or an equivalent method, plus application-layer encryption of sensitive data in transit (1.3).

Assessment Coverage

What We Test in Your Mobile App

4/2568 sets controls and contains no testing clause. We verify each control with a test based on the OWASP MASTG, a Reconix method mapped clause by clause to the notification.

iOS and Android application security testing to the OWASP MASTG, mapped to 4/2568 clause 5.3
Face comparison and presentation attack detection bypass on the ฿50,000 and ฿200,000 triggers
One-account, one-device binding and session hijacking resistance
Transfer limit enforcement, including risk-group daily caps and limit-raise checks
Rooted and jailbroken detection, anti-tampering, and blocking of risky accessibility, remote-control, and overlay apps
Certificate pinning, application-layer encryption, and sensitive data stored on the device
Old-version blocking, obfuscation strength, and permission review

Duties That Continue After Launch

These four clauses create work after go-live, and each one needs evidence when BOT asks.

Close New Vulnerabilities in Time

When a new vulnerability is found, the institution must put protection in place and close it within a suitable time, or by the deadline BOT sets (clause 5.3).

Waivers Are Case by Case

An institution that cannot meet a control must apply to BOT with its reasons and a plan to comply. BOT decides within 30 business days of a complete request and may add conditions (clause 5.4).

App-in-App Counts

The controls apply whether users reach Mobile Banking through the institution's own app or through another provider's app (Q&A item 1).

Risky Operating Systems

If you still serve operating systems flagged as risky, you must warn those users and cap their transfers at ฿5,000 a day (clause 5.3.2(3.3)).

Legal Framework

Related BOT Rules

4/2568 sets controls. The yearly penetration test and the e-money app rules sit in other BOT notifications.

BOT Notification 5/2566: IT Risk Supervision

Requires a penetration test by independent internal or external experts of Internet-facing systems at least once a year and on significant change (attachment 2, clause 6.7). BOT's Q&A names Mobile Banking as one of those systems (item 3). A security test is also due before go-live (clause 7.2). Covers financial institutions and specialized financial institutions.

BOT Notification 18/2568: e-Money Mobile Apps

Sets app controls for e-money licensees whose app transfers to accounts at other providers, including certificate pinning, anti-tampering, obfuscation, and rooted or jailbroken blocking, with new vulnerabilities closed in a suitable time (clauses 4 and 5.2.2).

Financial Institution Business Act B.E. 2551 (2008)

BOT issued 4/2568 under sections 39 and 41 of this Act, and the notification applies to every financial institution under it (clauses 2 and 4).

Our Approach

How We Validate BOT 4/2568 Compliance

We map each control in 4/2568 to a test, back every finding with a proof of concept, and include one retest of your fixes.

1
Device binding validation and rooted or jailbroken detection bypass (5.3.1(3), 5.3.2(3.1))
2
Face comparison and presentation attack detection bypass testing (5.3.1(4))
3
Transfer limit and risk-group cap enforcement testing (5.3.1(4), (5))
4
Anti-tampering, obfuscation, and risky-app blocking tests (5.3.2(2.3), (2.5), (3.2))
5
Certificate pinning, application-layer encryption, and on-device storage review (5.3.2(1.1), (1.3))
6
Session hijacking and old-version access testing (5.3.2(2.2), (2.4))

BOT 4/2568 Readiness Checklist

Use this checklist to gauge where your organization stands against each control in Notification 4/2568, plus the yearly penetration test under 5/2566.

One user account per Mobile Banking app, on one device (5.3.1(3))
Face comparison with presentation attack detection on ฿50,000+ transfers, every ฿200,000 a day, and limit raises to ฿50,000+ (5.3.1(4))
Daily withdrawal and transfer caps set by user risk group, with a controlled exception process (5.3.1(5))
No links of any kind in SMS or email; on-request links sent one request at a time with a notice (5.3.1(1))
Fake app monitoring on official stores and a takedown process with owners and deadlines (5.3.1(2), Q&A item 4)
App blocked on rooted or jailbroken devices and alongside risky accessibility, remote-control, or overlay apps (5.3.2(3.1), (3.2))
Users on risky operating systems warned and capped at ฿5,000 a day where still served (5.3.2(3.3))
Anti-tampering check at every launch, source code obfuscation, and old versions retired (5.3.2(2.2), (2.3), (2.5))
Certificate pinning or equivalent, application-layer encryption, masked passwords, and screen blurring (5.3.2(1.2), (1.3))
New vulnerabilities closed within a suitable time or by BOT's deadline (5.3)
Yearly penetration test covering Mobile Banking (5/2566 attachment 2, clause 6.7)

Frequently Asked Questions

Everything you need to know about BOT Notification 4/2568 and mobile banking security compliance.

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Reconix is the proof-first offensive security specialist in Thailand, serving regulated digital businesses of all sizes.