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Who is legally responsible if my accountant files something wrong?

You are. The Accounting Act puts the duty to keep accounts on the company, not on the bookkeeper you hired, and section 40 imposes the same penalty on the managing director, managing partner or any person responsible for operations where the offence came from their act, or from their failure to act when they had a duty to. Outsourcing moves the labour; it does not move the liability.

Last reviewed 21 September 2026

This is the single most expensive misunderstanding a foreign owner has about Thai accounting. "My accountant handles it" is a description of who does the work, not of who answers for it.

Two roles, and Thai law keeps them apart

RoleWho it isWhat the Act says
ผู้มีหน้าที่จัดทำบัญชี, the person with the duty to keep accountsThe company itself. Registered partnerships, limited companies, public companies, foreign juristic persons operating in Thailand, and joint ventures under the Revenue Code.Section 8
ผู้ทำบัญชี, the bookkeeperA named qualified individual the company must provide. Not the firm, and not a substitute for the duty above.Section 19

Read section 19 slowly: the obligation it creates is an obligation on you, to provide a qualified person. Hiring one discharges that obligation. It does not transfer the underlying duty to keep the accounts.

What section 40 does

Where the offender under the Act is a juristic person, the managing director, managing partner, representative of the juristic person or any person responsible for the operation is punished with the same penalty as the company, if the offence arose from their order or act, or from their failure to order or act when they had a duty to. There is a defence: a director who proves they did not participate in the offence, and did not consent to it, is not caught.

A foreign director who signed nothing, read nothing and asked nothing is not obviously inside that defence. "I did not know" and "I did not consent" are different claims, and only the second one is in the statute.

The duty that runs the other way

Section 12 requires you to deliver the supporting documents to the bookkeeper, complete and correct. That cuts both ways. A firm that filed from an incomplete box of receipts has a defence you do not, and a firm that never asked for the missing documents has a weaker one. Which is why the date you handed things over is worth recording.

What the fines are

FailureFineSection
Failing to provide a bookkeeper (section 19), or to hand over documents (section 12)Not more than 10,000 baht29
Failing to keep accounts at all (sections 8 and 9)Not more than 30,000 baht, plus not more than 1,000 baht per day until corrected28
Failing to submit the financial statements (section 11)Not more than 50,000 baht30
Breaching the retention and place-of-keeping duties (sections 13, 14, 15, 17)Not more than 5,000 baht31
False or incomplete accountsImprisonment up to 1 year or a fine up to 20,000 baht, or both36
Aggravated false accountingImprisonment up to 2 years or a fine up to 40,000 baht, or both39
The Revenue Code is a separate regime with its own penalties, and they are usually the larger number. A company can be perfectly compliant under the Accounting Act and still be facing a 2x penalty on a late PP 30 or a 20% surcharge on an underestimated PND 51.

What to do about it, practically

  1. Get the named ผู้ทำบัญชี written into the engagement letter, not just the firm’s name.
  2. Keep your own copy of everything you hand over, with the date. Section 12 is the hinge and you want to be on the right side of it.
  3. Ask for the filing acknowledgements each month, not the report. A report says what the firm believes; an acknowledgement says what the government received.
  4. Keep the Thai ledger accessible to you. The records are legally yours and must be kept at your place of business unless the Chief Accounts Inspector has permitted otherwise.
  5. Ask what happens when the firm gets something wrong, and whether they carry professional indemnity cover. The answers vary enormously and almost nobody asks.

If the answers you are getting now are unsatisfying, changing accountant without losing your books is the practical next page. If you would rather see what three other firms would charge and what they would actually take responsibility for, compare three quotes.

Every filing, and when it is due. A Thai company owes about a dozen of them a year. They are all on the Thailand tax & compliance calendar, monthly and annual, paper and e-filing dates side by side.

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This is general information about how a filing works, not accounting or tax advice for your company. Confirm anything that matters against the official notice or with your accountant. Spotted something out of date? Tell us and we will fix it.

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