(THAILAND) — A December 2024 ministerial permit enabling foreign pilots on domestic wet-lease aircraft was annulled effective November 17, 2025, reshaping how airlines staff and deploy pilots on Thai routes.
Overview of the ruling
Thailand’s Administrative Court annulled a Labour Ministry announcement that had allowed foreign pilots to operate domestic wet-lease flights. In practice, the decision withdraws the legal permission that let airlines rely on non-Thai cockpit crews for certain Thailand-only routes when the aircraft was brought in under a wet lease.
A wet lease is a rental deal where one airline supplies an aircraft plus crew, maintenance, and insurance to another airline. Think of it as “plane + pilots included,” rather than just borrowing an aircraft shell.
When that wet-leased aircraft is used on domestic routes inside Thailand, pilot nationality and work authorization become a central issue because Thailand restricts foreign workers in certain roles and limits who can fly domestic services. The annulment means the ministerial announcement is treated as invalid rather than merely paused under administrative law.
For airlines, that changes staffing assumptions fast. Schedules built around foreign pilots on domestic wet-lease flights may need re-crew planning, contract reshaping, or capacity reductions depending on available Thai pilots and training pipelines.
Regulators also have less room to approve similar arrangements unless a new, lawful exemption is created. The ruling effectively narrows immediate options for carriers relying on wet-lease foreign cockpit crews for domestic services.
Legal basis and challenges
The ruling turned on administrative legality and the limits of government discretion. The court framed the case under Section 9(1) of the Act on Establishment of Administrative Courts and Administrative Court Procedure BE 2542 (1999), a provision used to test whether an administrative act was unlawful or beyond lawful authority.
The challenge came from the Thai Pilots Association and its president, Teerawat Angkasakulkiat, who argued the Labour Ministry’s permission crossed legal lines and harmed Thai employment opportunities. Their case tied workplace protection to administrative process: the government may have authority to grant exceptions, but it must do so within the rules and for defensible reasons.
A second pillar was the Royal Ordinance on the Management of Foreign Workers Employment BE 2560 (2017). Under that framework, exemptions for foreign-worker roles are meant to be exceptional and typically must be justified by special circumstances.
The court found the exemption rationale did not meet that standard. The approval was viewed as benefiting a single company without a sufficient public-interest justification, and it risked harming Thai pilot job opportunities.
Key dates and timeline
Time mattered as much as legal theory: the policy opened the door, the lawsuit raised the alarm, the regulator tightened approvals, and the court’s annulment reset the baseline. For operators, each step changed what could be scheduled, crewed, and sold.
Airlines that use wet lease capacity often plan months ahead and lock in aircraft availability, crew provisioning, and block hours through contracts. When the regulator shifts its approval posture midstream, carriers may have to renegotiate terms, reassign aircraft, or change seasonal schedules.
The timeline highlights why approvals and staffing pipelines became harder to manage once oversight tightened and the court acted. An interactive timeline tool will display the key milestones, dates, stakeholders, and impacts for operational planning.
Impacts on pilots and employment
Domestic wet-lease staffing became a flashpoint because it sits at the intersection of demand for flexible capacity and Thai pilots’ desire for protected domestic jobs. Airlines want flexibility for peaks, while many Thai pilots remain sidelined in a constrained market.
The employment numbers cited in the dispute were stark: 1,700 unemployed Thai pilots within a pool of 5,000 affected workers. Against that background, letting foreign pilots fly domestic wet-lease flights looked, to the association, like importing labor into a market with available Thai cockpit crews.
CAAT’s response signals how officials view supply and demand: alongside a commitment to tighten domestic approvals, CAAT supported overseas placement for Thai pilots. The agency reported 26 placed at Cathay Pacific and described plans that could send 1,000 pilots abroad to markets including Japan, Israel, Hong Kong, and Macau.
That approach may relieve short-term job pressure at home and help Thai pilots build hours and type experience that later strengthen the domestic talent pool. For airlines, the labor effect is practical: if foreign pilots cannot staff domestic wet-lease flights, carriers may need to accelerate Thai pilot recruitment, simulator time, and line training.
Those steps take time and can affect capacity planning, which therefore may need a buffer. Businesses will likely reassess hiring timelines and training pipelines to meet domestic crewing requirements.
CAAT’s stated plans and future outlook
CAAT has said it will not extend similar arrangements beyond 2025. That pledge matters for contract timing because wet lease deals often span seasons and include options to extend.
A regulator’s “no extension” stance can force earlier renegotiations or earlier exits from wet-lease agreements. Teerawat Angkasakulkiat welcomed CAAT’s efforts while flagging pressure points, including international oversight attention from bodies such as the ICAO.
Airlines that rely on wet lease capacity may want to keep compliance files tidy, since scrutiny can ripple into audits and operating approvals. Another pressure point is whether piloting remains a restricted occupation or is removed, which would alter future debates.
✅ What airlines should plan for now: review wet-lease contracts, adjust pilots’ staffing pipelines, and monitor CAAT guidance on exemptions and overseas placements.
Legal and policy context for domestic wet-lease operations
The durable compliance message is simple: the default rule restricts foreigners from operating domestic flights, and exemptions are treated as rare. If a future exemption is proposed, decision-makers would likely need to show a specific public-interest need and why Thai pilots cannot fill the roles in the relevant time window.
Under the logic applied here, “business convenience” alone may not be enough. Evidence could include time-limited shortages, safety and training constraints, or emergency transport needs—paired with concrete measures that protect Thai employment.
Airlines and pilots should also think in documentation terms: wet lease arrangements touch multiple regulators and records, including aircraft registration and oversight, crew licensing recognition, work authorization, and route authority. When policy is tight, consistency across those documents becomes central.
Procedurally, stakeholders will be watching for three things: new ministerial action crafted to meet the legal standard, revised CAAT guidance on approvals, or additional litigation outcomes that clarify how exceptions can be justified.
Stakeholder perspectives and uncertainties
Thai Pilots Association members have framed the ruling as a labor-market protection win and expect CAAT initiatives to translate into real hiring or structured pathways. The overseas placement push may help some pilots in the short term but does not replace domestic cockpit opportunities on Thailand routes.
Industry concerns cluster into a few practical uncertainty buckets, notably enforcement consistency, potential policy revisions, and restricted-occupation implications. Airlines can reduce exposure by building contingency staffing plans, adding schedule buffers during transition periods, and sourcing capacity in ways that do not depend on foreign pilots flying domestic sectors.
Key uncertainty areas include how strictly approvals and inspections are handled across carriers and airports, whether a new lawful exemption is attempted and what evidence it would require, and whether broader labor policy changes alter the debate over domestic wet-lease flights.
Current status (early 2026)
Early 2026 has brought no reported reversals or extensions. For day-to-day operations, carriers should assume the restriction applies unless and until a new lawful exemption is issued and implemented through CAAT guidance.
For airlines, the near-term task is concrete: align wet lease contracts and domestic schedules with crewing rules now, not after peak-season rosters are published. Operational planning should reflect current restrictions and potential timeline risks for any future exemptions.
⚠️ Be aware that current restrictions apply unless a new lawful exemption is issued; monitor for changes in ministerial action or CAAT guidance.
This article discusses legal rulings and regulatory actions; consult official sources for current guidance. Individual circumstances vary; contact CAAT or a qualified attorney for specific advice.
Administrative Court Annuls Ban on Foreign Pilots for Wet Lease Flights
Thailand’s Administrative Court has invalidated a 2024 permit allowing foreign pilots on domestic wet-lease flights to protect local jobs. Triggered by a lawsuit from the Thai Pilots Association, the ruling emphasizes that employment exemptions must serve a clear public interest. Airlines now face urgent shifts in staffing, as the default rule requires Thai pilots for domestic operations, forcing a rethink of fleet and crew planning.
