TAIWAN Trends and Developments Contributed by: Robin Chang, Ken-Ying Tseng and Eddie Hsiung, Lee and Li, Attorneys-at-Law
enthusiasm has also waned. Fundraising for NFT ven- tures has become more difficult, leading to a notice- able decline in market activity. Unless another global NFT surge occurs, it seems less likely that Taiwan’s NFT market will regain its previous momentum. In Taiwan, in terms of industry sectors, the most likely areas for development of blockchain application – and where activities are already more visibly underway – are still in financial services, such as (i) the pilot pro- gramme for banks providing custody services for vir- tual assets and (ii) RWA (ie, tokenisation of real-world assets), as introduced below. Pilot programme for financial institutions to provide virtual-asset custody services Traditionally, financial institutions have not provided custody services for virtual assets. However, consid- ering that providing virtual-asset custody has gradu- ally become an international trend, and in order to support the development of domestic financial inno- vation, Taiwan’s Financial Supervisory Commission (FSC) launched a pilot programme at the end of 2024 allowing financial institutions to conduct virtual-asset custody services, with applications being accepted starting in 2025. Applicants for this programme must be financial institutions. However, financial institutions seeking to apply may collaborate with other parties (such as soft- ware service providers or VASPs) to participate in the pilot, and there are no specific restrictions imposed on these collaborating parties. Additionally, the pilot does not limit the business models that financial insti- tutions may adopt – they are free to design and plan their own models. According to the FSC’s suggested application docu- ments, financial institutions should specify whether the custody services are intended for VASPs, pro- fessional investors, or general investors at the time of application. This indicates that the FSC does not rule out the possibility that, in the future, banks could also provide virtual-asset custody services for general investors. According to an FSC press release, the pilot pro- gramme will, in principle, last six months, and the
application review process will take about two months. Depending on the results and experiences from this pilot programme, the FSC will draft relevant regulations and use the findings as a reference for future policy decisions. Whether full-scale adoption will occur will depend on the outcome of the pilot. A news report indicated that, according to the Chair- person of the FSC, five banks have been approved by the FSC to participate in the pilot programme for virtual-asset custody as of early May 2026. RWA In addition to the above-mentioned pilot programme for custody services, the FSC also launched a pro- gramme focused on RWAs in 2024. According to a press release issued by the FSC in November 2025, below is the summay of the RWA programme initiated by the FSC. In June 2024, the FSC collaborated with the Taiwan Depository & Clearing Corporation (TDCC) and vari- ous financial institutions to form the “RWA Tokeniza- tion Task Force” (“Task Force”) The Task Force com- pleted its final empirical report in September 2025, verifying the technical feasibility of the project. Three types of tests The Task Force – comprised of the Central Bank, the TDCC, and nine financial institutions – focused on domestic bonds, foreign bonds, and funds as targets for tokenisation. They used a Proof of Concept (POC) approach to test the viability of RWA tokens in the Taiwanese financial market across three specialised groups. • Domestic Bonds – utilising a proprietary blockchain and RWA trading platform, this group provided ser- vices for the subscription, issuance, trading, inter- est payment, redemption, and custody of TWD- denominated corporate and financial bond tokens (digitally native). By connecting to the Central Bank’s tokenised cash flow platform (developed by FISC), they achieved Delivery versus Payment (DVP) using TWD deposit tokens. • Foreign Bonds – through the TDCC’s blockchain platform, foreign bonds were tokenised and frac- tionalised to provide interest payment and redemp-
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