INTRODUCTION Contributed by: Adrian Ang, Allen & Gledhill
Regulatory legitimisation of digital assets The enactment of the Guiding and Establishing Nation - al Innovation for US Stablecoins Act (the “GENIUS Act”) in July 2025 was a watershed moment for the global crypto-ecosystem. By establishing a federal regulatory framework that mandates 1:1 reserve back - ing with high-quality liquid assets, the US is effectively on the path towards the legitimisation of stablecoins as a settlement instrument. This has catalysed the rise of PayFi, a new vertical where stablecoins are used for programmable B2B payments, real-time payroll, and cross-border trade settlement, bypassing legacy rails like SWIFT for intra-day liquidity management. In the European Union, the full application of the Mar - kets in Crypto-Assets Regulation (MiCA) has created a comprehensive regulatory regime for digital assets. MiCA distinguishes between asset-referenced tokens (ARTs) and e-money tokens (EMTs), with the issuers of significant ARTs and EMTs facing stricter supervision. We would expect 2026 to be the year where “single- currency stablecoins” backed by reserve assets contin - ue on their path towards becoming a significant medi - um of exchange in the digital economy, significantly eroding the market share of algorithmic alternatives. On a related note, we would expect real-world asset (RWA) tokenisation to continue to gain traction in 2026. The market for tokenised assets, which can span anything from government treasuries and money market funds to private credit, is projected to grow exponentially, with estimates suggesting a trajectory toward trillions in value by 2030. By one estimate, the market for tokenised US treasuries already exceeds USD10 billion, possibly driven by institutional demand for on-chain collateral. Major asset managers have launched tokenised funds on public blockchains, allowing investors to earn yield on-chain while using these tokens as collateral in DeFi protocols. This con - vergence allows for 24/7 liquidity management and atomic settlement, eliminating the T+1 or T+2 delays of traditional securities markets. However, the chal - lenge remains secondary market liquidity. In 2026, we would expect to observe the continued development of “unified ledgers” and interoperability protocols attempting to connect siloed liquidity pools across different blockchains and traditional bank ledgers.
Liability shifts in the global fight against fraud The payments sector in 2026 is defined by the tension between the demand for instantaneity and the impera - tive of security. Real-time payment systems are ubiq - uitous, but they have opened new vectors for fraud. For example, deepfakes (voice and video) are now a primary vector for social engineering, bypassing voice biometric security. “Fraud-as-a-service” platforms allow low-skilled criminals to launch sophisticated AI-driven attacks at scale. It is no surprise that regulators globally have been look - ing at how to safeguard consumers from the rise of fraud. For example, the United Kingdom requires in- scope payment service providers to reimburse victims of authorised push payment fraud within five days, with the cost split 50:50 between the sending and receiving institutions. In Singapore, the coming into force of the E-Payments User Protection Guidelines and the Guide - lines on Shared Responsibility Framework sets out a waterfall method for apportioning such losses. Under MiCA, crypto-asset service providers are liable for the loss of crypto-assets due to hacks or malfunctions. In the United States, the Protecting Consumers From Payment Scams Act proposes amending the Elec - tronic Fund Transfer Act to treat fraudulently induced electronic fund transfers in the same manner as unau - thorised fund transfers, and sharing liability between sending and receiving financial institutions. We would naturally expect the introduction of such regimes to lead to increased friction in payments, but a reduction in losses to scams. Globally, we would also expect other regulators to follow suit, pushing for a “shared responsibility” model that eventually includes telecommunications companies and social media platforms in the liability chain. Conclusion In summary, we expect the trends of convergence, agentic AI, regulatory legitimisation of digital assets, and shifts in fraud liability to continue to dominate the fintech scene. For 2026, the Fintech Global Prac - tice Guide continues to cover a wide variety of areas, including new additions on anti-money laundering rules, reverse solicitation, the regulatory treatment of staking, lending and cryptocurrency derivatives, and responsibility for losses. I am sure the Fintech Global Practice Guide for 2026 will be a useful resource for all practitioners and participants in the field.
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