Fintech 2026

INTRODUCTION  Contributed by: Adrian Ang, Allen & Gledhill

Eight Years of FinTech Global Practice Guides 2026 marks the eighth year since Chambers and Part - ners introduced the Global Practice Guide for Fintech, and I am humbled and honoured to continue being the contributing editor. When I was first approached by Chambers in 2024 to succeed Lee Schneider in this post, I thought back to each previous iteration of this guide. I have always been struck by the guide’s abil - ity to incisively capture the flavour of the market each year. This year also marks the tenth anniversary of the beginning of my fintech practice. Over the course of this period, in planning for the potential opportunities and challenges facing the practice, I have found the Chambers Fintech Guides invaluable in providing an overview of the key developments in the fintech world, and in their ability to identify and expound on key global trends. In keeping with this excellent tradition, in this introduction I have set out some key global trends I believe will shape the landscape of fintech this year. Four significant forces In approaching this 2026 edition of the Chambers Fin - tech Guide, we considered that the market had moved from a “move fast and break things” ethos towards a capital-efficient, increasingly regulated ecosystem focused on utility-driven infrastructure. Indeed, while the early years of fintech were marked by the buzzword “disruption”, you seldom hear the word being used now. This is not to say that fintech does not continue to disrupt traditional financial services. It is just that such disruption occurs under the backdrop of a far more mature regulatory environment. Four dominant forces appear to be shaping (and reshaping) the landscape this year: convergence, agentic AI, the regulatory legiti - misation of digital assets, and shifts in fraud liability. This introduction outlines the key global trends shap - ing the law and practice of fintech in 2026, setting the stage for the detailed country-specific chapters that follow. The year of convergence If the previous decade was defined by the “disruption” associated with agile start-ups moving fast and break - ing things as they “unbundled” banks and offered their take on financial services, 2026 would seem to be the year of continued “convergence”. For example, successful fintechs may consider it worth the cost to

pursue a “re-bundling” strategy, evolving into super apps or obtaining full banking licences to secure sta - ble deposits. In the vertical of embedded finance, predominantly non-financial platforms (e-commerce, mobility) are embedding lending and insurance products. For example, policies can be sold seamlessly at the point of sale (eg, travel insurance with a flight, extended warranty with a device). By one measure, this verti - cal is projected to exceed USD7 trillion in transaction value by 2026. The boundaries between traditional financial institu - tions, decentralised finance (“DeFi”), and technol - ogy giants appear as if they are being dissolved and replaced by a unified financial fabric interwoven with technology. For example, in the realm of cross-border payments, there is an ongoing initiative to connect domestic instant payment systems, starting with India, Malaysia, the Philippines, Singapore and Thailand. This allows for sub-60-second cross-border trans - fers at near-zero cost, challenging the correspondent banking model. On a related note, as of November 2025 mBridge has processed over USD55 billion in trade payments between China, the UAE and Thailand using central bank digital currencies (CBDCs). Convergence is not limited to business models and technology. In conjunction with such convergence, the regulatory gap is closing. “Same risk, same regula - tion” is the prevailing doctrine. We would expect fin - techs engaging in lending or deposit-taking-like activ - ity, to face bank-like capital requirements. We would also expect regulators to be looking at whether the “front-ends” of DeFi protocols (ie, the persons pro - moting and offering such DeFi protocols) ought to be regulated, at the very least on the basis that operat - ing the “front-end” for certain services constitutes a regulated activity. On a related note, we would expect a further focus on the management and oversight of technology risks. We would note that in conjunction with the greater reliance on large technology companies, financial institutions are imposing stricter contractual terms on vendors, such as a mandatory “right to audit”, data residency guarantees, and participation in “threat-

7 CHAMBERS.COM

Powered by