Fintech 2026

TAIWAN Law and Practice Contributed by: Robin Chang, Sarah Wu and Eddie Hsiung, Lee & Li

Lee & Li 8F, No. 555, Sec. 4, Zhongxiao E. Rd. Taipei 11072 Taiwan, R.O.C.

Tel: +886 2 2763 8000 Fax: +886 2 2766 5566 Email: attorneys@leeandli.com Web: www.leeandli.com

1. Fintech Market 1.1 Evolution of the Fintech Market Cryptocurrency

In January 2026, the Artificial Intelligence Basic Act (the “AI Basic Act”) was formally enacted and came into effect. The AI Basic Act establishes the statutory framework for the regulation and advancement of AI applications in Taiwan, providing the relevant legal standards and policy directives. Pursuant to the AI Basic Act, the Ministry of Digital Affairs (MODA) is tasked with developing an AI risk classification framework that aligns with international practices, and is responsible for supporting each sec - tor-specific competent authority, including the FSC, in the formulation of risk-based regulatory standards. Within this framework, the FSC is required to establish risk-based regulatory standards for AI applications in the financial sector, taking into account risk manage - ment needs and the prescribed risk classification framework. Furthermore, the FSC is to assist relevant industries in developing industry-specific guidelines and codes of conduct for the financial sector.

Due to the insolvency of FTX, as well as certain report - ed defrauding activities in Taiwan, the Financial Super - visory Commission (FSC) introduced a set of guide - lines for virtual asset service providers (VASPs) under the Money Laundering Control Act (the “Taiwan AML Act”) in September 2023. Further, in 2024, the Taiwan AML Act was amended, and under the revised Act, VASPs operating without registration with the FSC for AML purposes could face criminal liability. Moreover, the FSC is contemplating the possibility of introducing a crypto-specific law, with a draft announced in June 2025. Please see 2.14 Impact of AML and Sanctions Rules and 6.3 Impact of the Emergence of Crypto- currency Exchanges for further information. AI In the financial industry, the FSC rolled out the “Core Principles and Related Promotion Policies for the Use of Artificial Intelligence (AI) by the Financial Industry” in October 2023. Then, in June 2024, the FSC intro - duced the “Guidelines for the Use of Artificial Intelli - gence (AI) in the Financial Industry”. These guidelines, serving as administrative guidance, aim to help finan - cial institutions implement, manage and oversee AI technologies effectively. The guidelines cover key are - as such as: (1) establishing governance and account - ability structures, (2) ensuring fairness and prioritis - ing human-centred values, (3) safeguarding privacy and customer rights, (4) ensuring system security and robustness, (5) promoting transparency and explain - ability, and (6) fostering sustainable development.

2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models

Commonly observed fintech applications in Taiwan include peer-to-peer lending, electronic payment solutions, robo-advisers and cryptocurrencies. 2.2 Regulatory Regime Please see below a brief introduction to the regulatory regimes applicable to certain commonly seen fintech applications.

830 CHAMBERS.COM