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Taiwan's payments sector is governed by the Act Governing Electronic Payment Institutions (2015, amended January 2023) for fiat e-payment/e-money, and by the Virtual Asset Service Act (passed 30 June 2026) for crypto/stablecoin, shifting VASPs from AML-registration to FSC licensing.
A landmark 56-article Virtual Asset Service Act passed its third Legislative Yuan reading on 30 June 2026, requiring FSC approval for exchange, transfer, holding, underwriting and lending of digital assets, and has been forwarded to President Lai Ching-te for signing, with the Executive Yuan to set the commencement date separately.
Existing AML-registered platforms receive a 12-month grace period to submit licence applications and up to 21 months in total to obtain full FSC approval, but the compliance timeline remains unquantifiable until the Executive Yuan sets a commencement date.
Outlook
The commencement date the Executive Yuan sets for the Virtual Asset Service Act is the single marker to watch, since it will fix both the 12-21 month licensing runway for existing platforms and the point at which FSC scrutiny formally extends across exchange, transfer, holding, underwriting and lending of digital assets.
Licensing, Authorisation & Market Access
Taiwan's Financial Supervisory Commission secured passage of the Virtual Asset Service Act through the Legislative Yuan on 30 June 2026, the most significant market-access development for Taiwan's payments and digital-asset perimeter this cycle (wpm-2026-W1a-001). The Act creates a licensing regime spanning seven distinct virtual-asset-service-provider categories, replacing the AML-registration-only model that had applied under the amended AML Act since July 2024. Where the prior regime required only that a virtual-asset service provider, including an offshore provider establishing a Taiwan company or branch, register for AML purposes before offering services, the new regime conditions market access on affirmative Financial-Supervisory-Commission approval, bringing capital, custody-segregation and operational-control requirements to bear on market entry for the first time.
The reform reaches both bank and non-bank entities operating in the virtual-asset space, an important distinction for any operator assessing Taiwan's licensing perimeter: the Act does not carve out a separate, lighter-touch track for bank-affiliated virtual-asset activity, and both categories of entity face the same seven-category licensing structure. This is a materially different posture from jurisdictions that have created bank-specific exemptions or fast-track approval paths for regulated financial institutions entering the virtual-asset space.
Existing AML-registered virtual-asset service providers are not required to cease operations immediately upon the Act's passage. A transition mechanism gives them twelve months from an as-yet-undesignated commencement date to apply for the new licence, and twenty-one months in total to secure full licence approval (wpm-2026-W1a-002). This transition window is significant for market-access planning: it means Taiwan's virtual-asset market will operate under a dual old-and-new licensing regime for close to two years following commencement, during which currently-registered incumbents retain market access while their licence applications are assessed.
The practical significance of this reform for market entrants is twofold. First, the bar for lawful market access in Taiwan's virtual-asset sector has risen substantially, from a registration filing to a full supervisory licence, which will lengthen and complicate market-entry timelines for new entrants relative to the interim regime. Second, because the reform applies uniformly across seven categories rather than creating category-specific carve-outs, entrants offering multiple virtual-asset functions, such as exchange, custody and transfer services together, face a correspondingly multiplied licensing burden, a dynamic explored further under this cycle's commercial-intelligence findings.
The Act's seven-category structure means that market access is now assessed function-by-function rather than entity-by-entity: a firm offering exchange services, custodial services and fund-transfer services must, under the new regime, hold licences corresponding to each function it performs, rather than a single blanket registration covering all activities. This function-based licensing architecture is a deliberate design choice that shifts the market-access calculus for combined-function operators specifically, a dynamic this brief revisits under commercial intelligence below given its direct bearing on Taiwan's existing exchange landscape.
The Interpreter has rated this development HIGH impact and High confidence, reflecting both the primary-source strength of the Financial Supervisory Commission's own press release confirming passage and the structural reach of the reform across the entire virtual-asset-service-provider population rather than a single firm or transaction (wpm-2026-W1a-001). The twelve-month application window and the further nine-month period to reach full approval, twenty-one months in total, were reported by Taipei Times rather than by the Financial Supervisory Commission's own primary release, and this brief accordingly treats the precise transition-window figures as Assessed rather than High confidence pending direct regulatory confirmation, even though the existence of a transition mechanism itself is not in doubt (wpm-2026-W1a-002).
Outlook
The Financial Supervisory Commission has not yet designated a commencement date for the new licensing regime; that designation, together with the roughly nine sets of sub-regulations expected before it, is the key near-term market-access development to track, with an expected timeline around the first quarter of 2027. Until commencement is designated, the twelve-and-twenty-one-month transition clocks have not yet started running, so incumbent virtual-asset service providers currently operate in a holding pattern under the interim AML-registration regime. A further open market-access question is whether the Financial Supervisory Commission will publish guidance clarifying how the seven licence categories map onto existing combined-function operators before the transition clocks start running, or whether firms will need to file for multiple licences without such mapping guidance in place.
Sources and findings (6)
- T2https://www.klgates.com/Taiwan-Act-Governing-Electronic-Payment-Institutions-05-26-2015
- T3https://www.globallegalinsights.com/practice-areas/fintech-laws-and-regulations/taiwan/
- T2https://www.ocac.gov.tw/OCAC/Eng/Pages/Detail.aspx?nodeid=329&pid=71072018
- T3https://www.techtimes.com/articles/319485/20260701/taiwan-crypto-law-ends-gray-zone-era-opens-market-bank-competition.htm
- T3https://www.coindesk.com/policy/2026/07/01/taiwan-s-sweeping-crypto-law-raises-the-bar-with-licensing-reserve-mandates-and-tough-penalties
- T1https://law.fsc.gov.tw/EngLawContent.aspx?lan=E&id=1302