Blockchain & Crypto-Assets 2026 Comparisons

Currently, both security tokens and non-security tokens are under the supervision of the FSC. Specifically, the FSC regulate over financial products and services, including those involving blockchain and digital assets.

• Where digital assets deemed as securities, the FSC, through its Securities and Futures Bureau, enforces the provisions of the Securities and Exchange Act. Issuance and trading of such security tokens must comply with the requirements of the Act. The FSC has also authorised the Taipei Exchange (TPEx) to promulgate and implement specific regulations for STOs.
• For digital assets without the nature of securities, currently the FSC regulates VASP primarily under the anti-money laundering framework.

For non-security tokens in particular, because these are under the AML regime of the current framework, many of the systems being established are closely aligned with FATF standards. In November 2025, the Asia/Pacific Group on Money Laundering (APG) Mutual Evaluation Committee reaffirmed Taiwan’s “regular follow-up” status. This unanimous decision by APG members, prompted by Taiwan’s 2023 follow-up report, maintains the country’s standing in this top-tier category since its initial 2019 mutual evaluation.

It is worth noting that the forthcoming VASP-specific law will include a section on stablecoins, at which point the Central Bank will also play a role.

In Taiwan, the primary distinction regarding the characterisation of digital assets is between tokens having the nature of securities (ie, security tokens) and tokens without the nature of securities (ie, non-security tokens).

Security Tokens

Under the current regulatory framework in Taiwan, tokens that meet the existing legal definition of “securities” as set forth in the Securities and Exchange Act are subject to the full scope of regulatory oversight administered by the FSC. In order to provide a structured and compliant environment for such tokens, the FSC has delegated authority to the Taipei Exchange (TPEx) to develop and enforce detailed rules and requirements governing both the issuance and secondary trading of security tokens. These regulations are designed to ensure investor protection, market transparency, and regulatory compliance. Due to the rather high regulatory thresholds and associated compliance burdens, market participation has remained limited. To date, there has been only one officially approved security token issuance programme in Taiwan, highlighting the cautious and controlled approach taken by regulators toward this emerging form of digital asset.

Non-Security Tokens

In Taiwan, digital assets that are not deemed securities are regulated under MLCA. Following the amendment to MCLA in 2024, a VASP is required to register with the FSC in accordance with the relevant provisions of the MCLA before commencing operations. Operating without such registration may result in criminal liability. Many then-existing market participants had accordingly applied for registration with the FSC under the new legal framework. As of beginning of May 2026, there are eight registered VASPs. Also, pursuant to the Regulations Governing Anti-Money Laundering and Countering the Financing of Terrorism for Enterprises of Virtual Currency Platforms and Trading Business (the “VASP AML Regulations”), a duly registered VASP is required to:

• establish internal control and audit mechanisms;
• implement know-your-customer (KYC) procedures;
• maintain records;
• conduct continuous monitoring; and
• report large-amount transactions and suspicious transactions.

Furthermore, in April 2026, the Executive Yuan (cabinet of Taiwan) announced the draft of specific law dedicated to virtual assets, namely Virtual Assets Service Act, which proposes a licensing regime for VASPs. It remains uncertain when the Legislative Yuan (the congress) will pass this Act.

According to current Taiwan laws and regulations, licensed asset management companies (ie, securities investment trust enterprise and futures trust enterprises) are prohibited from investing in cryptocurrencies.

Security Token Offerings (STOs)

Since 2020, the Financial Supervisory Commission (FSC) and the Taipei Exchange (TPEx) have implemented a specialised framework for tokens classified as securities.

• Fundraising Thresholds:
1. under TWD30 million – issuances can proceed directly under standard STO regulations; and
2. over TWD30 million – the issuer must first enter the regulatory sandbox for evaluation before proceeding.
• Issuer Eligibility – only Taiwanese companies limited by shares that are not listed on the TWSE, TPEx, or the Emerging Stock Market may issue STOs. Foreign entities are currently prohibited from acting as issuers.
• Token Characteristics – authorised tokens are restricted to debt-based or profit-sharing structures. They must not grant traditional shareholder rights (such as voting).
• Investor Criteria – participation is generally limited to professional investors. For natural persons, there is a TWD300,000 investment cap per STO. Recent 2022 updates by the FSC and TPEx have slightly expanded eligibility to include certain qualified foreign investors.
• Operational Protocol – STOs must be hosted on a single designated platform. The platform operator is tasked with verifying issuer credentials and ensuring a prospectus is prepared. If the platform operator intends to issue its own tokens, it must obtain prior approval from the TPEx.

Non-Security Tokens (Virtual Assets)

Cryptocurrencies that do not function as securities are governed primarily by Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) frameworks, specifically the VASP Registration and VASP AML Regulations. Specifically, VASPs offering virtual-asset exchange services must disclose key details about the virtual assets, including the token’s whitepaper, which should contain information about the issuer, among other things. Also, a VASP providing virtual-asset trading platform services must establish criteria for reviewing virtual-asset launches. These criteria should cover, among other factors, information about the issuer and the legal risks associated with the issuer.

Security Token Offerings

Under the current STO framework, if a customer fails to fulfil their settlement duties, the securities firm (acting as the platform operator) must cancel the transaction. Following immediate notification to the customer, the firm is responsible for seeking compensation.

Beyond these default procedures, the STO regulations do not currently contain specific provisions addressing market integrity or the prevention of market abuse by traders.

Non-Security Tokens

While no specific laws currently govern market abuse for virtual assets, the VASP Guidelines mandate that providers ensure all trading is conducted fairly and transparently. To achieve this, VASPs must implement market-monitoring mechanisms – such as alerts for abnormal price swings – alongside rules to prevent market abuse and conflicts of interest.

Furthermore, under VASP Registration Regulations, exchange service providers are required to maintain and publicly disclose a conflict-of-interest policy. They must also take proactive steps to safeguard customer interests, specifically ensuring that all exchange orders are processed both promptly and fairly.

Security Tokens

There have been no major announced cases involving enforcement actions for violations.

Non-Security Tokens

There has been frequent discussion regarding illegal depositing taking under banking law or illegal fundraising in violations of the securities regulation. In a recent case, a service provider claimed during their service offering that they were not accepting fiat currency, but rather stablecoins. The prosecutor proceeded with an indictment, but the judgment has not yet been finalised.

If the activities are carried out offshore, the aforementioned legal issues will theoretically still apply unless the operations are conducted entirely offshore.

These regulatory and judicial stances are unlikely to change within the next 12 months.

Security Tokens

An STO platform may only be operated by entities licensed as a securities dealer. Existing securities firms intending to engage in such business must obtain prior approval from FSC. Furthermore, entities that are not currently licensed as any kind of securities firms may also apply to the FSC for a licence specifically permitting them to conduct business of proprietary trading of virtual assets.

Digital Asset Without the Nature of Securities

For digital assets that are not considered to be securities, Taiwan currently adopts a registration regime under MCLA. According to the Regulations Governing Anti-Money Laundering Registration of Enterprises or Persons Providing Virtual Asset Services (the “VASP Registration Regulations”), any entity seeking registration as a VASP must submit the following documentation.

• VASP information form.
• Corporate registration documents.
• Company articles of incorporation.
• Business rules/bylaws and description of business processes.
• Roster of shareholders.
• Roster of responsible person(s) of the company.
• Roster of beneficial owner(s).
• Statement representing that the responsible person(s) and beneficial owner(s) of the company are free of any circumstance in violation of Article 4 of these Regulations (ie, the negative qualifications).
• AML internal control and internal audit systems (“internal control systems”).
• Internal control system checklist reviewed by a CPA with CPA-issued review opinion.
• Complaint-handling procedures.
• Statement representing that there is no misrepresentation or concealment in the content of the application form and attachments.
• Other documents as required by the FSC.

See 3.1 Licensing Requirements.

According to the VASP Registration Regulations, any change in the beneficial owner of VASP is subject to the prior approval of the FSC.

There are no passporting-related provisions or mechanisms in Taiwan.

As advised in 2.6 Non-Compliance, if the services are rendered from offshore, the Taiwan regulations will theoretically still apply unless the operations are conducted entirely offshore.

The current advertising regulations for Taiwan are as follows.

Security Tokens

The marketing and disclosure requirements for security tokens in Taiwan are primarily governed by the “Regulations Governing Securities Dealers’ Operation of the Business of Trading of Virtual Currency with Nature of Securities” (the “STO Regulations”), as promulgated by the Taipei Exchange (TPEx). Under the STO Regulations, issuers are required to disclose material information through a designated “Information Disclosure Section”. The STO Regulations stipulate the following key requirements.

• Prohibition of Promotional Language – the content of material information disclosures must not contain exaggerated, promotional, or advertising language, nor may it include any false, concealed, or misleading statements.
• Pre-Disclosure Restrictions – issuers are prohibited from making any public announcements regarding material information prior to its official disclosure, in order to ensure the accuracy and broad dissemination of such information.
• Ongoing Disclosure Obligations – if there are significant developments or changes following the initial disclosure of material information, issuers are required to promptly update or supplement the disclosed information in accordance with the original disclosure provisions.

Digital Assets Without the Nature of Securities

For digital assets without the nature of securities, VASP Registration Regulations impose specific requirements on virtual-asset trading platforms. These platforms must establish internal review standards and procedures for the launching of virtual assets. The review standards must include an assessment of whether the advertising content or solicitation activities related to the virtual assets involve any improper or false statements, or any conduct that is fraudulent, concealed, or otherwise likely to mislead others.

Additionally, the FSC issued the “Guidelines for the Management of Virtual Asset Service Provider” (the “VASP Guidelines”) in September 2023, which set forth customer protection requirements, including:

• Fair Contracting Principles – VASPs must enter into contracts for the provision of virtual-asset products or services with customers based on principles of fairness, reasonableness, equality, reciprocity, and good faith.
• Risk Disclosure – prior to entering into such contracts, VASPs are required to fully disclose to customers the key terms, features, and risks associated with the relevant products, services, and contracts.
• Advertising Standards – VASPs must ensure that all advertising, solicitation, and promotional activities are free from false, fraudulent, or misleading content. All promotional materials must be accurate and truthful.
• Complaint Handling – VASPs are required to establish procedures for handling customer complaints and to resolve disputes related to virtual-asset transactions in a fair and timely manner.

Taiwanese law does not have explicit regulations regarding white labelling. However, it cannot be ruled out that such arrangements may be viewed as an offshore exchange (one that is not registered in Taiwan) providing services within Taiwan, which may therefore constitute a violation of Taiwanese regulations.

There are no specific regulations for DeFi in Taiwan. From the perspective of Taiwanese law, it is difficult to conceive of virtual-asset products that have no service provider at all. If there is indeed one or more principal parties “behind” these services, they could still be held liable for any violations of Taiwanese law. This is especially true in cases involving criminal liability, where authorities may trace responsibility back to the individuals (ie, natural persons) involved.

As for CeFi providers, if they provide services to clients using their own positions while utilising DeFi protocols “behind the scenes”, there appears to be no explicit legal prohibition. However, in theory, these CeFi providers are expected to maintain a certain level of robust internal controls to prevent their use of DeFi from causing a material adverse impact on their operations.

See 5.1 Ability to Use DeFi.

As advised in 5.1 Ability to Use DeFi, if there is indeed one or more principal parties “behind” the DeFi services, they could still be held liable for any violations of Taiwanese law, especially if criminal liability is involved.

There have been no major announced cases involving enforcement actions for DeFi.

Under the current legal framework in Taiwan, there are no explicit prohibitions that prevent the use of cryptocurrencies for payment purposes in general commercial transactions. This means that private parties may legally agree to use cryptocurrency as a form of consideration, provided the transaction does not involve regulated financial services or trigger anti-money laundering obligations.

Currently, Taiwan has not established specific regulations for RWA. Therefore, purely from a legal perspective, any issuer wishing to launch an RWA programme must comply with existing regulatory frameworks. For instance, if the design of a particular RWA constitutes a securities offering, it must theoretically fit within the current framework of securities laws. However, since existing securities regulations – with the exception of those specifically for security tokens – do not account for blockchain technology, any attempt to issue an RWA with the characteristics of securities may prove practically infeasible under the current regulatory framework.