Fintech 2026

Eight Years of FinTech Global Practice Guides

2026 marks the eighth year since Chambers and Partners 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 ability 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 Fintech 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 legitimisation of digital assets, and shifts in fraud liability.

This introduction outlines the key global trends shaping 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 breaking 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 stable 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 vertical is projected to exceed USD7 trillion in transaction value by 2026.

The boundaries between traditional financial institutions, decentralised finance (“DeFi”), and technology 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 transfers 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 regulation” is the prevailing doctrine. We would expect fintechs engaging in lending or deposit-taking-like activity, 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 promoting and offering such DeFi protocols) ought to be regulated, at the very least on the basis that operating 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-led penetration testing” exercises. For example, the Digital Operational Resilience Act (DORA) entered into force in the EU in January 2025, and aims to ensure that financial entities can withstand, respond to, and recover from information and communication technology (ICT) disruptions, such as cyber-attacks or system failures. While the management of ICT risks is not necessarily something new (eg, for several years Singapore’s regulator has required financial institutions to adhere to, where relevant, Guidelines on Technology Risk Management and the Notice on Cyber Hygiene), we would expect regulators’ increased focus on the management and oversight of technology risks to create a demand for solutions that map critical functions, conduct threat-led penetration testing, and manage third-party risk concentration.

Agentic AI

The evolution of the fintech market over the past 12 months has been defined by the rapid industrialisation of AI. 2024 and 2025 focused on large language models (LLMs) that could generate text or code, and thereby served as tools assisting human workers.

2026 would appear to be the year of widespread adoption of agentic AI. Unlike passive chatbots, these agents possess the ability to perceive their environment, form intent and act. Unlike traditional robotic process automation, which follows rigid rules, AI agents can handle exceptions, interpret unstructured data, and orchestrate actions across disparate systems. Agentic AI systems can therefore be thought of as systems that are capable of reasoning, planning and executing multi-step financial workflows without human intervention. Naturally, we can expect financial institutions to deploy agentic systems to automate or enhance complex, multi-step workflows.

We would also expect fintech businesses to capitalise on agentic AI to introduce various types of businesses. For example, “agentic commerce” can allow consumer-authorised bots to negotiate prices, renew subscriptions and execute payments, creating a new layer of “machine-to-machine” economic activity. In the realm of “agentic finance”, while legacy robo-advisers offered static exchange-traded fund (ETF) allocations on the basis of predetermined risk tolerances, agentic AI can be used to actively manage a user’s entire balance sheet (eg, moving excess cash to high-yield accounts) in real time. Agents authorised by consumers can negotiate purchases, book travel and execute payments. In the back office, AI agents can execute customer due diligence and know-your-customer processes, analyse transactions as part of transaction monitoring alerts, and draft any required activity reports (eg, on suspicious activity) for human review. Lenders can utilise “agentic underwriting”, analysing alternative data points (telco data, rental payments, open banking data) to score “thin-file” borrowers, and even leverage real-time access to accounting software via APIs to offer dynamic credit lines based on actual cash flow rather than static credit scores.

This technological leap creates some legal uncertainty. One issue impacting the market in 2026 is the attribution of liability for autonomous actions. If an AI agent executes a trade that results in significant loss, or denies a loan application based on opaque criteria, the question of attribution (ie, whether the act is that of the developer, the deployer or the user) becomes critical. In 2026, we see the crystallisation of liability frameworks that may, among other things, attribute responsibility to the deployer of the high-risk system, treat high-risk AI agents as an extension of their principal, and necessitate robust “human-in-the-loop” oversight mechanisms.

A secondary issue is that of explainability. The “black box” nature of these models poses risks if a decision is required to be justified. It may be the case that regulators may increasingly require financial institutions to provide specific reasons for certain actions, even when decisions are made by complex neural networks.

Consistent with the idea of AI agents being an extension of their principal (whose actions must be explainable), the implications are, among other things, the necessity of “proof of authority” guardrails. A new “AI assurance” industry has emerged to audit these agents, ensuring they operate within defined risk parameters and do not hallucinate or exhibit bias in credit scoring or claims processing.       

Regulatory legitimisation of digital assets

The enactment of the Guiding and Establishing National 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 backing 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 Markets 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 continue on their path towards becoming a significant medium 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 convergence allows for 24/7 liquidity management and atomic settlement, eliminating the T+1 or T+2 delays of traditional securities markets. However, the challenge 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 imperative of security. Real-time payment systems are ubiquitous, 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 looking 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 Guidelines 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 Electronic Fund Transfer Act to treat fraudulently induced electronic fund transfers in the same manner as unauthorised 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 Practice 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.