Regulatory overview
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- Regulatory index
- Latest regulatory change
TaiwanTaiwan requires AML registration for virtual asset service providers within scope. The services act promulgated in July 2026 establishes a future licensing and stablecoin regime whose commencement depends on the Executive Yuan. Tokenized securities remain subject to securities rules and are not authorised by VASP registration.
A business providing virtual asset services in Taiwan must distinguish current registration from the act promulgated in July 2026. The new act provides category-specific licences and stablecoin rules, but its timetable depends on a commencement decision; promulgation alone does not open every procedure.
If the aim is to issue debt or an economic interest through tokens, there is also a specific securities route under TPEx rules. The instrument, intermediary and investor status determine access. VASP registration and industry membership do not replace that assessment.
Which framework applies and what depends on the new act
The AML registration regulations have applied since 30 November 2024 to exchange, transfer, custody and participation in virtual asset issuance or sales. Their definition excludes securities and other financial assets issued under their applicable laws. Article 3 requires completed registration while preserving permissions required under other regimes.
The Virtual Asset Service Act, promulgated on 22 July 2026, establishes category-specific licences and a stablecoin regime. Article 56 leaves commencement to the Executive Yuan. The official database consulted still identifies provisions awaiting implementation; promulgation must not be presented as the immediate opening of the new licensing system.
How FSC, the central bank and TPEx are involved
The FSC handles registration and supervises the services framework. It is also the competent authority under the 2026 act, with Central Bank involvement within that institution's remit. Article 34 requires consultation and Central Bank consent before stablecoin issuance can be authorised under the new regime.
Taipei Exchange, TPEx, participates in the specific security token procedure, reviewing securities firms' applications before submitting them to the FSC. TVASPA performs industry association functions, but membership does not replace public registration or turn securities activity into an ordinary VASP service.
What registration requires and how future transition is calculated
An AML application requires corporate documents, responsible persons, beneficial owners, procedures, internal controls and a CPA review of those controls. Overseas providers need the required company or branch registration. Article 6 requires TVASPA membership before operations and sets a deadline for commencing business after registration, not a deadline for granting registration.
Article 55 of the new act provides that qualifying existing operators must apply within twelve months and obtain a licence within twenty-one months from commencement. The latter deadline may be extended once by three months. This future transition neither waives current duties nor automatically begins in July 2026.
What the STO route permits and which right investors receive
The TPEx STO rules define a securities firm trading route. Article 25 covers profit-sharing tokens without shareholder rights and debt tokens; Articles 30 and 31 restrict subscription to professional investors subject to conditions. This does not generally authorise tokenized shares, real estate or every public offering.
Documentation must specify the claim or economic entitlement against the issuer, repayment terms and transfer restrictions. TPEx requires consistency between programmed execution and the prospectus, alongside technical, financial and legal opinions. A revenue interest does not itself establish direct ownership of the property or business producing that revenue.
Which custody and disclosure controls providers must maintain
Articles 23 to 27 of the registration regulations govern segregation, ownership, permitted use, key policies and reconciliation of assets in custody. The framework also addresses asset admission, information and complaints. Its AML label must not be interpreted as an absence of operational controls or a public solvency guarantee.
The promulgated act adds express provisions on excluding customer assets from the insolvency estate and on stablecoin reserves. Commencement and implementing requirements must be checked before attributing those protections to a current transaction. Contracts must address return, incidents and customer rights without promising full recovery merely because a token is used.
What to prepare before choosing registration, licensing or the STO route
Start the file with the issued right and each entity’s activity. If using the STO route, confirm the product, professional investor status and authorised intermediary; align the token’s operation with the prospectus and ownership records.
For VASP services, check current registration, membership and operating controls while monitoring official commencement of the 2026 act. Calculate transition from the event specified by the law, not a report of its passage. Document custody, reconciliation and return without anticipating future protections not yet applicable.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- AML registration does not replace permissions for other financial activities.
- The July 2026 act distinguishes seven provider categories and stablecoin issuance.
- Its transitional periods run from commencement, not promulgation.
- The TPEx STO route defines eligible products and investors rather than permitting every retail token.
Regulatory milestones
AML registration takes effect
Activity-based virtual asset registration requirements apply.
Frequently asked questions
Promulgation alone does not determine commencement. Article 56 leaves the date to the Executive Yuan, and Article 55 calculates transition from that date. Current duties must be maintained and the official timetable checked.
It does not replace securities market permissions. The TPEx STO route has intermediary, product and professional-investor requirements and does not automatically cover every issuance.
No. Article 6 sets the period for commencing operations after registration is completed. It is not a promise to decide an application within six months.
No. The AML regulations require completed registration and association membership before operation. Membership does not replace permissions required by other laws.
Article 9 requires prior FSC approval for listed changes, including responsible persons, beneficial owners and lines of business. Other application changes must be reported within five business days; classify the change before implementing it.
