Taiwan FSC proposes stablecoin permits with 40-day comment window

Taiwan’s Financial Supervisory Commission (FSC) on 6 November 2026 published in the Executive Yuan Gazette a 36-article draft of the Regulations Governing Issuance Permits and Management of Stablecoins. The proposal would require stablecoin issuers to obtain an FSC permit, obtain the Central Bank’s consent before approval, and comply with rules on issuance, redemption, reserve assets, internal controls and disclosures.

The draft implements provisions of Taiwan’s Virtual Asset Service Act, promulgated on 22 July 2026. It is not yet in force. The Gazette notice says comments may be submitted within 40 days from the day after publication. Counting 7 November as day one, the deadline is 16 December 2026.

A bank-centred issuance regime

The draft would allow banks to apply, alongside companies invested in by a financial holding company or bank and any other institutions the FSC later designates. A bank applicant would need to be a Taiwanese company, have no accumulated losses in its latest audited financial statements, comply with capital adequacy requirements, have received no fine in the previous year for deficiencies involving anti-money laundering and counter-terrorist financing, information security or internal controls, and have not been subject to specified Banking Act article 61-1 sanctions in the previous six months. The draft allows exceptions where the relevant deficiencies or circumstances have been improved and the FSC has recognised that improvement.

Foreign bank branches are excluded because the underlying Virtual Asset Service Act limits applicants to companies organised under Taiwan’s Company Act.

Non-bank issuers would need:

- minimum paid-in capital of NT$300m, funded in cash;
- public-company status, or a commitment to become a public company within one year of authorisation;
- an exclusive business of issuing and redeeming stablecoins; and
- where the issuer is invested in by a financial holding company or bank, combined ownership of more than 50%, including one financial holding company or bank holding more than 25%.

Atlas reads this as a bank-centred route rather than a general virtual-asset service-provider permission. The additional capital, public-company and dedicated-business requirements put non-bank issuance behind a substantially heavier corporate and governance perimeter.

The permitted products would also be narrow. An issuer could offer a stablecoin linked one-to-one to the New Taiwan dollar or to a single foreign currency. A stablecoin linked to a basket of fiat currencies would not qualify.

Each class of stablecoin would require a separate application. The application package would include a business plan, issuance and redemption procedures, a white paper, trust arrangements, cybersecurity controls, the technical architecture for restricting transfers when legally required, a CPA-reviewed internal-control checklist, reserve-assurance materials and a five-year information-system and business-continuity budget assessment.

The FSC could reject an application if the documents were incomplete, false, insufficiently concrete or difficult to implement, or if the proposal raised concerns about the sound conduct of issuance or redemption.

Full reserves and three-day redemption

The draft would require each class of stablecoin to have separate, full reserve assets. Reserves would have to be segregated from the issuer’s own property and from the reserves backing other stablecoins. Their fair-value total could not fall below the total amount of that class in circulation. Any shortfall would have to be replenished by the next business day and placed into the trust account.

Subscription payments would be held in a separate trust account for each class at a bank authorised to conduct trust business. The trustee could not be the issuer, although a non-bank issuer could use a related bank as trustee. The issuer and trustee would have to reconcile the account balance every business day and keep reconciliation records for at least five years.

The draft would restrict reserve use to redemption, legally permitted uses and related income distributions. Subject to ratios and ranges to be set by the FSC, assets could include same-currency bank deposits, government bonds, Treasury bills, negotiable certificates of deposit and other financial products approved after consultation with the Central Bank. The trustee bank would execute permitted investments.

Issuers would have to appoint a CPA to review reserve use and reserve adequacy each month, notify the trustee and file the result with the FSC within 15 days after month-end. A broader CPA review of issuance, subscription, reserve, redemption and related controls would be required every six months, with the result filed within two months after the end of each half-year.

Redemption would have to be paid in the same currency within three business days after the issuer accepts the application. Payment would come from the relevant trust account and would have to reach the redeemer’s own same-currency bank account or another method preserving a traceable payment record. The issuer could not delay payment or accept a third party’s request to stop it, except where required by a court judgment or other law.

Issuers would have to verify subscribers and redeemers and reject applications involving anonymous or false identities, unverifiable documents, unexplained abnormalities or persons and entities subject to terrorism-financing sanctions. An issuer could rely on a virtual-asset underwriter for customer identification, but would retain ultimate responsibility.

Controls, disclosures and the next stage

Non-bank issuers would be prohibited from providing holders with overdrafts, loans or other credit lines. All issuers would need board-approved internal controls, internal audit, compliance and risk-management systems. The internal-audit function would report to the board at least annually.

The proposal also requires operational-continuity procedures, secure information systems, sufficient cybersecurity staff and the ability to act quickly when a competent authority lawfully orders restrictions on a stablecoin’s transfer or disposition.

Public disclosures would include the issuer’s permit number, white paper, reserve and redemption policies, outstanding supply, reserve composition and value, CPA reports, trustee-bank details, redemption rights and costs, and complaint procedures. Outstanding supply and reserve composition would need daily updates; other information would be updated when it changed.

An issuer would have six months from permission to begin issuing. The FSC could grant one extension of up to six months if requested at least one month before the original deadline. It could revoke or rescind permission for false application materials, failure to begin on time, unauthorised changes or serious unresolved breaches.

The draft’s final article leaves the commencement date blank. The requirements therefore remain proposals pending the consultation and finalisation process. Comments can be filed through the FSC’s draft-announcements webpage by 16 December 2026.