Across Asia Pacific, there have been many regulatory sandboxes launched in recent years intended to support fintech innovation. However, in many cases, big fintech success stories emerged outside of the sandboxes, usually because the sandboxes were too restrictive. While regulatory support is important to facilitate a healthy fintech ecosystem, it is not usually government that spurs the most significant innovation – but the private sector.
In many cases, the sandbox concept looks good on paper, but once put into practice, it constrains a fintech’s ability to grow. This can be especially detrimental for very young companies that are trying to scale up and build significant user bases.
One characteristic of regulatory sandboxes in the APAC region that seems to vary little despite the significant disparities in market environments, regulatory systems and consumer financial habits is that they put a heavy emphasis on structure and control – the overriding objective seems to be to promote financial innovation without taking any real risks. But by eliminating almost any potential risk, sandboxes also constrain the options that their participants have to develop their products and services.
The Taiwan experience: High expectations, unremarkable results
With a reputation as one of the more conservative financial markets in Asia, Taiwan seemed like an ideal candidate for a fintech regulatory sandbox that could allow startups some room to experiment. At the time its first sandbox law was passed, in late 2017, Taiwan was eager to develop its fintech sector. With a large amount of idle capital held by its incumbent financial services giants, Taiwan wanted to guide this money into productive investments instead of real estate speculation.
At the time, the Act on Financial Technology Innovations and Experiments was passed, the Taiwanese legislator who initiated it, Karen Yu, said that its passage made Taiwan the first country in the world to introduce a financial regulatory sandbox law. She said that “the legislation would greatly increase the flexibility of financial-oriented regulations that have been limiting innovation, while “breaking down barriers between sectors, so that tech and financial firms can work together seamlessly.”
Though the lawmakers who played a key role in the legislation sought to overcome expected bureaucratic inertia, in practice, red tape became a formidable obstacle to the sandbox’s success. For instance, the sandbox committee was supposed to decide within 60 days if a submission qualified, but we learned by talking to fintech startups that slow review of applications became the norm, while in some cases, simply getting the application completed correctly was difficult because of its many requirements.
We observed during the creation of Taiwan’s fintech sandbox that incumbent financial institutions, which maintain close relationships with Taiwanese financial regulators, may have used their clout to shape the sandbox’s rules – and ensure that the risks of disruption were minimized. This “regulatory capture” caused Taiwan’s Financial Supervisory Commission (FSC) to emphasize prudential regulation more than financial innovation and enhanced competition. Citing observations from a UK fintech firm, Taiwanese researchers noted in an in-depth research report on fintech sandboxes published in November 2021 that “financial researchers from the U.K. and Singapore proactively respond to fintech entrepreneurs while the Taiwanese counterpart’s response is comparatively reactive.”
As of May 2024, there have not been any notable success stories from Taiwan’s fintech sandbox. The number of participating firms remains extremely small, and the last time the FSC reported on a new entrant was November 2020, when the regulator authorized the company Joinvest to launch a group buy platform for bonds in the sandbox.
Australia sees room for improvement
The first iteration of Australia’s fintech sandbox is only slightly older than Taiwan’s – by about a year – and similarly has struggled to produce any notable successes. However, while Taiwan seems willing to leave its sandbox “as is” – Australia is moving to rejuvenate the experimental space in a bid to make it more useful for fintech startups. Canberra’s approach is likely informed by the determination of regulators to introduce greater competition to a financial services sector historically dominated by the Big Four banks: National Australia Bank (NAB), Commonwealth Bank of Australia (CAB), Westpac and Australia and the Australia and New Zealand Banking Group (ANZ).
Notable fintech failures in Australia over the past few years may have convinced regulators that the sandbox has an important role to play. These include the abrupt implosion of the Australian neobank Xinja in December 2020, the January 2021 acquisition by NAB of online lender 86 400, effectively eliminating a new competitor, and the collapse of the digital bank Volt in June 2022. By one estimate, 41% of Australian fintechs are not reaching their capital raising targets.
In April, the industry group FinTech Australia called on the Australian federal government to urgently review the current iteration of its fintech regulatory sandbox, which has been in place for less than four years. Fintech Australia said that the sandbox is “underutilized and not fit for purpose.” The industry group highlighted what it sees as the sandbox’s major shortcomings. Onerous restrictions prevent it from being practical as a testing ground.
One possibility to improve the effectiveness of the sandbox would be to require approval from the Australia Securities and Investments Commission (ASIC) before testing can begin. This approach could ease the regulatory burden on startups, speed up their time to market and still ensure adequate protection of consumers.
To increase the likelihood of sandbox reforms being successful, FinTech Australia has called on the federal government to earmark specific funding in Australia’s A$15 billion National Reconstruction Fund.
Sandbox for stablecoins
For its part, Hong Kong is taking the sandbox concept in a different direction than Taiwan or Australia. The city appears intent on using a fintech sandbox as part of its plan to build a hub for cryptocurrency.
To that end, the Hong Kong Monetary Authority (HKMA) in March announced the launch of a sandbox for stablecoins. Per the sandbox rules, applicants should have genuine interest in developing a stablecoin issuance business in Hong Kong with a “reasonable business plan” with a limited scope and in a risk-controllable manner,” the HKMA said in a news release. I
It seems the HKMA wants to use the sandbox in a consultative manner. HKMA chief executive Eddie Yue said in the news release that the sandbox is intended to allow industry and the HKMA to exchange views on the city’s stablecoin regulatory regime. The regulator expects that the sandbox “will facilitate the formulation of fit-for-purpose and risk-based regulatory requirements, which is key to promoting the sustainable and responsible development of the stablecoin issuance business,”
One of the sandbox’s first projects is a proof-concept pilot involving Standard Chartered, the digital bank Mox Bank, Mastercard and Libera. The project explores the operational and risk management benefits of tokenized deposits to support the settlement of tokenized assets.
It will be interesting to see how the pilot pans out. Though the participants laud the benefits of tokenized asset settlement in the context of carbon credits in a news release, it is not fully clear why tokenization would be necessary, and how it would better support sustainable finance than non-blockchain solutions. On the other hand, if the pilot is successful, there could be positive implications for the broader fintech sandbox concept – and even stablecoin issuance elsewhere in Asia.
New sandbox initiatives
It would be premature to draw the conclusion that cryptocurrency is the fintech segment best suited for sandboxes looking only at the Hong Kong example – especially as time will be needed to assess the project. That said, the sandbox environment might be suited for crypto startups. The reason is that compared to other fintech segments like payments (in fiat currency), digital banking, embedded finance etc. crypto is more volatile and prone to problems. In a sandbox scenario, the crypto sector could feel relatively free to experiment while being insulated from the typical regulatory challenges it faces.
With that in mind, in mid-May, the Philippine fintech Coins.ph said that it had started testing its Philippine Peso stablecoin, PHPC, as part of a Bangko Sentral ng Pilipinas (BSP) sandbox. The testing is expected to continue until June. Thereafter, the central bank will assess whether the stablecoin can be opened up for wider usage. Coins.ph believes that PHPC can be used for remittances, trading, B2B payments and Web3 gaming.
Coins.ph’s leadership seems confident about its stablecoin. The platform is targeting 20,000 to 30,000 users of PHPC during the sandbox period and expects to receive full approval for the stablecoin in two to three months, while the pilot is expected to be launched on the Coins.ph platform early June. “We’re being monitored for performance and there’s a set of metrics that we have to hit. Once we hit those metrics, then we can leave the sandbox,” Coins.ph Chief Executive Officer Wei Zhou said at a media briefing in early May.
Given the Philippines’ payment digitization and financial inclusion goals, the PHPC stablecoin might well gain traction – and along with Hong Kong’s pilot, show that the sandbox concept can be helpful for at least one fintech segment. Meanwhile, it will be essential to keep in mind that previous fintech regulatory sandbox initiatives across the region did not come to fruition because regulators erred too heavily on the side of caution. The key for the success of these new initiatives and others in the future will be striking the right balance between prudent regulation and creating an environment that fosters innovation.