COUNTRY NOTE • LICENSING
Taiwan | Crypto License (VASP Registration) • 2025
General Overview

Taiwan regulates virtual-asset businesses through a multi-agency model led by the Financial Supervisory Commission (FSC), with the Central Bank of the Republic of China (Taiwan), the Ministry of Justice (MOJ) for AML/CTF, and the industry’s self-regulatory body TVASPA providing additional oversight and coordination.

Crypto is not legal tender; it is treated as a virtual commodity/investment asset. Core obligations center on AML/CTF, real-name verification, internal controls, and consumer protection.

What You Can Do with a Taiwan VASP License
  • Operate an exchange (retail & institutional spot markets)
  • Provide wallet/custody (segregated client assets, key-management standards)
  • Run other VA services/projects (subject to scope alignment and ongoing AML/CTF compliance)
  • Join TVASPA (recommended SRO participation for standards and cooperation)
License Scope & Regulators

Primary regulator: FSC (designated lead for crypto since Mar 2023).

Supporting authorities: Central Bank (policy/monitoring), MOJ (AML enforcement).

Self-regulation: Taiwan VASP Association (TVASPA)—industry standards, best practices, and coordination with authorities.

Process & Timeline (Typical: 4–6 months total)
Stage 1 — Preparation (2–4 weeks)
  • Map services and target users; build end-to-end AML/KYC/EDD and real-name flows.
  • Draft a comprehensive business plan, governance model, and org chart.
Stage 2 — Filing (3–6 weeks)
  • Submit the application pack to the FSC: business plan, AML policies, tech/cyber documentation, company structure, key-person details (fitness & propriety).
  • Expect completeness checks and clarifications; background checks on principals.
Stage 3 — Banking Enablement (2–4 weeks)
  • On approval/conditional approval, open a corporate account with a local bank or EMI, providing license/registration documents and compliance evidence.
  • Core dossier components: Business plan; AML/CTF framework; technical & security documentation; financials/tax records; IDs and background checks for directors/officers.
Minimum Requirements (At a Glance)
  • Taiwan legal entity (local registration required for overseas firms before serving TW clients)
  • Physical office & on-shore operating capability
  • AML Officer (management-level) and compliance function
  • Clean criminal records for directors/officers; proven AML/CTF competence
  • Internal controls: segregation of client vs platform assets, change management, incident response
  • Listing/review mechanism for asset admission & delisting
  • Banking/EMI relationship suitable for VA flows
  • (If issuing tokens): publish a white paper and observe STO/SEA rules where applicable
  • No statutory minimum capital in general; appropriate paid-in capital should reflect risk, scale, and service set.
Legal & Policy Framework
  • Money Laundering Control Act (AML): mandatory AML/CTF program, effective July 1, 2021 (scope clarified Apr 2021).
  • Securities and Exchange Act (SEA): applies where a token qualifies as a security; STO Regulations (2019) set specific compliance.
  • FSC Guiding Principles (Sept 2023): governance, custody, listing reviews, consumer protection, disclosure, and internal controls.
  • TVASPA (June 2024): 24 founding members; collaborative self-regulation and anti-fraud initiatives with government.
Company Registration (How to Set Up)
  • Form a limited company under the Company Act (name check, Articles, scope).
  • Appoint ≥1 director, establish a local office, books and records on-shore.
  • After incorporation, prepare the VASP submission (see Process) and align operations (staffing, vendors, cybersecurity, audit trail).
Taxation (Quick Guide)
  • Corporate Income Tax: 20% on net taxable income.
  • Capital Gains: taxed under general income rules (no crypto-specific CGT regime).
  • Withholding: generally 21% for non-resident dividend recipients (treaty may vary).
  • VAT: 5% may apply to on-shore transactions; nexus and transaction type determine liability.
  • Foreign entities creating a permanent establishment (branch) → Taiwanese CIT applies.
Ongoing Obligations (Post-Approval)
  • Periodic reports to FSC/authorities; cooperate on inspections.
  • Continuous CDD/EDD, monitoring, sanctions screening, STRs.
  • Strict segregation of client assets; reconciliations; wallet governance (hot/cold splits, key ceremonies).
  • Governance & internal control: risk management, audit/compliance testing, incident logs.
  • TVASPA participation recommended for shared standards and anti-fraud work.
Sanctions & Enforcement
  • Fines and remedial orders for AML/CTF/control failures.
  • License/registration revocation or restrictions for serious breaches.
  • Criminal liability (incl. imprisonment) for severe AML/CTF violations.
  • Public disclosures can damage reputation and customer trust.
  • Proposed AML amendments (2024) increase penalties for non-compliance.
Turnkey Snapshot
  1. Incorporate in Taiwan; secure office; appoint directors.
  2. Hire AML Officer; finalize AML/CTF & real-name program.
  3. Prepare dossier: business plan, tech/cyber, custody, governance, listing policy.
  4. File with FSC; respond to Q&A and background checks.
  5. Open local banking/EMI account; align ops and reporting.
  6. Go live; maintain audits, monitoring, and SRO engagement.
CryptoWisely.io Insight: Taiwan is compliance-forward and cautiously permissive — strong AML/CTF perimeter, consumer-protection rules, and rising self-regulation via TVASPA. It suits exchanges, custodians, and wallet providers that demonstrate real on-shore substance, tight controls, and transparent governance. Compared with lighter offshore routes, Taiwan demands maturity but rewards credibility and government-industry alignment — ideal for regional trust and North Asia anchoring.