Jun Wakabayashi
Taiwan is often not top of mind when it comes to fintech in this part of the world. It’s rather a curious phenomenon. I’ve always heard about Taiwan’s lacking fintech capabilities, but at the same time, I also recognize that the country features many characteristics conducive to innovation around financial services, including a strong talent pool, high rates of internet/mobile penetration, widespread access to credit cards and bank accounts, and a generally higher willingness to pay and save compared to other, more emerging countries in the region.
Yet, activity in this space feels paltry at best. There are currently less than 60 fintech players operating in Taiwan, in contrast to around 350 in South Korea, 600 in Hong Kong, and 1,200 in Singapore. Regulations are often cited as a primary deterrent. Regulations, however, are the bedrock of any financial system to prevent it from breaking. So, what is it specifically about Taiwan’s regulatory regime that seems to turn founders away? And what opportunities, if any, have yet to be uncovered for prospective fintech players looking to enter Taiwan
Money in the bank
Taiwan displays a very robust financial services sector, and is considered “overbanked” by most standard measures. There are 36 domestic commercial banks and 5,055 branch offices catering to a population of 24 million people according to Taiwan’s Central Bank. That’s equivalent to 210 branches per million population; by contrast, Hong Kong counted 165 and Korea 133 in 2017. Consequently, roughly 94percent of all Taiwanese adults now have bank accounts, visibly surpassing the global average of 69percent. The high concentration of financial services in Taiwanese cities has led to high levels of convenience, demonstrated by the ratios of 141 ATMs per 100,000 people (compared to the global average of 53), roughly 2 credit cards and 3 NFC payment cards (i.e. Easycard, iPass, iCard) per person, and the highest insurance coverage in the world.
From a startup’s perspective, establishing partnerships with banks and more specifically winning their trust is an uphill battle to say the least
Despite the well established banking system, penchant for digitalization among financial institutions is still sparse. Speaking to my own experiences as a consumer, I find myself commonly faced with clunky mobile banking apps or often displacing my physical passbooks which are still widely used by banks. Strict KYC/AML/anti-fraud procedures and largely paper-based processes can sometimes turn simple banking requests into half-day, in-person affairs. And of course, limited English speaking staff, user interfaces, and forms pose a distinct set of challenges for foreign entrepreneurs.
From a startup’s perspective, establishing partnerships with banks and more specifically winning their trust is an uphill battle to say the least. One lending startup that I spoke to spent more than a year meeting with multiple rungs of internal team members within a bank from product to sales to credit risk to compliance, all in an effort to convey their value proposition and get buy-in across the hierarchy for a potential collaboration. By contrast, it only took them 3 months to establish the same type of commercial partnership in a neighboring country.
The tides, however, seem to be gradually changing. In 2016, the Financial Supervisory Commission (FSC) which oversees all finance sectors unveiled a strategy to revolutionize fintech development in Taiwan. It details a handful of priorities including doubling e-payment penetration, promoting blockchain adoption, creating a fintech incubation hub, while issuing an industry-wide mandate for banks to collaborate more with startups and digitalize some of their existing service offerings. All these initiatives aim to ensure that financial institutions adequately meet consumers’ evolving needs and play an active role in facilitating Taiwan’s digital economy, instead of falling by the wayside.
Better safe than sorry
The basis of Taiwan’s regulatory and broader legal system finds its roots in Germanic civil law, which is widely adopted across continental Europe, Latin America, and many parts of Asia including Japan and South Korea. It’s a rule-based system that basically says “you’re only allowed to do what I say is allowed” as opposed to the more principle-based common law found in the US or UK where it’s more of a “if I don’t prohibit it, then you can do it” attitude, according to Shan Luo, managing director of FinTechSpace, a government-supported incubator for local and international fintech startups.
Consequently, many regulations in Taiwan follow a positive-listed approach, restricting the scope of possibilities to a very narrow band that may not adequately capture the evolution of technology. For example, a typical KYC process for opening an online brokerage account might stipulate a national ID card as a requirement under Taiwanese laws, whereas a negative-listed approach might just require anything that proves your ID. The latter is a broad stroke up for interpretation, whereas the former is a granular instruction that specifically dictates what is allowed, with anything outside those bounds requiring a codified change in the law, which can take upwards of 2 years.
The rigid legalese not only stems from the fact the regulators can be held personally liable for any fraud, misconduct, or oversight that resulted from their decrees, but also Taiwan’s largely export-driven economy. As a global manufacturer of electronic goods, Taiwan derives roughly 55percent of its GDP from exports, and is thus very cautious in preventing money laundering or any financial crime that might undermine its status as a reliable trading partner.
It comes as no surprise then that most finance-related activities require a license, which normally comes attached with steep capital requirements and strict AML procedures that fall beyond the means of a typical early stage startup.
More recently, the FSC announced its plan to roll out Open API across its entire banking sector, which essentially allows third-party service providers including startups to more seamlessly integrate with banks and leverage their data. Ultimately, this would allow customers to enjoy a more diverse and convenient array of financial services through technology, bringing Taiwan closer in line with global standards.
