Since the UK proposed its regulatory sandbox regime in November 2015, APAC countries such as Australia, Malaysia and Singapore have been quick to follow pace with their own proposals for a similar regulatory "safe space". Hong Kong, although arguably late to the race, has caught up by having its sandbox regime come into effect from the day of announcement (6 September 2016) while other regulators in the APAC region are still going through the process of public consultation (Australia, Malaysia and Singapore). However, unlike other sandbox regimes which aim to cater to a range of firms, the Fintech Supervisory Sandbox (FSS) launched by the Hong Kong Monetary Authority (HKMA) is only open to institutions authorised under the Banking Ordinance and already under the supervision of the HKMA, ie, licensed banks, restricted licence banks and deposit-taking companies.

In our briefing, we take a closer look at:

  • the different regulators' motivations for introducing a sandbox;
  • how Hong Kong's sandbox for authorised institutions (AIs) operates – and what alternatives are available for non-AIs; and
  • the different sandbox regimes in Australia, Malaysia, Singapore and the UK.

Please click here to read the full briefing.


Herbert Smith Freehills LLP is licensed to operate as a foreign law practice in Singapore. Where advice on Singapore law is required, we will refer the matter to and work with licensed Singapore law practices where necessary.