不丹：金融科技监管沙盒框架的审查和诊断

BHUTAN Review and Diagnostic of the Fintech Regulatory February2026 Puja Singh (Monetary and Capital Markets Department) and Ken Coghill (Short-term External Expert) High-Level Summary Technical Assistance ReportMonetary and Capital Markets Department Bhutan:Review and Diagnostic of the Fintech Regulatory Sandbox FrameworkPrepared by Prepared by Puja Singh and Ken Coghill (MCM) TheHigh-Level Summary Technical Assistance Reportseries provides high-level summaries of the assistance provided to IMF capacity development recipients, describing the high-level objectives, findings,and recommendations. ABSTRACT:This report summarizes the International Monetary Fund's (IMF) technical assistancemission to the Royal Monetary Authority of Bhutan (RMA), focused on reviewing and strengthening thefintech regulatory sandbox (RS) framework. The mission, conducted from August 25 to September 2,2025, assessed the RS's alignment with Bhutan's digital transformation goals, its capacity to foster JEL Classification Numbers:E42, E44, G18, O16 (consulthttps://www.aeaweb.org/econlit/jelCodes.php)Keywords:Regulatory Sandbox; Fintech; Financial Innovation; Financial Regulation; Digital Financial The contents of this document constitute a high-level summary of technical advice provided by the staff ofthe International Monetary Fund (IMF) to the authorities of Bhutan (the "CD recipient") in response to theirrequest for capacity development. Unless the CD recipient specifically objects within 30 business days of International Monetary Fund, IMF PublicationsP.O. Box 92780, Washington, DC 20090, U.S.A.T. +(1) 202.623.7430 • F. +(1) 202.623.7201publications@IMF.org Background The Royal Monetary Authority of Bhutan (RMA) launched its regulatory sandbox (RS) framework in June2020 to provide a controlled environment for testing innovative financial products and services built onemerging technologies. Recognizing the need to strengthen this framework to support Bhutan's broader The IMF's technical assistance was structured around three core objectives: (1) conducting a two-daycapacity development workshop for RMA staff on regulatory approaches to fintech and RS best practices;(2) reviewing the existing RS framework to assess its functionality, governance structures, and alignmentwith Bhutan's digitalization strategy; and (3) engaging with stakeholders—including central bank The mission was conducted on-site in Thimphu, Bhutan, from August 25 to September 2, 2025. Itincluded training sessions supported virtually by the UK Financial Conduct Authority (UK FCA) and UAEDubai Financial Services Authority (UAE DFSA), bilateral meetings with RMA departments and financialsector stakeholders, and assessment of Bhutan's digital financial ecosystem. This work complemented Summary of Findings The mission found that while the RMA had made progress in establishing the foundational RS framework- limited resources, critical challenges hindered its effectiveness. A key theme was the absence of a clearlegal mandate for the RS. The board memo establishing the RS and letters of admission (LoA) neitherexplicitly outline the legal basis nor clarify enforceability of RS-related activities. The absence of explicit Another key theme was unclear strategic alignment and overly broad scope. The RS lacked alignmentwith RMA's core mandate of financial stability, market development, and financial inclusion, covering 12types of activities including both regulated and non-regulated services. Of six current cohort participantsin the ongoing second cohort, none had conducted live testing with real customers; most were developing The mission also revealed governance weaknesses and resource constraints. Governance structuressuffered from overlapping mandates, with the Steering Committee (SC) combining strategic andoperational roles and the Technical Evaluation Committee (TE&CC) managing both applicationassessments and supervision, creating conflicts of interest. The RS operated without dedicated full-time Furthermore, the mission identified absence of formal risk tolerance frameworks, inadequate eligibilitycriteria lacking character and fitness requirements, insufficient operational procedures, and no clear exitstrategies. Data privacy concerns arose from intended sharing of anonymized customer data withoutadequate legal basis or customer consent frameworks under RMA's Data Privacy and Data Protection Summary of Recommendations To effectively strengthen the RS framework, the mission recommended that RMA authorities first identifysupervisory priorities and conduct a comprehensive feasibility study to assess whether a regulatorysandbox, innovation hubs, tech sprints, or alternative mechanisms best serve Bhutan's needs given Following the feasibility study, governance structures should be reorganized by establishing a legalmandate for the RS, creating a dedicated role for the sandbox, limiting the SC to strategic oversight, and The RS should be rebranded as pa