Taiwan weighs fund-manager trading changes: the current reporting duties

Taiwan's Financial Supervisory Commission (FSC) is reviewing restrictions on investment-trust staff's personal trades and electronic devices, CNA reported on October 15, 2026. The regulator said it would weigh conflicts of interest, market development and the interests of employees and investors. It did not announce an adopted relaxation or a commencement date. The report also records the regulator declining to attribute individual departures to those restrictions.

For a US or other international asset manager recruiting into a Taiwan securities investment trust enterprise, an offer of greater investment freedom therefore needs a basis in the rules that currently apply. A headquarters policy or anticipated reform cannot establish what a Taiwan fund manager may trade. The current reporting framework also reaches some family interests, with different information requirements for different relatives.

The reports cover more than the manager's account

Article 77 of the Securities Investment Trust and Consulting Act requires specified responsible persons, department heads, branch managers, fund managers and their related persons to report stock and equity-derivative transactions to their enterprise under FSC rules. Article 14 of the personnel regulations defines related persons and extends the reporting framework to investment managers conducting discretionary investment business.

The FSC's November 27, 2024 order supplies the detail. For covered personnel, holdings are reported within ten days of starting the role. Previous-month transactions are reported by the tenth of the following month; no monthly transaction report is required when there were no trades. The individual, spouse and minor children's covered trades must also be reported before execution. The order identifies Taiwan exchange-listed, over-the-counter and Emerging Stock Board shares and specified equity derivatives as reportable investments.

For other blood relatives within the second degree, such as parents, siblings and adult children, the report generally needs only names and identification numbers, rather than transaction details. The order permits an exemption for those other relatives who are foreign nationals, do not reside in Taiwan and have not invested in the specified Taiwan shares. A global onboarding form demanding every relative's complete overseas brokerage history would not accurately describe this particular reporting obligation.

Article 77 separately restricts covered personal trading from the enterprise's decision to use fund assets to trade the relevant shares or equity derivatives until the fund no longer holds them, subject to FSC exceptions. Filing a report does not itself satisfy that separate restriction. A proposed transaction still needs assessment under the applicable exceptions and controls.

Disclosure can lead to recusal

Article 15 of the personnel regulations prohibits a covered person from participating in a fund's decision to trade an issuer's securities when that person or their spouse is the issuer's director, supervisor, manager or a shareholder holding at least 5%. For that threshold, the rule includes shares held by a spouse, minor children or through another person's name.

This affects staffing as well as account monitoring. A manager's spouse may have a corporate role that requires the manager to step away from a particular investment decision even when neither spouse proposes a personal trade. A declaration filed with compliance would identify the issue; it would not remove the prohibition on participating in that decision.

Article 13 also imposes duties of care, loyalty and good faith on the enterprise's covered personnel and employees. Subject to exceptions provided by law, it prohibits leaking information learned through work or using it for securities trading. These duties concern the use of information, regardless of whether it passes through an office terminal or a personal device. The reported review provides no basis to promise a new hire that those duties have ended.

Fictional scene

Sources

• CNA, October 15, 2026: the FSC's ongoing review of personal trading and device restrictions.
• Securities Investment Trust and Consulting Act, Article 77: trading restrictions, regulatory exceptions and reporting duties.
• Regulations Governing Responsible Persons and Associated Persons of Securities Investment Trust Enterprises, Articles 13, 14 and 15: conduct, related persons and recusal.
• FSC Order No. 1130385818, November 27, 2024: reporting scope, timing and exceptions; effective on issuance.

Sources checked: October 17, 2026. The cited provisions and order are in force; the reported review remains a review. This is general Taiwan-law information, not approval of a particular personal trade.