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Fintech & Payments Legal Outlook 2025

The global fintech industry looks to be rebounding after the first half of 2024 saw continuing decline in investment, funding, and M&A volumes. The second half of the year has seen the tide start to turn with the insatiable appetite for AI in finance has bringing a renewed sense of hope. Following Trump's re-election in the US, global markets and tech stocks are experiencing a boost and going into 2025, the mood is more positive.

Meanwhile, ongoing efforts to digitalise financial assets, payment systems, and market infrastructure are progressing from pilot to scale, with tokenisation holding transformative potential. Retail customer demand for instant, frictionless payments drives innovation, and all market participants are feeling the pain of cost pressures for which the innovation holds the promise of solutions.

The compliance landscape is increasingly complex for fintech and payments, including crypto and digital assets. Regulators are expanding oversight, but are recognising the need to promote innovation in a competitive world where nationalism is on the rise. Different regulatory approaches and a lack of common standard add to the challenge, with divergences between the EU and UK, competition between Singapore and Hong Kong, and in the US, continuing and often contentious regulatory questions - with hopes that could change in 2025.

We focus on opportunities and risks in finance innovation, including tokenisation, new forms of digital money, instant payments and open banking. These innovations unfold amid growing demand for AI, security, and resilience in financial services - and the increasing convergence of AI and digital assets. For those innovating to solve the key efficiency challenges in finance, taking a holistic approach to the compliance challenge has become an imperative.

The Future of Fintech & Payments in 2025

A global legal perspective

Peiying Chua

"In Asia, demand for fintech continues to be driven by growing economies and underbanked populations although fintech players face scaling challenges due to geopolitical, market and regulatory diversity. Asia is also set to lead in RegTech adoption, with significant government and private sector support, while investor interest in AI-driven fintech looks set to boost funding in 2025.

Hong Kong and Singapore both have maturing fintech ecosystems with supportive regulatory environments, fostering innovation in payments and digital assets. Together with the UAE, Hong Kong and Singapore have advanced bespoke licensing for cryptoasset service providers and stablecoin regulations also emerging.

There has been continued rollout of regulatory sandbox and pilot initiatives designed to support the development of digital market infrastructure. These sandboxes may also influence permanent changes to the legal and regulatory environment, depending on the findings of the policymakers behind them.We expect to see more sandbox activity in 2025, while again it will likely take much longer for the full effects on the market to be seen.

While Mainland China has been a first mover in regulating specific types of AI, in Hong Kong and Singapore regulators have focused on providing guidance on the use of AI by financial institutions. As regulators intensify their focus on AI governance in Asia, the volume of guidance is likely to grow."

Peiying Chua, Asia Head of Fintech

Marius Raetz

"Despite a decline in European funding, mid-market fintech M&A is rising, driven by mature fintech companies pursuing acquisitions amid uncertain IPO markets.

The EU is at the forefront of cryptoasset regulation through MiCA – which will continue to phase in over 2025, and is enhancing operational resilience under DORA, coming into force in January 2025. The EU's proactive regulatory approach to cryptoassets targets stablecoins, restricting certain business models and supporting the Digital Euro project aimed at strategic autonomy and widespread access to CBDC. It is looking to support innovation with the EU DLT Pilot Regime and a programme of exploratory work on new technologies for wholesale central bank money settlement.

The AI Act which is being phased in over the next couple of years, together with sector-specific regulatory guidance, requires financial firms to become AI-literate as well as adaptable to open finance as directed by FIDA reforms. The security of EU wide open finance will be supported by the European Union Digital Identity initiative. This aims to provide secure cross-border digital identity solutions, with 83 million digital ID wallets projected by 2025.

The Instant Payments Regulation mandates eurozone banks to engage in cost-free instant credit transfers with a phased implementation in 2025 and full compliance by 2027. Additionally, efforts are underway to mitigate payment card fraud, urging shared liability among tech firms."

Marius Raetz, Germany Head of Fintech

Richard Hay

"The UK continues to dominate Europe’s fintech ecosystem in terms of funding, with a number of maturing fintechs focusing on global expansion. Like many other sovereigns, supranational and agencies, the UK is experimenting in digital issuances, while the industry led Regulated Liabilities Network project is working on a ‘platform for innovation’ across multiple forms of digital money.

On digital assets, the UK is seeking to capitalise on the second-mover advantage with its regulatory package and Digital Securities Sandbox, and address some of the learnings from MiCA. The FCA's roadmap covers stablecoins, crypto custody, and financial crime, with consultations taking place in 2025 and regulations expected to go live in 2026.

As part of the UK’s national payments vision unlocking open banking enabled A2A payments for e-commerce is a strategic short to medium term priority. The UK is planning to introduce a legal framework for digital verification services, without creating a mandatory digital ID system, to improve P2P payments. It has already introduced a fraud reimbursement requirement and pressure may grow to slow down some payments.

In 2025 regulators will use new powers the UK’s critical third party regime to start designating some those “critical” to the financial system and imposing operational resilience rules on them directly. Meanwhile proposals for the regulation of frontier AI are also expected."

Richard Hay, UK Head of Fintech

Joshua Ashley Klayman

"Trump's campaign promises – including making the US the “crypto capital of the world” – have fueled crypto market enthusiasm and increased deal-making and interest from investors, builders and contributors. Irrespective of whether Trump delivers on these pledges, the market already has felt the impact, and Bitcoin has reached all-time price highs. And with Republican majorities in both Congressional houses, many expect long-awaited crypto market structure and stablecoin legislation in the second half of 2025, with more immediate priorities being taxes, tariffs, immigration and national security.

Changes in key regulatory leadership, including the SEC and Treasury, and a projected end to “regulation by enforcement,” will lead to greater legal certainty for crypto and tokenization projects. Trump has appointed the White House’s first-ever “AI and Crypto Czar,” signaling an elevation in strategic priority of both the AI and crypto sectors and reflecting the increasing convergence of AI and digital assets.

A more welcoming US regulatory stance towards crypto, together with a focus on US competitiveness, will open opportunities for novel digital asset related products and services and market players, from digital natives to traditional financial institutions and household names, are likely to enter the crypto space in force.

While Trump has vowed not to permit a US CBDC during his term, and FedNow adoption continues to be slow, we anticipate continued advancement and experimentation in the area of digital financial market infrastructure (DFMI). In addition, the CFPB is laying the foundation for open banking in the US, and digital identity verification standards are developing. "

Joshua Ashley Klayman, US Head of Fintech

Key themes

Explore the publication

1

A brighter horizon for global fintech investment and funding

In 2025, the global fintech sector is expected to see a rebound in investment and M&A activity with deal volumes expected to rise if geopolitical uncertainties ease and interest rates stabilize. There is optimism for VC growth and late-stage funding rounds, especially in emerging economies where fintech continues to address significant market needs. We hone in on the bright spots.

"While there is a lot of investor dry powder needing to be deployed, investors are looking for business models with positive unit economics and the ability to scale in a commercially rational manner."

Niranjan Arasaratnam, Partner, Singapore

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2

Route to digital market infrastructure: same road, same direction, new milestones in sight

Momentum continues to build behind tokenisation initiatives and other efforts to digitise the financial markets. More milestones are expected to be met in 2025, building on the progress of previous years. But there remains a long road ahead. The implications of the forces currently in play will likely take several years to unfold.

"It may sound like the same story year-on-year, but the market has seen meaningful progress on various fronts over the last year, and we can expect more in 2025."

Richard Hay, UK Head of Fintech

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3

Diverging policy approaches to retail stablecoins and central bank digital currencies

There has been an uptick in stablecoin initiatives over the last year as the sector explores mainstream use cases. Several jurisdictions have introduced or are introducing new stablecoin regulations, but there are notable differences in the scope and effects of these regimes. Meanwhile, some central banks are strongly pushing retail CBDCs while others see no need.

"In the short to medium term, stablecoins and CBDCs may become important components of a diverse retail payments landscape."

Peiying Chua, Asia Head of Fintech

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4

Real time payments: the challenge of increasing both speed and security

Digital payments have become a bedrock of the global economy. Technological advancements and consumer demands are driving faster and more convenient digital payments. But greater speed and less friction can increase risks. Different countries around the world are finding different ways to promote innovation while also protecting consumers.

"For card payments, biometric authentication methods, such as fingerprint scanning and facial recognition, are becoming more widespread. In the longer run, technologies like blockchain and AI could potentially help enhance the security of payments without compromising speed."

Ben Packer, Litigation, Arbitration and investigations Partner, London

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5

An increasingly fragmented landscape for cryptoasset regulation

Across the world cryptoassets are increasingly being brought inside the regulatory perimeter. But jurisdictions are taking different approaches and moving at different speeds resulting in a complex and fragmented regulatory landscape. Going into 2025 all eyes are on the leading crypto market, to see what the Trump 2.0 administration will influence the US regulatory landscape and, in turn, the market.

"In 2025, crypto, like AI, appears to be a strategic must-win for the US. A clearer, more welcoming US regulatory stance will likely have big impacts on crypto markets across the world."

Joshua Ashley Klayman, US Head of Fintech

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6

Increasing need for AI resilience in Financial Services

Artificial intelligence continues to challenge the way that financial services firms think about their business. The emergent capabilities of generative AI, in particular, raise both excitement and caution as firms test what the latest technology can do and where its limitations lie. For regulated firms, AI-specific rules and guidance are on the horizon but the immediate priority is ensuring their AI adoption meets existing standards, including those designed to manage third-party risks.

"Setting up an AI governance framework which ensures compliance with existing data protection and financial services regimes is an important first step towards meeting the additional challenges of AI-specific regulation."

Julian Cunningham-Day, Global Co-Head of Fintech

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7

The future of finance is open: the role of digital identity in open banking and finance

Open banking is transforming the financial landscape and gaining worldwide momentum. Even in jurisdictions where open banking has been mainly industry-led, regulators are now providing frameworks which support customers in accessing a wider range of innovative financial products through open finance. Digital identity and biometrics have a key role in providing the security to ensure consumer trust in greater data sharing and collaboration between financial service providers.

"As they innovate to meet customer demands, firms must also continue to meet regulatory standards, such as making sure they protect their customers’ data."

Guillaume Couneson, Partner, Brussels

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