BBO Think Tank · Regulatory Intelligence · 2026

The BBO Sandbox
Benchmark Report

A comparative study of how nine of the world's leading financial centres regulate and test virtual-asset firms, with a practical roadmap for any country building a regime of its own.

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Jurisdictions
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Sandbox frameworks
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Regulatory themes
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Primary sources
About the benchmark

Why this report exists

New kinds of financial firms, from crypto exchanges to stablecoin issuers and tokenisation platforms, want to bring their products to market. Regulators have to decide how to allow that without putting the public at risk. Many countries handle this with a regulatory sandbox: a supervised space where firms can test new products with real customers while a regulator watches closely and eases some of the usual rules. It works much like a test track, where a vehicle has to prove itself before it is allowed onto public roads.

Most major financial centres have now built a sandbox of their own, and the results vary widely. This report studies nine of the leading examples. For each one it explains, in clear and comparable language, how the regime works, what it gets right, and where it runs into trouble. From there it sets out a practical roadmap for building a regime to a high standard, written with emerging markets in mind and Nigeria in particular. The findings draw on more than 200 primary sources and on direct input from regulators and practitioners in these markets.

Who it's for
Regulators Policymakers Founders Investors

Written for anyone who needs to understand how these regimes really work and which lessons are worth copying. A report by BBO Think Tank.

Executive summary

What makes a sandbox actually work

By now almost every major centre accepts that some form of sandbox is worth running. The harder question is how to run it well. The regimes that succeed give firms genuine room to test products with customers, and they leave enough legislative headroom for those firms to grow once a test goes well. The ones that fall short often read well in policy papers yet still trap firms behind low caps, short time limits, and unsettled legal questions. This report works through that pattern across nine jurisdictions and draws out the choices an emerging market should borrow and the ones it should leave alone.

Most critical unresolved gaps

Where the regimes are breaking down

RANK 01

Sunset & cap limits

European Union

The EU's DLT Pilot caps activity at €10bn and shuts down after six years. Those limits stop it doing the very thing a sandbox is meant to do, which is help good firms grow. It needs revising soon.

Critical
RANK 02

Ambition outrunning delivery

Hong Kong · United Kingdom

Both countries rank high for political will but struggle to deliver in practice. Hong Kong needs a clear three-list model that sets out what is allowed, what is exempt, and what is banned. The UK's pre-licensing route still gives firms no real testing relief.

Critical
RANK 03

Confusing a licence path with relief

Cayman Islands · EU

Offering a route towards a licence is different from offering relief from one, and several regimes blur the two. Cayman needs to bring Part 3 of its VASP Act into force, and the EU needs to look beyond its sunset clause.

High
RANK 04

CARF alignment

Mauritius · Global

The January 2026 reporting deadline pulls smaller jurisdictions into the same scrutiny the EU applies under DAC8. Clear guidance for small VASPs has still not arrived.

Medium
Thematic severity matrix

How ten themes play out across nine jurisdictions

Each theme is mapped to the jurisdictions it affects most, and shaded by how serious the issue is. Select any cell to see what we recommend.

Select a cell Hover over or tap any cell to see the theme, the jurisdiction, and what we recommend.
Critical High Medium Resolved Global exposure
↔ scroll sideways to see every jurisdiction on smaller screens
Jurisdiction index

How the nine markets compare

J1 · GBCritical

United Kingdom

The UK runs a pre-licensing route rather than a true testing waiver, so firms get no real relief while they trial. How client assets are treated in insolvency is still unsettled.

J2 · EUCritical

European Union

MiCA has set the tone for crypto regulation worldwide, yet the DLT Pilot's cap and sunset clause hold it back from helping firms grow.

J3 · AELeading

Dubai (DIFC + VARA)

A dual-regulator setup, with the DFSA's Innovation Testing Licence alongside VARA's MVP pathway. It is one of the most operationally mature models in the study.

J4 · CHMedium

Switzerland

A well-built, tiered legal framework that the market has been slow to take up. Access to the EU is the main thing holding adoption back.

J5 · SGHigh

Singapore

Singapore is moving to a trust-first model under its DTSP regime. It raises the bar for quality, and it carries a real risk that some firms leave.

J6 · AUModerate

Australia

An exemption-based Enhanced Regulatory Sandbox now under review, with the Digital Asset Framework set to reshape its scope from 2026.

J7 · HKCritical

Hong Kong

Strong political backing for digital assets, held back by an execution gap that puts its status as a hub at risk. The regulator needs to move from gatekeeping towards actively supporting firms.

J8 · MUMedium

Mauritius

A framework still taking shape against a January 2026 CARF deadline. The legal structure is in place, though the supporting guidance has yet to be published.

J9 · KYHigh

Cayman Islands

A pre-licensing route that will only deliver genuine relief once Part 3 of the VASP Act is brought into force.

Full report

Read the full report

The full report adds the detailed legal analysis for each jurisdiction, the risk assessments and rankings, the complete thematic matrix, and the roadmap for Nigeria, with every source cited.

  • Section 1: combined legal summaries for each jurisdiction
  • Section 2: successes, failures, gaps, and a comparative ranking
  • Practical lessons for regulators in emerging markets
  • Full citations to legislation, regulator guidance, and data

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