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Vouchers, which are closely tied to daily consumer spending, whether in physical forms such as paper or magnetic cards, or in non-physical forms such as codes or passwords, are generally designed with prepayment and bearer-based redemption features. Holders may redeem the goods or services specified in the voucher at merchants designated in advance by the issuer, thereby fulfilling the agreed-upon exchange function between both parties. If the classification of vouchers is based on the specificity of the redeemable items and the timing of invoice issuance, reference may be made to Article 14 of the “Regulations Governing the Use of Uniform Invoices,” under which vouchers may be broadly categorized into “goods vouchers” and “cash vouchers,” as detailed below:

1. Goods Vouchers: These refer to vouchers that state in the remarks section that they may be used to redeem pre-specified goods or services. Examples include massage vouchers, accommodation vouchers, skincare or beauty treatment vouchers, meal vouchers, and hot spring vouchers. Issuers of such vouchers are required to issue a uniform invoice at the time of voucher sale in accordance with applicable regulations. No additional invoice is required at the time of redemption. However, gift cards issued by convenience store chains such as FamilyMart, or vouchers issued by mass merchandisers such as PX Mart or RT-Mart, although not limited to the exchange of specific types of goods and merely indicate a monetary value, shall still be categorized as goods vouchers.

2. Cash Vouchers: Cash vouchers specify only the monetary amount and do not indicate the quantities or specific types of goods. Holders of such vouchers may redeem goods of equivalent value either in full or in multiple transactions based on the face value indicated. For example, vouchers issued by major department store operators are typical examples of cash vouchers. In other words, the issuer shall issue a uniform invoice each time the voucher is redeemed, based on the amount used in that particular transaction. However, not all voucher-like certificates issued by department store operators are necessarily categorized as cash vouchers. These companies often issue a wide variety of certificates, such as purchase certificates or merchandise pickup slips, that bear only a monetary amount. Although these may appear to function like cash, they often do not allow for change to be given and do not require an invoice to be issued at the time of use, which aligns them more with goods vouchers in substance. Therefore, it is advisable to determine the nature of such certificates based on the terms and conditions stated on the back of the vouchers in order to minimize potential disputes.

As voucher issuers span across various industries and the designs of vouchers may vary significantly, to avoid consumer disputes, the government has previously consolidated the versions of vouchers issued by different industry categories into 19 broad categories, including retail, leisure, beauty and hairdressing, sports, telecommunications, tourism, and others. The competent authorities for each industry are responsible for overseeing the issuance of physical or electronic vouchers by businesses under their jurisdiction and in accordance with their regulatory scope.

Furthermore, given that goods vouchers are considered standard form contracts under the law, issuers shall comply with the mandatory and prohibited clauses for goods vouchers as announced by the Executive Yuan. Any restrictions imposed must fall within the scope permitted by law and shall not result in undue inconvenience to the user. Issuers are also required to adopt mechanisms in line with the aforementioned regulations, including performance guarantees, dispute resolution, and refund procedures, to protect consumers who have prepaid for such vouchers. If an issuer is found to be in violation of the relevant regulations and fails to make corrections within a specified period as ordered by the competent authority, it shall be subject to an administrative fine of not less than NT$30,000 and not more than NT$300,000 pursuant to Article 56-1 of the Consumer Protection Act. If the issuer fails again to make corrections within the subsequent period, it shall be subject to an administrative fine of not less than NT$50,000 and not more than NT$500,000, and may be fined on a per-instance basis thereafter.

Although the securities industry is not currently included among the business categories for goods voucher classification in Taiwan, some market-sensitive firms have already noted the commercial potential of such products. In fact, certain U.S. online platforms have introduced electronic vouchers in the form of gifts that can be redeemed for specific stocks or converted into investment amounts. The concept behind such marketing schemes is that they may serve not only as presents for holidays, anniversaries, or birthdays, but also offer added value through elements of creativity, surprise, financial investment education, and the potential for future appreciation. These products have thus gained popularity in a short period of time.

While some securities firms in Taiwan have launched similar promotional campaigns offering incentives for new account openings—such as physical gifts, convenience store vouchers, or trading credits—these activities, regardless of whether conditions of use are attached, differ in nature from commercial transactions involving payment for goods vouchers. As such, they have not been subject to the regulatory framework governing voucher issuance.

Accordingly, the Financial Supervisory Commission (FSC), the competent authority for the securities market, tends to view such account-opening incentives not as goods vouchers, but rather as marketing promotions aimed at business development. These may involve disseminating or promoting business-related information or activities to the general public through media, promotional tools, or other channels. In other words, such activities fall under the scope of the “Criteria Governing Internal Control Systems of Securities Firms (CA-18800).” Therefore, securities firms must comply with the “Regulations Governing the Advertisements and Solicitation or Promotional Activities Conducted by the Financial Services Enterprise” issued by the Securities Association, which set out standards for conduct, prohibitions against inappropriate practices, specific business rules, and the reporting of advertising materials. On this basis, securities firms should prepare the necessary documentation in advance and file it with the Securities Association accordingly.

In light of Taiwan’s rapid advancement in financial digitalization and the increasing diversification of financial products and services, SinoPac Securities Corporation, a comprehensive securities firm with paid-in capital exceeding NT$16.2 billion and 44 business locations, applied to the FSC in August 2024 for a pilot program to issue vouchers. Drawing on experiences from Korea and other foreign markets, the firm referred to this initiative as “Stock Gift Cards.”

The objective of this innovative program is to extend the commercial application of vouchers into the financial investment sector. By offering vouchers that may be redeemed for stocks or ETFs, it transforms what is traditionally perceived as rational and calculated investment behavior into a service experience with social and emotional value. Consumers who purchase “Stock Gift Cards” may use them as red envelopes during the Lunar New Year, gifts for birthdays or important holidays, employee incentives, or even prizes for year-end banquets. Furthermore, securities firms issuing “Stock Gift Cards” may leverage them to develop diversified marketing channels, attract demographics that are typically harder to reach, and provide the public with a more accessible and convenient means to participate in investment. This approach is expected to lower the age of new account holders and enhance the general level of investment participation.

According to the content provided by the aforementioned company in its proposal to the Financial Supervisory Commission (FSC) titled “Financial Technology Development and Innovative Experimentation Plan,” the total value of the voucher market in Taiwan is estimated to be approximately NT$40 billion. Among this, the penetration rate of digital vouchers has reached nearly 90 percent. With the acceleration of digital consumption in the post-pandemic era and the continued rise in the use of mobile devices and digital payments, the electronic voucher market has experienced rapid growth. As the application of goods vouchers becomes increasingly widespread, operating models must continue to evolve in response to changes in consumer habits, particularly under intense market competition. Based on the above, the pioneering extension of goods voucher applications into the financial investment sector presents an opportunity to cultivate a new business model characterized by the “giftification of stocks,” thereby embodying the spirit and essence of innovative experimental financial services.

Similar voucher-like products such as “stock gift cards” have already appeared in several international financial markets, including the United States, Australia, Hong Kong, and Korea. Notably, in Korea, the Financial Services Commission (FSC) designated the sale of “financial investment vouchers via online platforms” as an approved “Innovative Financial Service” under its regulatory sandbox program in October 2019. Starting in March 2020, the FSC authorized the first batch of four securities firms to issue such vouchers, allowing them to sell the products through e-commerce and social media platforms such as KakaoTalk and 11st. Following the conclusion of the sandbox period, and given that Korea’s financial regulatory system follows a negative-list approach, the competent authority in charge of securities ultimately ruled that these financial investment vouchers, due to their deposit-like nature, do not fall under the definition of financial investment instruments under the country’s Capital Market Act. Therefore, only the general regulations applicable to the issuance and sale of vouchers apply, and no additional financial regulatory restrictions were imposed.

During the 18-month trial period from March 2020 to September 2021, the four participating securities firms collectively sold financial investment vouchers with a total value of approximately NT$6.8 billion. Among them, Korea Investment & Securities (KIS), a leading firm in brokerage, asset management, investment banking, and proprietary trading, sold over 3.8 million vouchers. Reports indicate that about 70 percent of the actual users of these vouchers were young investors aged 20 to 30. In terms of business models, Korean securities firms have collaborated with e-commerce platforms and social media apps for sales and have also employed diverse promotional strategies such as account-opening gifts and prize draws to market the products across multiple channels. As for the investment targets available, although initially restricted to the purchase of domestic stocks only, they were later gradually expanded to include the purchase of foreign stocks, mutual funds, and repurchase agreements (RPs) involving bonds.

Based on the above, the “Stock Gift Card” program developed by SinoPac Securities Corporation represents an innovative model for funding securities investments. The company offers “Stock Gift Cards,” which are similar in nature to vouchers, for public sale via its official website. Through the online platform, customers can purchase electronic vouchers with varying face values and later choose to use them personally or transfer them to others. Holders of “Stock Gift Cards” may log in to the company’s electronic platform to convert the card’s face value into funds for securities market investments. The converted amount may be applied to settlement payments, handling fees, transaction taxes, and other related expenses. From this perspective, these electronic vouchers serve as an innovative funding mechanism built upon the company’s existing business framework.

Accordingly, pursuant to Article 4 of the Financial Technology Development and Innovative Experimentation Act and Article 2 of the Regulations Governing Financial Technology Innovative Experimentation, SinoPac Securities submitted its application for a trial program to the Financial Supervisory Commission (FSC) on September 13, 2024, under official letter No. 1130000004 issued by the Platform Development Department. Following the provision of practical recommendations by the Taiwan Stock Exchange Corporation (TWSE) regarding business structure, legal compliance, anti-money laundering and counter-terrorist financing, and anti-fraud measures, the FSC approved the trial program on February 27, 2025, under letter No. 1140190796. The FSC also instructed the company to submit promotional materials to the Securities Association for prior review and to exercise due diligence in selecting third-party service providers for outsourced operations to prevent personal data breaches. The company is required to submit quarterly progress reports, commence the program within three months from the date of approval, and report the official launch date within five business days thereafter.

After multiple submissions of advertising and promotional materials to the Securities Association, the company formally notified the FSC via letter No. 1140000004 issued by the Platform Development Department on March 20, 2025, stating that the Stock Gift Card business would officially launch on April 8, 2025, with the online sales platform going live at 8:15 a.m. on the same day. On May 14, 2025, the company held a press conference to publicly introduce the Stock Gift Card business and actively seek media exposure.

The issuance structure of the Stock Gift Cards offered by SinoPac Securities involves the signing of a prepayment trust agreement with a bank, acting as the trustee. The company deposits customers’ prepayments into a designated trust account, which is managed by the bank in accordance with the trust agreement, and the funds are strictly allocated for designated purposes. The Stock Gift Cards are issued in various denominations and are intended to be valid for the duration of the sandbox trial period. If the business is ultimately approved for formal launch, this time restriction will no longer apply. Given the advantages of digital vouchers over traditional paper-based ones, such as convenience, environmental friendliness, greater variety, ease of use, storage, and inquiry, SinoPac Securities has adopted an electronic format for the issuance and sale of its Stock Gift Cards. Customers may access their Stock Gift Cards at any time via mobile phones or other portable devices to make inquiries, make changes, transfer the card to others, or redeem it.

To fulfill the goal of promoting inclusive finance, the Stock Gift Card is sold directly to investors in the form of an electronic voucher through the company’s official website. To reduce the sense of unfamiliarity among first-time users and accommodate those who may be new to the investment market, the company’s online platform also provides detailed user guides for beginners. This initiative is intended to increase purchase incentives among the general public, expand market share based on the existing customer base, increase the number of new account openings, and provide investors with a more diversified and higher-quality financial management experience. To protect the interests of the investing public and prevent abuse of the product by individuals engaging in speculative activities, a purchase limit per customer has been imposed during the trial period.

For those wishing to purchase the electronic voucher via SinoPac Securities’ official website, the currently supported payment methods include Web ATM transfers and electronic payments linked to a bank account or digital wallet. In addition to limiting payment options for the Stock Gift Card, the company also requires purchasers to provide certain personal information in order to track the flow of funds and transaction records associated with the voucher. This data is processed and used solely for the specified purpose.

For individuals with little to no prior exposure to the stock market, the Stock Gift Card serves not only as an introductory tool for financial investment education but also helps new investors better understand the risks and nature of stock investments. It further enables early development of investment experience and lowers the threshold for market participation. After careful assessment by the Platform Development Department under the Digital Finance Division of SinoPac Securities, the company concluded that whether the purchaser uses the Stock Gift Card personally or gives it to friends, relatives, or employees, the mass promotion of this product will generate brand outreach and cumulative benefits. Through the interpersonal spread effect of gift-giving, the company expects to reach more potential clients and further enhance the overall accessibility and participation in financial investment across society.

According to the termination provisions announced by SinoPac Securities Corporation, during the sandbox trial period, returns due to personal reasons are permitted only for Stock Gift Cards that have not yet had their redemption codes used. Such returns must be processed in accordance with the company’s established return procedures. In line with the Mandatory Provisions to be Included in and Prohibitory Provisions of Standard Form Contract, when participants proactively request a return and the cancellation is approved, unless the reason is attributable to the company, SinoPac Securities reserves the right to deduct any purchase discounts from the face value and charge a handling fee of 3 percent (any amount below NT$1 shall be rounded up to NT$1; bank remittance charges shall be calculated separately). It is also important to note that the Stock Gift Card has a fixed redemption period. If the card is not successfully redeemed within the specified period, a full refund will be issued to the original purchaser.

Additionally, the sandbox trial includes redemption limits. During the trial period, each person’s redemption amount for Stock Gift Cards is capped at NT$250,000 per year. Redeemed vouchers may only be used for investment in the “SinoTrade Taiwan Stock” target and for covering related securities transaction expenses such as settlement payments, handling fees, and transaction taxes. To prevent malicious speculation or money laundering by certain individuals, once the Stock Gift Card amount is redeemed, it may not be freely withdrawn or transferred during the trial period. However, this restriction will no longer apply once a securities transaction is executed.

Once a cancellation and refund request is approved, the code representing the rights to the Stock Gift Card will be immediately deactivated and cannot be reinstated or reissued. Unless the cause is clearly attributable to the company, the Stock Gift Card, issued as a non-registered electronic voucher, is not eligible for refund, suspension, or reissuance in cases of theft, misuse, loss, or technical issues such as unreadable barcodes or card numbers due to mobile device malfunction.

To protect the rights of voucher holders and prevent losses in the event that the issuing company encounters financial mismanagement or insolvency before voucher redemption, a performance guarantee mechanism is generally established. In this regard, SinoPac Securities Corporation has designed a fund protection mechanism in cooperation with its affiliate, SinoPac Bank, by establishing a trust structure to safeguard prepaid funds and ensure consumer rights. To support the government’s anti-money laundering policies, purchasers are required to provide a minimal amount of personal information. This enables any refund, if necessary, to be returned directly through the original payment channel.

As for dispute resolution, Article 24 of the Financial Technology Development and Innovative Experimentation Act applies, under which the dispute resolution procedures of the Financial Consumer Protection Act shall apply mutatis mutandis. These include the right to file complaints, request mediation, and arbitration, which shall be handled by the relevant authorities and, if needed, with the assistance of professional personnel. The formation, interpretation, and enforcement of this service agreement shall be governed by the laws of the Republic of China (Taiwan). In the event of a dispute, participants may first contact the company’s customer service hotline or send an email to the designated customer service address. The company will respond to the complaint within three business days of receipt and follow up with further assistance as needed. If the participant’s complaint is not properly handled and responded to within 30 calendar days from the date of receipt, the participant may apply for mediation through the Taiwan Securities Association or the Financial Ombudsman Institution.

Based on a review of the “Stock Gift Card” program initiated by SinoPac Securities Corporation, the product is, in essence, an electronic voucher requiring login credentials and password authentication for use and which is settled through a deduction-based payment mechanism. By contrast, current mandatory and prohibitory provisions for standard form contracts concerning the issuance of vouchers in Taiwan are primarily limited to industries such as retail, intercity bus transportation, hotels, tourism, telecommunications, food and beverage, parking, and sports venues. These industries are already governed by specific contract terms. However, the securities industry is not yet included in this regulatory scope, and in practice, there are no precedents of securities firms issuing vouchers directly or through third-party agents.

Under civil law, gift vouchers are generally regarded as bearer securities governed by Article 719 of the Civil Code, meaning that a contractual relationship is established between the buyer and seller based on standard form contract terms. Accordingly, regardless of whether the holder of a Stock Gift Card acquires it through original purchase or subsequent transfer, the act of entering the redemption code on the issuing securities firm’s trading platform may be interpreted as the creditor’s demand for the debtor (the securities firm) to fulfill its contractual obligation. In terms of fund flow, the Stock Gift Card represents prepaid funds that, upon successful online verification of the voucher code, are indirectly converted into settlement payments for securities transactions. These funds are not directly deposited by the investor into the settlement account.

Therefore, when the holder redeems the face value of the Stock Gift Card, and the securities firm subsequently offsets the equivalent amount against the settlement amount owed by the investor rather than transferring funds directly into the investor’s account, this structure may raise questions regarding the nature of the fund flow. However, according to SinoPac Securities’ explanation, the firm does not remit the funds directly to the investor. Instead, the equivalent amount is used to reduce the investor’s settlement obligations. In other words, the investor is only required to pay the remaining balance after deducting the value of the Stock Gift Card from the total settlement amount. The firm asserts that there is no transfer of funds to the investor’s account, and therefore no actual act of depositing funds on behalf of the investor.

In light of this, if the company’s explanation holds, the fund flow arrangement could be interpreted as mutual obligations between the investor and the securities firm arising from two separate acts, “redemption of the Stock Gift Card” and “execution of a securities transaction.” Since both obligations are monetary and due, they may be offset against each other in accordance with Article 334 of the Civil Code regarding set-off of obligations. Furthermore, the investor’s act of entering the code and redeeming the Stock Gift Card may be viewed as an expression of intent to set off, in accordance with Article 335 of the Civil Code. The respective obligations between the two parties would thus be extinguished to the extent of the offset amount.

Moreover, given that the issuance of vouchers inherently involves fundraising and credit expansion, and that there is currently no precedent in the securities industry, even if the Stock Gift Card is approved for pilot testing, it would be appropriate, with reference to the legislative intent of Article 17 of the Consumer Protection Act, to formulate dedicated Mandatory Provisions to be Included in and Prohibitory Provisions of Standard Form Contract. This would help prevent consumer disputes, safeguard consumer rights, and promote fairness in standard contract practices.

Pursuant to Article 17 of the Consumer Protection Act, the central competent authority may, for the purpose of preventing consumer disputes, protecting consumer rights, and promoting fairness in standard form contracts, designate specific industries and formulate the mandatory and prohibitory provisions of their standard form contracts. Such provisions shall be submitted to the Executive Yuan for approval and promulgation. Any standard form contract that violates the aforementioned promulgated provisions shall be deemed invalid with respect to those non-compliant clauses. Moreover, the mandatory provisions publicly announced by the central competent authority shall form part of the contract even if not explicitly included in the contract text.

With reference to the Mandatory and Prohibitory Provisions of the Standard Form Contract for Retail Online Trading as announced by the Executive Yuan, important items that must be included in the standard form contract for products such as the Stock Gift Card include the following 14 categories: business operator information, principles of contract interpretation, product information, use of electronic documents as a method of expression, confirmation mechanism and contract performance, maximum quantity limit per product order, delivery location and method, description of payment methods, shipping fees, right to return and cancel the contract, personal data protection, handling of unauthorized use of accounts or passwords, system security, and consumer dispute resolution.

As for the prohibited provisions that may not be included in similar standard form contracts for online trading under the law, these include eight categories: restriction on the exercise of personal data rights, use of personal data beyond the stated purpose, unilateral modification of the contract, exemption from liability for contract termination and damages, restriction on the consumer’s right to terminate or rescind the contract, advertising disclaimers, exclusion of evidence, and designation of jurisdiction.

In addition, according to the Banking Bureau, Mandatory and Prohibitory Provisions of Standard Form Contract for the Business of Electronic Payment Institutions that provide services to assist with the issuance of merchandise (service) vouchers. Therefore, in the event of a full-scale launch of the Stock Gift Card business, in addition to the above-mentioned standards applicable to online trading in the retail sector, reference may also be made to the provisions set by the Banking Bureau. These may serve as the basis for formulating more tailored and practical supporting regulations to ensure alignment with the overall legal framework. A comparison table of the legally required and prohibited clauses specified respectively by the competent authorities for online retail transactions and electronic payment institution operations is provided below.

The Financial Technology Innovative Experimentation mechanism, established by the Financial Supervisory Commission, provides a risk-controlled environment to encourage business innovation. It enables enterprises to test business models involving emerging technologies or services, and the Stock Gift Card is positioned as one such new form of financial service. Pursuant to the Financial Technology Development and Innovative Experimentation Act, applicants are required to specify the scope, duration, and scale of the experimentation, as well as the exit mechanism should the experiment be terminated early or upon expiration. For the Stock Gift Card, the trial period is set at one year. In the event of an extension or early termination of the experiment, participants must be notified at least 30 days prior to the effective date of change through public announcements on the website, phone calls, text messages, or emails, along with instructions on the corresponding handling procedures.

According to the Ministry of Economic Affairs letter Jing-Shang-Zi No. 09500183370 dated December 4, 2006, and its prescribed “Mandatory Provisions to be Included in and Prohibitory Provisions of Standard Form Contracts for all sorts of gift certificates”, the Stock Gift Card qualifies as a voucher under this definition. In other words, SinoPac Securities Corporation issues certificates of a specified monetary value, which holders may redeem by verifying the serial number and password, thereby requesting the issuer to apply the equivalent amount of the Stock Gift Card toward the purchase price of stocks. Upon successful redemption by entering the voucher code into the company’s electronic trading platform, the face value of the Stock Gift Card is converted into available investment funds in the investor’s securities account, which may be used for investment in the "Taiwan Stock in Sino Trading" product. However, in accordance with Article 4, Item 25 of the Regulations Governing the Use of Uniform Invoices, securities firms are exempt from the requirement of issuing uniform invoices. Therefore, the issuance and redemption of the Stock Gift Card are not subject to invoice requirements. As the card functions as a cash equivalent, any unauthorized acts such as forgery, alteration, reproduction, tampering, or photocopying may constitute criminal offenses and must be strictly avoided.

In reviewing the product design structure of the Stock Gift Card, it is evident that the ultimate holder, in order to exercise the rights represented by the card, must first complete the account opening process and become a registered customer before being permitted to log in to the official website and convert the card for personal use under their real name. Conversely, if the holder is not yet a customer of the company, they will be guided through the steps necessary to open an account. Accordingly, this also constitutes, without question, a form of business solicitation or promotional activity directed at the general public for the purpose of business development and related matters.

Judging from the original intent behind SinoPac Securities Corporation’s launch of the Stock Gift Card, the aim appears to be to reach specific groups that previously had little or no investment demand. According to the company’s internal research, approximately 80 percent of the population in Taiwan still lacks or has yet to develop financial investment needs. To attract such demographics into the securities investment ecosystem, the company has sought to leverage the traditional cultural practice of gift-giving as a gateway, integrating the concept of electronic vouchers with long-term stock investment strategies. This approach taps into the vast domestic gift voucher market while simultaneously expanding the company’s customer base. The result is the conception of a value-added gift product that reflects changing consumer behaviors, especially among Generation Z, who expect more from financial products than just returns. They also value a sense of participation and enjoyment. It is this emotional connection that allows the Stock Gift Card, when paired with a stable stock accumulation strategy, to transform stocks from a purely rational financial instrument into something more relatable and engaging.

That said, the product remains in the sandbox trial phase, with a total issuance cap currently limited to NT$100 million. Even if the cap is conditionally increased to NT$200 million upon regulatory approval, it will still be considered a small-scale offering. Accordingly, the company is limiting public purchases to online channels, with purchase limits already in place as previously described. The experiment targets a participant base of 35,000 to 50,000 individuals. After completion of the sandbox trial, the company also intends to promote collaboration with listed companies, envisioning the Stock Gift Card as a potential option for year-end bonuses or shareholder meeting gifts. Future plans include cross-sector cooperation, such as partnering with e-commerce platforms, to introduce more innovative services and financial products. These efforts aim to expand the stock investment ecosystem and contribute to the advancement of inclusive finance in Taiwan.