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RegulationJan 8, 202610 min read

Regulatory Convergence: How ASEAN is Building a Unified Digital Asset Framework

An analysis of cross-border regulatory developments shaping institutional adoption and the path toward harmonized standards.

ZT

Zachariah Tembo

Head of Tokenization

The Convergence Imperative

ASEAN's digital asset regulatory landscape has historically been characterized by fragmentation. Each member state developed frameworks independently, creating complexity for cross-border operations and limiting regional market development.

This is changing. Regulatory bodies across the region are increasingly coordinating on digital asset standards, recognizing that harmonization benefits all participants.

Current State of Play

Singapore

The Monetary Authority of Singapore (MAS) has established the most comprehensive framework in the region through the Payment Services Act and Securities and Futures Act. Recent updates have clarified treatment of stablecoins and DeFi protocols.

Thailand

The SEC Thailand has developed a robust security token framework, with several successful offerings completed. Recent amendments have expanded permissible token structures.

Indonesia

OJK (Financial Services Authority) is finalizing comprehensive digital asset regulations expected in 2026. The framework will cover both utility and security tokens with clear licensing requirements.

Malaysia

The Securities Commission Malaysia has licensed several digital asset exchanges and is developing guidelines for tokenized securities.

Philippines

The BSP and SEC are collaborating on a unified approach that will cover both payment tokens and security tokens under a single framework.

Convergence Mechanisms

Several mechanisms are driving regulatory convergence:

ASEAN Working Groups

Formal working groups on financial technology include digital asset standardization as a key agenda item. Regular meetings facilitate knowledge sharing and coordination.

MOU Networks

Bilateral MOUs between regulators enable information sharing and coordinated supervision of cross-border activities.

Industry Advocacy

Regional industry associations are advocating for harmonized standards, providing regulators with practical insights on operational requirements.

Implications for Institutions

Regulatory convergence has several implications for institutional participants:

Simplified Compliance

Harmonized standards will reduce the compliance burden for regional operations, enabling more efficient deployment of resources.

Market Expansion

Mutual recognition frameworks will enable products structured in one jurisdiction to be offered across the region, expanding addressable markets.

Operational Efficiency

Standardized requirements for custody, reporting, and settlement will enable development of regional infrastructure rather than jurisdiction-specific solutions.

Timeline and Expectations

Based on current trajectories, we expect:

2026: Indonesia finalizes comprehensive framework; Thailand and Singapore announce mutual recognition for certain token categories 2027: ASEAN-wide guidelines for security tokens published; regional sandbox for cross-border offerings launched 2028: Full mutual recognition framework operational for compliant offerings

Strategic Positioning

Institutions should position now to capture the benefits of convergence:

1. Establish regional compliance capabilities that can adapt to harmonized standards

2. Build relationships with regulators across multiple jurisdictions

3. Develop flexible product structures that can accommodate varying requirements during transition


For guidance on navigating ASEAN digital asset regulations, contact enquiries@leadwood.consulting.

Interested in Learning More?

Our team is ready to discuss how these insights apply to your specific context and objectives.