数据无国界：协调东盟数字法规促进增长

Table of Contents Chapter 1Setting the Stage: Data Is theLifeblood of ASEAN’s DigitalEconomy06 Chapter 2The Growing Roadblock: How Cross-Border Data RestrictionsAre Holding ASEAN Back12 Chapter 3 The Consequences: MissedOpportunities for ASEAN’sGrowth and Innovation17 Chapter 4 21 The Role of DEFAin Enabling DataConnectivity Chapter 5The Path Forward: AProactive Approach to DataConnectivity25 Data Without Borders: HarmonisingASEAN’s Digital Regulations for Growth ASEAN’s digital economy is growing rapidly. Fintech, e-commerce, and real-time payments arethriving across the region, fuelled by a young, mobile-first population. In 2022, digital paymentsin the six largest ASEAN economies exceeded USD 806 billion. But behind this growth lies asimple truth: data powers everything. Every digital transaction, customer interaction, and financial service relies on the secure andseamless movement of data. Today, however, businesses are facing growing friction. Cross-border data restrictions and inconsistent national regulations are making it harder to innovate,expand, and stay competitive. To understand how companies are navigating this evolving landscape, the Singapore FintechAssociation surveyed 109 organisations across ASEAN. The message from the private sector isclear: fragmented data rules are undermining both compliance and growth. $806B Digital payments in 2022 73% of respondentssaid that cross-border data transferrestrictions couldlimit their access toessential global techtools, and expecttheir operationalcosts to increaseand productivity todecrease due tosuch rules. 109organisationssurveyed 73% of respondentsexpect stringentdata transfer rulesto impact costand productivity. 70% 61% of respondentsexpect revenuesto be negativelyimpacted due tostringent data transferrules. of respondentsreported that theserestrictions would negativelyimpact their ability to enternew markets. singaporefintech.org Executive Summary 73% of respondents reported that these restrictions would negatively impacttheir ability to operate in a market which introduces such restrictions,with significant negative impacts on crucial operational activities: Customer support There are also implications on the use of innovative AI technologies. of respondents said that these restrictions would have a negativeimpact on their creation and use of Gen-AI. 58% A majority of respondents (58%) disagreed that data localisationimproved data security. Despite these challenges, businesses remain committed to responsible data practices.What they want is consistency. A majority of respondents believe that a regionalframework, such as a robust ASEAN Digital Economy Framework Agreement (DEFA),would be transformative. They are calling for clear, harmonised rules that allow trusteddata to move securely across borders. This report outlines a practical path forward: finalise a high-standard DEFA, alignnational privacy laws, and limit data localisation to clearly justified cases. It also calls forgreater promotion and use of tools and mechanisms like the ASEAN Model ContractualClauses and the Global Cross Border Privacy Rules System, alongside support forinnovation through regulatory sandboxes and modern data-sharing models. Above all,it urges ASEAN to work together, with urgency and clarity, to build a more connected,competitive digital future. ASEAN has the opportunity to lead. With the right approach, data can shift from beinga barrier to becoming one of the region’s greatest competitive advantages. Theopportunity is here. The time to act is now. Acknowledgements This report was produced by the Singapore Fintech Association (SFA)as part of its ongoing efforts to advance digital policy dialogue andpromote trusted data connectivity across ASEAN. The initiative wassupported by regional stakeholders committed to strengthening theregion’s digital economy through greater regulatory harmonisation andindustry collaboration. SFA would like to thank Derek Ho, Assistant General Counsel, Privacyand Data Protection, Mastercard, whose guidance was instrumentalin shaping the direction of this report. We are also grateful to ValerieTan, Jason Puah, and Doug Campbell Pitt for their contributions to theresearch and drafting process. We also thank the national banking associations of the ASEAN BankersAssociation, and in particular Paul Gwee, Secretary General, for theirsupport and collaboration. Their involvement helped ensure strongregional representation and relevance across the financial sector. We further acknowledge the support of SFA’s partner associationsacross the region, whose participation helped amplify outreachand engagement, and whose insights helped to ensure this reportreflects the realities and perspectives of a broad spectrum of industrystakeholders. The 109 fintechs and financial institutions that responded to the regionalsurvey provided invaluable, ground-level insights into how cross-borderdata regulations are affecting b