As India prepares to tighten regulation on cryptocurrencies, Southeast Asia is evolving into a patchwork of policy innovation, incubators of innovation, and cautionary examples. As India is trying to bring its crypto regulation in sync with international anti-money laundering (AML) norms, its Southeast Asian neighbors are going down other paths of regulation — from hardline suppression to visionary national digital asset policy.
And how's India's current regulatory strategy faring compared to Singapore's, Thailand's, Indonesia's, and the Philippines'? And what can regional policymakers learn? Here is a comprehensive side-by-side comparison of how Asia's top economies are addressing the next era of digital assets — and how India is faring.
India moved from ambiguity to official regulation in 2022 for the crypto sector. India does not have a standalone law in the shape of a "Crypto Act," but it has witnessed a series of regulations to regulate virtual digital assets (VDAs):
30% flat tax on cryptocurrency profits (applicable from April 2022)
1% TDS on all crypto transactions over ₹10,000
Virtual digital assets fall under Prevention of Money Laundering Act (PMLA)
Users are required to go through KYC and the platforms must register with FIU
Even though these regulations have cut speculative trading volumes by more than 60%, as reported by CoinDCX and WazirX, they have also resulted in a large-scale migration of Indian users to offshore exchanges and DeFi platforms.
Indian strategy is traditional and risk-averse, but according to experts, there is no law that dissuades innovation and drives away genuine Web3 firms
Singapore: Leader in Regulatory Sophistication and Licensing Tightness
Singapore, or Asia's "crypto haven," is probably the leader in regulatory innovation. The Monetary Authority of Singapore (MAS) promulgated the Payment Services Act in 2019, wherein all digital payment token service providers are licensed and have AML/CFT obligations.
MAS is risk-based — enabling blockchain innovation but demanding strong consumer protection regulations. In 2023, it banned crypto advertising to the public in the interest of risk to financial stability. It also mandates segregation of client assets by firms and prohibits lending of retail holdings of crypto.
While India's hardline high-tax policy has scared away crypto exchanges, Web3 companies, and venture capitalists, Singapore has a more relatively balanced cryptocurrency profit tax system. This attracted crypto exchanges, Web3 companies, and venture capitalists.
Thailand: Regulatory U-Turns and Mixed Signals
The Thailand and crypto history is one of regulation turnarounds. Crypto exchanges and ICO sites were legalized by the Thai SEC in 2021, a more enticing offer to accept. But with the Terra-Luna crash and additional fraud claims surfacing, the government hardened controls once again in 2022-2023.
Prohibited crypto as a payment method
Mandated express investor warnings and risk disclaimers
Imposed stricter reserve requirements on digital asset companies
The SEC and central bank of Thailand, however, had lines of communication with market players. The government also tested a retail CBDC pilot in 2023, whereas India launched the e-rupee half-way. Thailand is attempting to tread a middle path — promoting the use of blockchain while tightening on speculation- and consumer-risk-based platforms.
Indonesia turned unexpectedly crypto-friendly even though it is the world's largest Muslim-majority nation with a culture of conservatism with finances. Crypto is being regarded as a commodity rather than a currency by the Commodity Futures Trading Regulatory Agency (BAPPEBTI), with equity trading being done under licensed platforms.
As of 2023:
Legally licensed more than 30 crypto exchanges
Nearly 17 million Indonesians are account holders who use crypto as registered users
The nation opened a national crypto exchange in July 2023
Indonesia also launched Zakat-compliant tokens and sharia-compliant crypto education, demonstrating the balance between regulation and cultural context. While India is concentrating on taxation and enforcement, Indonesia is developing local infrastructure for safe access to digital assets.
Bangko Sentral ng Pilipinas (BSP) was the first Asian regulator to release crypto guidelines back in 2017. Its guidelines are for digital assets to promote remittances and financial inclusion — an industry of highest priority in a country where more than 40% of adults don't have a bank account.
VASPs will be licensed
Less heavy-handed, open-armed taxation than India's crypto regime
Has a fintech and blockchain pilot regulatory sandbox
The Philippines is also collaborating with the Asian Development Bank to pilot blockchain-based identity platforms. It puts crypto not only as an instrument for speculation, but as a gateway to economic empowerment — something India's Digital India program could learn from.