A Comparative Analysis of Fintech Cybersecurity Governance in Singapore and Indonesia: Regulatory Effectiveness, Risk Exposure, and Policy Implications

Abstract

This study compares fintech cybersecurity governance in Singapore and Indonesia, focusing on regulatory effectiveness, risk exposure, and policy implications. A systematic literature review was conducted using data from 2018 to 2024, sourced from Scopus, Web of Science, Google Scholar, and official reports issued by financial regulators, including the Monetary Authority of Singapore (MAS) and the Financial Services Authority of Indonesia (OJK). An inductive thematic analysis was applied to synthesise findings from 52 eligible documents. The results show that Singapore demonstrates stronger regulatory coherence, mandatory technology risk management (TRM) frameworks, and a higher level of digital literacy, contributing to lower cybersecurity risk exposure across the fintech ecosystem. In contrast, Indonesia faces recurring challenges, including inconsistent data protection enforcement, limited consumer awareness, and uneven technological infrastructure. The study highlights that the regulatory gap and governance maturity significantly influence national fintech resilience. The paper contributes to the literature by integrating a cross-country perspective on fintech cybersecurity governance and by proposing policy recommendations for emerging markets, particularly the need for unified data protection enforcement, capacity building, and enhanced public awareness.