1. What is the current legal landscape for your practice area in your jurisdiction?

The legal landscape for fintech in Malaysia in 2026–2027 is, without doubt, undergoing an unprecedented sea change that may well catch many off guard, both in terms of what is already unfolding and what is yet to come.

The signs are now more visible than ever that from the initial release by the Securities Commission (“SC”) of its public consultation on tokenised capital market products under the Public Consultation Paper: Proposed Regulatory Framework for Offering and Dealing in Tokenised Capital Market Products; to the establishment of the inaugural SC Regulatory Sandbox; alongside the release by Bank Negara Malaysia (“BNM”) of its Discussion Paper on Asset Tokenisation in the Malaysian Financial Sector; and the establishment of the Digital Asset Innovation Hub (“DAIH”), which is now closely examining tokenised money, including stablecoins and tokenised deposits. This has been further reinforced by the SC’s release of the Practice Note permitting the offering of Broking Services for Digital Assets and, most recently, Bursa Malaysia’s issuance of Consultation Paper No. 1/2026, titled Proposed Amendments to the Main Market Listing Requirements and the Directives of Bursa Malaysia Securities Berhad to Facilitate the Listing and Trading of Digital Currency Exchange-Traded Funds, pursuant to which Bursa Malaysia is proposing amendments to facilitate the listing and trading of digital currency exchange-traded funds, or digital currency ETFs. Taken together, these developments point, quite unmistakably, towards the next wave of institutional and regulatory adoption of digital assets in Malaysia.

It is also beyond serious doubt that, within Malaysia, many financial institutions and market participants are now seeking to position themselves to participate in, and capture, the broader opportunities emerging across the fintech landscape. Broadly speaking, this movement may be understood across three principal legal categories or layers within the wider fintech landscape.

The first is the use of digital assets for payment purposes, whether through stablecoins, tokenised deposits, or central bank digital currencies, each of which presents its own distinct regulatory and operational challenges, as well as broader policy concerns. These developments will inevitably require wider infrastructure support, whether in relation to the maintenance of blockchain networks, the issuance layer, or the provision of the necessary rails and systems to enable such instruments to be used meaningfully for payments in the future.

The second layer is the tokenisation of real-world assets or, more immediately and specifically, capital market products. This is potentially a very broad space, spanning a wide range of instruments, including bonds, sukuk, fund interests, structured products, and other securities. In many respects, this mirrors, and is intended to keep pace with, the wider global movement towards the tokenisation of securities and capital market products, which may in due course allow for greater liquidity, broader market access, and more efficient participation by the wider investing public.

The third layer is the broader tokenisation economy itself, which requires more traditional fintech players, such as those operating in merchant acquiring, remittance, payment systems, payment gateways, custody, and related infrastructure, to prepare themselves for a market in which digital assets and crypto may increasingly be incorporated into payment flows and the wider tokenisation of capital market products. While these traditional fintech players already possess the network, scale, and operational maturity, the adoption of blockchain-based models may still be somewhat unfamiliar territory, bringing with it a different set of operational, legal, and regulatory issues that will need to be navigated with care.

With that, it is becoming increasingly clear that, across 2026–2027, the Malaysian market is moving towards a broader and more mature tokenised economy, with fintech players across the ecosystem positioning themselves accordingly at different layers of the value chain in anticipation of what is to come. Whether at the level of payment infrastructure, tokenised money, capital market product tokenisation, custody, remittance, merchant acquiring, or wider supporting rails, the direction of travel is now difficult to ignore because what is emerging is not merely a passing trend, but the early architecture of a more deeply integrated digital asset and tokenisation economy.

The key challenge, however, is that as the market evolves, the legal and regulatory landscape is evolving alongside it. Regulators in Malaysia, whether BNM, the SC, or even the Labuan Financial Services Authority, are themselves learning, adapting, and responding to these developments in real time, while relevant regulations, legal frameworks, and guidelines continue to be introduced, refined, and passed. That is precisely why this is perhaps the most crucial moment to pay close attention and become properly familiar with these national and global developments, including the legal landscape, which is now moving at considerable speed.

2. What three essential pieces of advice would you give to clients involved in your practice area matters?

If one were to narrow this down to only three pieces of practical advice, the first would be this: remain flexible and open-minded about what is coming. Much of what is now emerging, whether tokenised money, stablecoins, tokenised deposits, CBDCs, or blockchain-based financial infrastructure, can appear highly technical and, at times, overwhelming, particularly when these developments must also be understood through a regulatory and compliance lens. Yet this is precisely the nature of structural shifts in financial markets that once momentum builds, developments tend to arrive not in isolation, but all at once. In that environment, institutional rigidity can quickly become a disadvantage, therefore, the most prudent course is to remain commercially alert and operationally adaptable.

The second would be to keep learning and to remain vigilant as to what is coming next. The evolution of AI itself offers a useful illustration that the market has moved from traditional machine learning to generative AI, and is now increasingly turning its attention towards agentic AI, where systems are capable of acting with a greater degree of autonomy. That shift is not merely theoretical, as companies are already exploring how autonomous AI agents may, in time, initiate or execute payments and transactions, whether through stablecoins or other forms of payment instruments. If more widely adopted, this will inevitably give rise to an entirely new set of operational, legal, governance, and regulatory questions. Questions of authorisation, liability, control, fraud, consumer protection, systems integrity, and regulatory attribution will not be far behind. The important point is that, while many institutions are still learning, the market itself is not standing still, as it will continue to move, experiment, and push at the boundaries. It is precisely for this reason that the second advice is to remain ever vigilant and, at the same time, to prepare thoughtfully and deliberately by recognising that each new wave of technological innovation will introduce a corresponding set of novel legal issues, and to be ready to address the legal implications as they arise.

The third would be to work with local counsel that genuinely understands the fintech landscape. In a market that is moving this quickly, the choice of legal adviser matters greatly. When the legal issues are novel, when the regulations are still evolving, and when market practices are still being formed, experience in conventional areas alone may not be sufficient. The right counsel is not simply one that can interpret legal texts in the abstract, but one that is already close to the market, familiar with the underlying technologies, and actively preparing for where the industry is heading from the wider legal landscape.

3. What are the greatest threats and opportunities in your practice area law in the next 12 months?

The greatest threat and opportunity, in many respects, are one and the same, a double-edged sword arising from the rapidly evolving fintech landscape. It is no secret that much of the legal profession has yet to develop a deep familiarity with blockchain technologies and the broader tokenisation economy. The learning curve is not only steep, but also demands more than a study of the law, as it requires a fundamental understanding of the underlying technology, which can be both time-consuming and intellectually demanding.

This, in itself, presents a clear challenge. Keeping pace requires sustained effort, continuous learning, and a willingness to engage with developments that are still in motion. Yet, it is precisely this dynamic that creates the opportunity. Those who remain close to the market, who invest the time to understand both the technology and its legal implications, and who operate at the forefront of these developments, will be distinctly positioned to guide businesses with clarity and confidence. In that sense, the very complexity of the landscape becomes the point of differentiation for fintech lawyers in the years ahead.

4. How do you ensure high client satisfaction levels are maintained by your practice?

Client expectations have evolved meaningfully. Increasingly, clients are not simply seeking discrete legal advice, but are looking to their lawyers as trusted advisers, somewhat closer in role to management consultants who can engage with the broader corporate strategy and help navigate what lies ahead. Therefore, in a fast-moving fintech environment, familiarity with the market is as important as technical legal proficiency, and maintaining high levels of client satisfaction requires a more integrated approach.

Fintech lawyers must now understand the commercial realities of the business, appreciate the strategic objectives of the client, and position themselves as genuine partners in shaping the next phase of growth. It is this ability to combine legal insight with commercial judgement that ultimately underpins a more enduring and meaningful client relationship.

5. What technological advancements are reshaping your practice area law and how can clients benefit from them?

The most significant technological advancement reshaping the practice is, without doubt, artificial intelligence. It is not that AI will replace lawyers or law firms, but rather, it is increasingly enabling lawyers to operate with greater precision, speed, and efficiency. For clients, the benefits are both immediate and tangible, as legal advice can be delivered more quickly, with sharper analysis and, in many cases, at a more accessible cost. In that sense, AI allows clients to obtain not only faster outcomes, but also greater overall value. Law firms that embrace AI with care and deliberation will, in time, distinguish themselves from those that do not, both in the quality of their work and in the experience they offer to clients.