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Title page 1

Contents 6

Foreword 4

Acknowledgements 5

Abbreviations and acronyms 11

Executive Summary 13

1. Trade, digitalisation and ASEAN 17

1.1. Trade in the digital era 18

1.2. Digital trade is at the centre of ASEAN's initiatives 19

1.3. AMS show a strong potential to draw benefits from digital trade 22

1.3.1. Important progress has been made in connecting people to the Internet 22

1.3.2. Trade accounts for an important share of ASEAN economic activity 23

1.4. Digital trade is increasingly important for ASEAN economies 30

1.4.1. Digitally deliverable services drive growth of ASEAN digital trade 34

1.4.2. ASEAN is the second largest exporter of ICT goods 36

1.4.3. AMS rely strongly on foreign markets for their digital inputs 37

1.5. Findings and recommendations 41

Annex 1.A. Supporting figures and tables 42

References 45

Notes 46

2. Reforming the domestic regulatory environment affecting digital trade 47

2.1. Domestic regulatory bottlenecks constrain ASEAN's digital trade performance 48

2.1.1. Digital trade restrictiveness varies significantly across policy areas and AMS 49

2.1.2. Digital network services also remain highly restricted, particularly in telecommunications 56

2.2. Creating an enabling environment for digitally ordered goods 60

2.2.1. ASEAN's going paperless efforts are underway 61

2.2.2. Addressing trade facilitation challenges 62

2.2.3. Beyond the border: lowering barriers on services, supporting digitally ordered goods 64

2.3. ICT and related products continue to face tariff and non-tariff measures in many AMS 67

2.3.1. Reducing tariffs on ICT and related goods would significantly increase cost-efficient access to foreign markets 68

2.3.2. ICT and related products are subject to a high number of non-tariff measures in some AMS 73

2.4. Findings and recommendations 75

Annex 2.A. Supporting figures and tables 77

Partial-equilibrium simulation of joining the WTO Information Technology Agreement and its expansion 85

References 89

Notes 92

3. Maximising the benefits of cross-border data flow regulation 97

3.1. Data flows are critical for modern day economic and social interactions 99

3.2. Cross-border data flow regulation takes various forms 100

3.2.1. Domestic regulations addressing cross-border data flows vary greatly across AMS 100

3.2.2. Cross-border data flow provisions in trade agreements can facilitate data flows with trust 103

3.2.3. Inter-governmental arrangements also enable cross-border data transfers 106

3.3. Data localisation measures are growing and becoming more restrictive in ASEAN 106

3.4. AMS need to continue the process of reforms to promote a balanced approach to cross-border data flows 110

3.5. Findings and recommendations 111

Annex 3.A. Supporting figures and tables 112

References 113

Notes 115

4. Deepening and broadening digital trade integration from DEFA to the WTO 119

4.1. International co-operation can help facilitate digital trade 121

4.2. International commitments on digital trade issues are growing fast in ASEAN 122

4.3. DEFA: The deeper the better 123

4.3.1. Moving towards an extensive DEFA 124

4.3.2. DEFA has the potential to increase ASEAN regional trade by 13-20% 128

4.4. The WTO Agreement on E-commerce: broadening digital trade integration 131

4.4.1. The WTO AoE would extend digital trade integration outside the region 131

4.4.2. The WTO AoE has the potential to increase ASEAN trade 133

4.5. The importance of the WTO e-commerce Moratorium 134

4.5.1. What is WTO e-commerce Moratorium? 134

4.5.2. Potential revenue implications for AMS are small 135

4.5.3. AMS should support the reinstatement of the WTO e-commerce Moratorium 136

4.6. Findings and recommendations 136

References 137

Notes 138

5. Transitioning ASEAN towards the AI era 139

5.1. ASEAN has understood the importance of AI 140

5.2. AMS are at different stages of AI adoption 141

5.3. Market openness is critical for ASEAN to harness AI's potential 143

5.3.1. Domestic AI policy frameworks vary considerably across AMS 144

5.3.2. Tariff-barriers on AI enabling goods remain high in some AMS 147

5.3.3. Services enable access to AI technologies 148

5.3.4. Skilled workers 149

5.3.5. Data governance 150

5.3.6. International co-operation 151

5.4. Findings and recommendations 152

Annex 5.A. Supporting figures and tables 153

References 154

Notes 157

Annex A. Country pages 158

Brunei Darussalam 158

Cambodia 159

Indonesia 160

Lao PDR 161

Malaysia 162

Myanmar 163

The Philippines 164

Singapore 165

Thailand 166

Viet Nam 167

Tables 9

Table 1.1. Viet Nam, Singapore, and Malaysia represent the largest ASEAN Member States in merchandise trade 25

Table 1.2. Singapore represents more than half of ASEAN services trade 27

Table 1.3. Participation in digital trade is uneven in ASEAN 33

Table 1.4. Main findings and recommendations related to Chapter 1 41

Table 2.1. Recommendations for improving trade facilitation related to automation and border agency co-operation 64

Table 2.2. AMS' membership in ITA and its expansion, as of November 2025 72

Table 2.3. Main findings and recommendations related to Chapter 2 76

Table 3.1. Major legal instruments affecting the cross-border flow of data in ASEAN Member States 101

Table 3.2. ASEAN Member States' Regional Trade Agreements (RTAs) with cross-border data flow provisions 105

Table 3.3. Main findings and recommendations related to Chapter 3 111

Table 4.1. INDIGO scores for different permutations of DEFA 125

Table 4.2. Overview of "Stabilised text" of WTO Agreement on E-commerce 132

Table 4.3. Potential impact of the WTO e-commerce Moratorium on ASEAN Member States 135

Table 4.4. Main findings and recommendations related to Chapter 4 136

Table 5.1. Singapore is the only ASEAN Member State that has signed Regional Trade Agreements (RTAs) including an AI provision 151

Table 5.2. Main findings and recommendations related to Chapter 5 152

Figures 7

Figure 1.1. ASEAN has developed an interlinked architecture of digital trade initiatives, progressively expanding its integration ambition 21

Figure 1.2. The share of individuals using the Internet is growing fast but remains uneven across ASEAN Member States 22

Figure 1.3. ASEAN Member States show high internet connectivity and shares of trade to GDP implying strong potential for digital trade 23

Figure 1.4. Despite its overall economic importance, ASEAN Member States' participation in trade differs for services and goods 24

Figure 1.5. Machinery, electrical equipment, and mineral products account for over half of ASEAN's merchandise trade 26

Figure 1.6. Other business services, transport, and travel are most prominent components of ASEAN services trade 28

Figure 1.7. The relative importance of intra-ASEAN trade has declined over the last decade towards foreign partners, such as China,... 29

Figure 1.8. ASEAN digital trade grew by almost 10% per year, outpacing growth in the rest of the world 30

Figure 1.9. New players in digital trade have emerged at the global stage, including Singapore 32

Figure 1.10. Digital trade accounts for a growing share in exports of most ASEAN Member States 34

Figure 1.11. Digitally deliverable services are the major driver of ASEAN digital trade 35

Figure 1.12. EU 27, the United States, Japan, and China are destination markets for more than half of ASEAN digitally deliverable services exports 36

Figure 1.13. ASEAN is the second largest exporter of ICT goods, with Viet Nam almost tripling its global share over the last decade 37

Figure 1.14. Digitally deliverable services account for an increasing share of ASEAN Member States' services imports 38

Figure 1.15. The United States, EU 27, and other ASEAN Member States accounted for more than half of ASEAN imports of digitally deliverable services 39

Figure 1.16. The ASEAN region is the third largest importer of ICT goods and sources one-fifth of imports intra-regionally 40

Figure 2.1. Domestic regulatory barriers for digital trade vary significantly among ASEAN Member States 49

Figure 2.2. DSTRI framework with measures across five areas 50

Figure 2.3. Digital fragmentation is growing within and outside ASEAN 55

Figure 2.4. ASEAN Member States' regulatory environment in digital network services is more restrictive than the OECD average, particularly... 58

Figure 2.5. Telecommunication services saw regulatory improvements in most ASEAN Member States over the last decade, particularly... 59

Figure 2.6. Computer services are more restrictive in ASEAN than the OECD average 60

Figure 2.7. ASEAN Member States have made important progress in improving their trade facilitation environment 63

Figure 2.8. From distribution to logistics and courier services, ASEAN Member States' regulatory environments impose barriers on the sales,... 67

Figure 2.9. Tariffs on ICT and related products are particularly high in Cambodia, representing around three times the regional average 69

Figure 2.10. Joining the WTO Information Technology Agreement and its expansion would significantly reduce tariffs on ICT and related products,... 70

Figure 2.11. HS codes covered in ITA 1 and ITA 2 71

Figure 2.12. Cambodia and Myanmar would significantly benefit on the intensive margin from increased access to ICT/ITA goods by joining the WTO ITA 73

Figure 2.13. NTMs on ICT and related products are particularly high in the Philippines, Myanmar, Viet Nam, and Cambodia and take the form... 74

Figure 3.1. ASEAN Member States' approaches to cross-border data flows vary significantly 101

Figure 3.2. Singapore participates in two-thirds of RTAs with a cross-border data flow provision in e-commerce chapters and has mainly legally... 104

Figure 3.3. Data localisation is growing and becoming more restrictive in the ASEAN region 107

Figure 3.4. A typology of approaches to storage and processing requirements 108

Figure 3.5. Indonesia is the major user of the strictest form of data localisation (Cat. 3) among the seven ASEAN Member States 108

Figure 3.6. Strict data localisation prevails in the public and cloud computing sectors across ASEAN Member States 109

Figure 3.7. Financial, personal, and cloud computing data are most affected by strict data localisation requirements (Cat. 3) 110

Figure 4.1. Digital trade chapters in trade agreements have grown fast in ASEAN 122

Figure 4.2. ASEAN Member States are amongst the most integrated in terms of digital trade commitments 123

Figure 4.3. DEFA is poised to increase digital trade integration and openness significantly 127

Figure 4.4. Impact of different DEFA scenarios on total trade and regional trade 130

Figure 4.5. The AoE opens new opportunities for digital trade integration 133

Figure 4.6. Potential impact of the implementation of the WTO Agreement on E-commerce 134

Figure 5.1. Investments in AI are characterised by significant disparities between ASEAN Member States 142

Figure 5.2. Singapore is outperforming other ASEAN Member States in AI innovation 143

Figure 5.3. AI frameworks vary considerably across ASEAN Member States, mirroring different levels of preparedness 145

Figure 5.4. Tariff-barriers on AI enabling goods remain high in some ASEAN Member States although the ASEAN tariff environment is more... 148

Figure 5.5. Most ASEAN Member States are more restrictive to the movement of AI professionals than the OECD average, with little change over time 150

Boxes 9

Box 1.1. Measuring digital trade 31

Box 1.2. What products are included in trade of Information and Communication Technology goods? 37

Box 2.1. The OECD Digital Services Trade Restrictiveness Index (DSTRI) 50

Box 2.2. United Nations Convention on the Use of Electronic Communications in International Contracts 51

Box 2.3. ASEAN Initiatives for cross-border instant payment systems 52

Box 2.4. Indonesia's domestic regulation relating to customs duties on electronic transmissions 53

Box 2.5. OECD index measuring the restrictiveness of sector-specific services regulations 57

Box 2.6. OECD Trade Facilitation Indicators (TFIs) 62

Box 2.7. WTO Information Technology Agreement (ITA) and Membership of ASEAN economies 71

Box 2.8. Non-tariff measures 75

Box 3.1. Empirical findings suggest that restrictive domestic data flow regulations reduce economic outcomes 99

Box 3.2. Classifying data localisation measures into broad categories 107

Box 4.1. The OECD Index of Digital Trade Integration and Openness (INDIGO) 121

Box 4.2. The Digital Economy Framework Agreement (DEFA) 124

Box 4.3. Calculating the potential partial equilibrium impact of DEFA 128

Box 4.4. The WTO Joint Statement Initiative on e-commerce 131

Box 5.1. ASEAN initiatives on AI 141

Box 5.2. Four levels of AI policy elaboration 144

Annex Tables 9

Annex Table 3.A.1. Data localisation measures in ASEAN Member States analysed in Section 3.3 112

Annex Table 5.A.1. Adopted AI policy instruments of ASEAN Member States analysed in this chapter 153

Annex Figures 8

Annex Figure 1.A.1. Mobile broadband is growing fastest and accounting for the largest share in broadband connectivity globally and in ASEAN 42

Annex Figure 1.A.2. The composition of merchandise exports is very similar between Singapore and Malaysia but more diverse among the other... 43

Annex Figure 1.A.3. Digitally deliverable services are the fastest growing export component in several ASEAN Member States 44

Annex Figure 2.A.1. Telecommunications services in many ASEAN Member States primarily face restrictions related to effective competition... 77

Annex Figure 2.A.2. Estimated trade cost effect in Brunei Darussalam's telecommunications sector 79

Annex Figure 2.A.3. Computer services in many ASEAN Member States primarily face restrictions on the movement of people and foreign market entry 81

Annex Figure 2.A.4. Air transport services are facing a stricter domestic regulatory environment compared to other transport modes 82

Annex Figure 2.A.5. Performance in trade facilitation varies by policy area and ASEAN Member State 83

Annex Figure 2.A.6. ASEAN Member States' trade facilitation environment relevant for a transition towards digitised information and processes... 84

Annex Figure 2.A.7. Comparison of ITA products and ICT goods, HS2007 85

Annex Figure 2.A.8. Simulation of tariff liberalisation on ITA goods including ex-outs 86

Annex Figure 2.A.9. Imports of ITA goods by end-use category 87

Annex Figure 2.A.10/Annex Figure 2.A.8. Singapore applies few Non-Tariff Measures to most of its ICT/ITA imports 88

Annex Boxes 10

Annex Box 2.A.1. Brunei Darussalam's regulatory reforms in telecommunications have the potential to cut trade costs by half 79

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