This paper examines how cybersecurity risks are regulated within the ECF frameworks of these two countries and evaluates the effectiveness of the legal protections provided to financial investors. This study investigates the following central research question: how can a comparative legal framework be developed to strengthen the legal protection of financial investors against cybersecurity risks on Indonesian and Malaysian equity crowdfunding platforms? This study employs a normative legal research method, drawing on statutory, conceptual and comparative approaches. The legal materials examined include legislation, regulatory policies, cybersecurity governance frameworks and academic literature on equity crowdfunding and investor protection in Indonesia and Malaysia. The research reveals that both jurisdictions have established legal frameworks governing equity crowdfunding and digital financial services. However, cybersecurity governance, regulatory supervision, data protection standards and platform liability significantly differ. While Malaysia adopts a more integrated regulatory approach through centralised supervision and clearer cybersecurity requirements, Indonesia continues to experience regulatory fragmentation and overlapping institutional authority. The analysis shows that existing regulations in both countries primarily focus on financial compliance and market supervision, whereas legal protection against cybersecurity-related losses is minimal. Consequently, investors may face legal uncertainty when cyber incidents result in financial harm or unauthorised access to investment assets. Based on these findings, the study recommends developing a comparative legal framework that emphasises cyber resilience, stronger cybersecurity obligations for platform operators, enhanced investor rights, integrated regulatory supervision and clear liability mechanisms for cyber-related losses. Such reforms are expected to strengthen investor confidence, improve legal certainty and support the sustainable growth of equity crowdfunding ecosystems in Indonesia and Malaysia.
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