Cross-Border Sukuk Regulation: A Comparative Analysis of Legal and Shariah Governance Frameworks in Five Key Markets

This study examines the contrasting regulatory frameworks governing Sukuk across Saudi Arabia, Malaysia, Nigeria, the United Kingdom, and Hong Kong. It explores how differences in legal systems, Shariah governance structures, and institutional arrangements affect the growth and integration of the global Sukuk market. Using a comparative qualitative design, the study relies on secondary data from peer-reviewed journals, regulatory publications, and official reports of international Islamic finance institutions. The data were analyzed through thematic content analysis, which identified patterns and disparities in Sukuk regulation. Findings reveal that while Sukuk has become a vital instrument for funding infrastructure and sustainable development, the absence of standardization limits cross-border investment and market confidence. The study reiterates the need for harmonized legal and Shariah frameworks to enhance transparency, investor protection, and global market stability. It concludes that collaboration among regulators, scholars, and standard-setting bodies such as Accounting and Auditing Organization for Islamic Financial Institutions (AAOIFI) and Islamic Financial Services Board (IFSB) is essential to reinforce global consistency in Sukuk issuance and practice. The paper contributes to the ongoing discourse on international financial integration and offers policy insights for advancing a unified Sukuk framework.