REGULATORY APPROACHES TO DIGITAL TRANSFORMATION OF THE BANKING SECTOR: THE EXPERIENCE OF DEVELOPED COUNTRIES

Abstract

The digital transformation of the banking sector is a key trend in the modern financial system, requiring the adaptation of the regulatory framework to ensure stability, security, and innovative development. The article provides a comparative analysis of regulatory approaches to the digitalization of banks in developed countries, including the European Union, the United Kingdom, Norway, the United States, and Asian countries (China, Singapore). The study covers aspects such as the regulation of digital currencies (CBDCs), fintech ecosystems, cybersecurity, and data protection. The results demonstrate both general trends and national specificities. It is emphasized that the European Union is one of the leaders in the field of digital finance regulation, demonstrating a comprehensive regulatory approach that combines stimulating innovation with strict requirements for cybersecurity and regulation of crypto assets. A description is provided of such EU regulations as EU Regulation 2022/2554 Digital Operational Resilience Act, which establishes uniform requirements for the digital operational resilience of the EU financial sector; PSD2 Directive (Payment Services Directive 2, – regulates payment services and promotes the development of open banking) and PSD3; Markets in Crypto-Assets, which regulates the crypto-asset market, increases investor protection, and ensures financial stability. The US is found to be characterized by a decentralized regulatory system with competition between federal and state regulators. Flexibility for fintech in the US is combined with caution on the issue of CBDC and contradictions in the regulation of the crypto market. The study shows that China and Singapore are combining state control with cutting-edge technological development. China is leading the way in implementing a CBDC (digital yuan) while completely banning cryptocurrencies, while Singapore is balancing regulation with support for fintech. The conclusions emphasize that the key tasks for regulators remain ensuring cybersecurity, data protection, harmonization of standards and development of international cooperation.