| Indonesia | Law No. 19 of 2008 on State Sharia Securities; Government Regulation No. 56 of 2008 | Separate-law model | Use of state assets and beneficial rights; dedicated issuing company; SPV-based sovereign structure | Provides one of the clearest statutory frameworks, yet still does not eliminate deeper doctrinal uncertainty, because it relies on limited transfers of beneficial rights rather than full alienation of public assets. |
| United Kingdom | Finance Act 2008; Government Alternative Finance Arrangements Regulations 2014; FSMA-related amendments | Amendment model | Sukuk accommodated through tax, regulatory, and borrowing-law adjustments aimed at functional equivalence with conventional sovereign finance | Shows a pragmatic accommodation strategy, but one that facilitates sukuk without fully resolving whether the instrument is a proprietary certificate, a debt equivalent, or a special alternative-finance product. |
| Turkey | Amendment introducing Article 7/A into the Public Finance and Debt Management Law; Law No. 6111; Law No. 6327; Law No. 6332; Capital Markets Board Communiqués | Amendment model | Lease-certificate structure enabled through layered changes to public-finance, tax, and capital-markets law | Illustrates a strongly accommodative legislative technique: sukuk is made possible through exceptions, equivalences, and supporting rules, rather than through a single settled legal theory of the instrument. |
| Malaysia | Capital Markets and Services Act 2007 (Act 671); Prospectus Guidelines; Registration of Shariah Advisers Guidelines 2009 | Institutionally integrated regulatory model | Stronger securities-law setting combined with centralized or structured Sharia governance | Represents one of the most developed frameworks, but the article emphasizes that even strong institutionalization does not fully dissolve deeper tensions, especially where trusteeship, disclosure, and governance disputes arise. |
| Egypt | Law No. 10 of 2013 on Sukuk; Law No. 17 of 2018 amending Capital Market Law No. 95 of 1992 | Shift from standalone sukuk legislation to integration within the amended capital-market framework. | Statutory recognition was first attempted through a separate sukuk law, then later reconfigured within the broader capital-market regime. | Illustrates that formal enactment did not produce a stable standalone model; instead, the legal treatment of sukuk was later reorganized within the broader capital-market framework. |
| Luxembourg | Luxembourg’s July 2014 sukuk law and related treasury/market arrangements | Targeted accommodation in a non-Muslim financial center | Adjustments designed to avoid tax or structural disadvantage relative to conventional bonds | Shows that sukuk can enter mainstream financial centers, but only through tailored legal adjustments, not because it fits naturally into existing debt-law categories. |
| Hong Kong | Loans Ordinance amendments; tax legislation | Targeted accommodation in a non-Muslim financial center | Legal and tax changes designed to facilitate sovereign sukuk without disadvantage relative to conventional borrowing | Like Luxembourg, it supports the article’s claim that sukuk’s integration often depends on jurisdiction-specific accommodation, not on a settled transnational legal model. |