Dr Jiwei Qian is a Senior Research Fellow at the East Asian Institute, National University of Singapore. His research interests include innovation policy, social policy and digital economy. His latest book, Governing China's Digital Transformation: Industrial Policy, Regulatory Governance, and Innovation (Routledge, 2026), explores the critical policy landscape of China's digital economy, including industrial and regulatory policy issues. Previously, he authored The Political Economy of Making and Implementing Social Policy in China (Palgrave Macmillan, 2021) and co-edited Innovation and China’s Global Emergence (NUS Press, 2021). He has published widely in leading academic journals, including China Quarterly, Cities, Journal of European Social Policy, Journal of Social Policy, Pacific Review, Policy and Society, Policy Studies Journal, Public Choice, Social Science & Medicine, and Telecommunications Policy among others.

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States across the developing world enact data localization mandates to assert digital sovereignty, yet effective governance remains elusive. This paper identifies a structural explanation: localization law governs the physical layer, particularly data centers, but not the platform ecosystem through which data is processed and governed. We term this the Localization-Dependency Paradox: states secure jurisdiction over physical infrastructure while ceding effective governance over the platform layer above it, thereby embedding hyperscaler dependency rather than resolving it. Drawing on facility-level data from seven US and Chinese hyperscalers across six Southeast Asian countries between 2010 and 2026, the paper shows that the paradox operates through divergent network topologies. US hyperscalers construct Singapore-centered hierarchies that concentrate regional governance in a permissive hub, while Chinese hyperscalers build more distributed networks with localized processing nodes. Two mechanisms generate this divergence: home-state regulatory frameworks create asymmetric entry incentives, and hyperscalers satisfy physical-layer mandates through zero-equity colocation while retaining platform governance contractually. The 2024 Vietnam submarine cable disruption, treated as an external shock, further shows that topology shapes resilience: US, but not Chinese hyperscalers recalibrated. The Localization-Dependency Paradox reflects an emerging digital state of nature in which sovereignty mandates govern infrastructure while effective governance shifts to platform ecosystems.

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