Immigration Law and Human Rights
Open access
Peer reviewed
Abstract
Abstract
Visa and residence permit policies are legal instruments of immigration governance that regulate the mobility of business actors, foreign workers, investors, and global talent while safeguarding state sovereignty and security. Within ASEAN, Indonesia, Singapore, and Malaysia have developed different policy designs to accommodate business and investment mobility. This study compares the legal frameworks governing visas and residence permits in the three countries, assesses their normative-administrative effectiveness in supporting the business climate, and formulates directions for Indonesian legal reform. It employs normative legal research using statutory, comparative, and conceptual approaches. Primary legal materials consist of immigration laws and policies of Indonesia, Singapore, and Malaysia, complemented by secondary legal materials and analyzed through a descriptive-comparative method. The analysis adopts the perspectives of ius constitutum, ius operatum, and ius constituendum. The study finds that Singapore operates a selective yet adaptive system through differentiated immigration pathways for investors and skilled professionals, supported by digitalized services and relatively clear institutional specialization. Malaysia relies on a pass-based regime and long-term residence programmes that are comparatively competitive for investors, professionals, and expatriates. Indonesia has undertaken reforms through visa simplification, digitalization, and the Golden Visa scheme, but still faces regulatory fragmentation, inter-agency coordination challenges, and the need for stronger legal certainty and service integration. Normatively, a simple, transparent, digital, and risk-based policy design is more compatible with business mobility while preserving immigration control. Indonesian reform should therefore focus on regulatory harmonization, institutional integration, service standards, and periodic evaluation of economic benefits and immigration risks.
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@article{Sari2026Legal,
title = {Legal Comparison of Visa and Residence Permit Policies in Indonesia, Singapore, and Malaysia in Supporting the Business Climate in the ASEAN Region},
author = {Nur Karima Kemala Sari},
journal = {Adagium.},
year = {2026},
doi = {10.70308/ex1qmq13},
url = {https://doi.org/10.70308/ex1qmq13}
}FAQ
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