<![CDATA[The differences between the civil law tradition in Indonesia and sharia law in Saudi Arabia shape the distinct institutional characteristics, status, authority, and supervisory mechanisms of their respective legal documentation institutions. This study aimed to comparatively analyze the notarial institution in Indonesia and Kātib al-‘Adl in Saudi Arabia based on their legal systems and digital modernization. The study employed a normative juridical method with a comparative law approach. The research data were derived from secondary legal materials comprising legislation, literature, and official documents, which were analyzed comparatively. The findings showed that notaries in Indonesia serve as independent public officials and perform their professional duties based on attributive authority conferred by law. By contrast, Kātib al-‘Adl in Saudi Arabia holds the status of a government employee under the Ministry of Justice and exercises authority based on Islamic law and royal decrees. In terms of modernization, Saudi Arabia has implemented fully centralized digitalization of documentation services through the 2020 Documentation Law, whereas Indonesia continues to face formal legal barriers in the form of physical-presence requirements when implementing the cyber notary concept. This study confirms that differences in legal systems influence the bureaucratic characteristics and pace of technological adaptation of the two institutions. These findings provide a comparative basis for developing notarial policies while demonstrating the need for progressive regulatory reform to improve efficiency and support the digital transformation of notarial services in Indonesia.]]>
