The establishment of the Investment Management Agency Daya Anagata Nusantara (Danantara) under Law Number 1 of 2025 marks a paradigm shift in Indonesia’s state wealth management. However, Danantara’s institutional design raises normative concerns, including the ambiguity of its sui generis legal status, weak independent oversight, and unclear public accountability. This study compares Danantara’s institutional regulations with Temasek Holdings (Singapore) and Khazanah Nasional Berhad (Malaysia), and formulates an ideal model of oversight and legal accountability. Using a normative legal method with statutory, comparative, and conceptual approaches, this study finds that Danantara fundamentally differs from Temasek and Khazanah in three aspects: the legal regime of establishment, the degree of separation between ownership and management functions, and clarity of institutional mandate. Based on best practices from both institutions, this study proposes an ideal oversight model for Danantara built on three pillars: strengthened internal oversight through independent board restructuring, multilayered external oversight encompassing mandatory independent audit and parliamentary reporting, and structured public transparency through adoption of the Santiago Principles and mandatory annual public reporting.
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