The rapid expansion of the gig economy across Southeast Asia has fundamentally disrupted traditional labor market structures, creating a significant regulatory void in the protection of platform workers. This article presents a comparative legal analysis of labor law enforcement for gig economy workers in Indonesia and Singapore, two nations with distinctly different regulatory approaches. Employing qualitative legal research with a normative-comparative approach, this study examines statutory frameworks, judicial interpretations, and policy instruments in both jurisdictions. The findings reveal a striking regulatory divergence: Singapore has enacted the Platform Workers Act 2024, establishing a sui generis legal category with mandatory Central Provident Fund contributions, work injury compensation, and collective representation rights. In contrast, Indonesia continues to rely on fragmented regulations that relegate platform workers to ambiguous "partnership" status, excluding them from basic labor protections under Law No. 13 of 2003. The study identifies that less than 3.5% of Indonesian gig workers possess employment social security, while Singapore provides comprehensive coverage to approximately 70,000 platform workers. The article argues that Indonesia's regulatory inertia constitutes structural inequality that perpetuates worker vulnerability, and recommends the adoption of a hybrid "third category" legal framework inspired by Singapore's progressive model, while adapting it to Indonesia's unique socio-economic context. Furthermore, the article examines Indonesia's post-amendment governance of state-owned enterprises under Law No. 1 of 2025, which strengthens Good Corporate Governance and Business Judgment Rule protections, though implementation challenges persist. The effectiveness of both regulatory reforms depends significantly on consistent internal controls, transparent metrics, and principled judicial interpretation.
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