<![CDATA[This study analyzes the disparity in environmental, social, and governance due diligence enforcement within transnational corporate restructurings between Indonesia and Singapore, evaluating its profound impact on foreign direct investment certainty. Utilizing a doctrinal legal methodology with comparative and conceptual approaches, this research systematically investigates the normative friction between mandatory frameworks in Singapore and fragmented regulations in Indonesia. The findings reveal that the corporate legal architecture of Indonesia, particularly the reduction of sustainability metrics to mere corporate philanthropy under the Company Law, alongside the complete absence of green antitrust parameters in merger controls, creates severe legal uncertainty. This regulatory vacuum directly exposes investors to greenwashing and hidden financial risks. Consequently, this article proposes a statutory reconstruction grounded directly in the Green Constitution paradigm. Transforming voluntary metrics into mandatory due diligence within corporate restructuring is an absolute necessity to protect all transnational investors, optimize investment climates, and ensure long term ecological sustainability.]]>
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