<![CDATA[Purpose: This study aims to analyze the comparison of legal policies on the protection of workers with disabilities in Indonesia and Malaysia from a human rights perspective, as well as to identify key implementation challenges. Research Design and Methodology: The research employs a normative juridical approach by examining statutory regulations, legal doctrines, and international instruments such as the Convention on the Rights of Persons with Disabilities (CRPD). Findings and Discussion: Indonesia adopts a quota-based mandatory approach under Law Number 8 of 2016, while Malaysia applies an incentive-based model under the Persons with Disabilities Act 2008. Although Indonesia provides a stronger normative legal framework, its implementation remains weak due to inadequate supervision, ineffective sanctions, limited workplace accessibility, and low employer awareness. In contrast, Malaysia's incentive-based approach lacks binding legal obligations and effective enforcement, resulting in limited employment opportunities for persons with disabilities. This study contributes a comparative analysis of quota-based obligations and incentive-based employment models from a human rights perspective, demonstrating how different legal policies influence the realization of substantive equality and the right to work. Implications: Strengthening law enforcement, monitoring mechanisms, workplace accessibility, and employer awareness is essential to achieving an inclusive labor market consistent with human rights principles.]]>
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