The self-declare halal certification scheme facilitates certification for micro and small enterprises but involves multiple parties with distinct responsibilities, raising questions about legal accountability when product non compliance occurs. This study examines the legal accountability framework and proposes a proportionate model based on functions, authority, obligations, and risk control capacity. Employing normative legal research with statutory and conceptual approaches, primary and secondary legal materials are analyzed through qualitative prescriptive methods, including normative mapping, gap identification, legal interpretation, and construction. The findings reveal an accountability gap between functional allocation and responsibility attribution within the self declare mechanism. To address this gap, the study proposes a layered accountability model comprising primary, verification, institutional determination, and systemic supervisory accountability. Responsibility is assessed using a point-of-failure test that examines legal authority, obligations, risk-control capacity, and causal connections between failures and product non-compliance. The model shifts accountability from an actor-centered approach toward function-based and failure-based attribution, promoting a more proportionate allocation of responsibility consistent with justice principles in Islamic economic law and maqasid shariah. Further empirical research on post certification cases is necessary to evaluate the model’s practical applicability and effectiveness in addressing accountability gaps within Indonesia’s halal certification system.
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