A Comparison of Corporate Waqf Models in Malaysia and Indonesia: An Empirical Analysis of Models, Sectoral Acceptance, and Governance Challenges

Abstract

Corporate waqf is increasingly recognised as an alternative fiscal policy instrument in contemporary Islamic economics, yet its implementation in Malaysia and Indonesia faces distinct structural constraints. This article compares corporate and productive waqf models in both countries through a Systematic Literature Review (SLR) of 156 academic articles (2016–2025) drawn from the ScienceDirect (Elsevier) database, supplemented by additional sources to ensure comprehensive thematic coverage. The findings show that corporate/SME sector acceptance is driven by knowledge and attitude rather than religiosity alone; Malaysia leads in Waqftech innovation and SRI Musharakah Sukuk, while Indonesia pioneers the Bank Wakaf Mikro model and the integration of Baitul Maal wa Tamwil. Both countries also face distinct governance challenges institutional financial vulnerability in Malaysia versus Nazhir professionalism and land registration issues in Indonesia. This article puts forward policy implications encompassing the digitalisation of governance, professional certification, standardisation of risk management, and structural support from the banking sector. The study also acknowledges the limitations of a single-database SLR approach and proposes directions for future research.