Comparative Analysis of Zakat Implementation in Three ASEAN Countries (Indonesia, Malaysia, and Singapore) from 2021 to 2023: A Study on Regulations and Practices

Abstract

The purpose of this study is to analyze the implementation of zakat in three ASEAN countries (Indonesia, Malaysia, and Singapore) during 2021–2023, focusing on the policies and practices applied in each country. A comparative approach is used to identify differences and similarities in legal frameworks, governance mechanisms, and their impact on society. Research data were obtained through the analysis of policy documents, zakat institution reports, and a review of relevant literature. The findings of this study reveal that the regulatory systems for zakat in Indonesia, Malaysia, and Singapore reflect differing approaches tailored to the characteristics of their societies and governmental structures. Indonesia has a robust legal framework through Law No. 23 of 2011, which provides a foundation for BAZNAS and LAZ to collaborate in managing zakat. Malaysia employs a decentralized system, with each state having full authority over zakat management. While this approach allows responsiveness to local needs, the absence of national regulation leads to weak coordination and disparities in transparency and efficiency among states. Singapore demonstrates the most centralized and professional zakat management system through the Islamic Religious Council of Singapore (MUIS), regulated by the Administration of Muslim Law Act (AMLA). Supported by modern technologies such as online zakat payment systems, Singapore achieves a high level of efficiency despite its Muslim community comprising only 15% of the total population. This study provides recommendations to enhance the effectiveness of zakat implementation in the ASEAN region through policy harmonization and strengthened inter-country collaboration.