The Comparison of Corporate Social Responsibility Regulations in Limited Liability Companies Between Indonesia and Germany

Abstract

This study aims to analyze and compare Corporate Social Responsibility (CSR) regulations in limited liability companies in Indonesia and Germany and identify substantive aspects of the German CSR model that are relevant for adoption in strengthening the legal framework for CSR in Indonesia. CSR is viewed as a social and environmental obligation that companies must fulfill to support sustainable development. This study uses a normative legal method with a legislative, conceptual, and comparative approach. The results show that although CSR in Indonesia is mandatory under Law No. 40 of 2007 and Government Regulation No. 47 of 2012, its implementation is still not optimal due to weak supervision, a lack of uniform reporting standards, and the absence of an independent supervisory body. In contrast, Germany regulates CSR more comprehensively through the Lieferkettensorgfaltspflichtengesetz (LkSG) and Handelsgesetzbuch (HGB) §§289b–289e, which emphasize the principles of due diligence, transparency, independent reporting, and supervision by special institutions such as the Bundesamt für Wirtschaft und Ausfuhrkontrolle (BAFA). Based on the results of the comparison, Indonesia needs to adopt the principle of due diligence, implement independently audited sustainability reporting, and establish a special supervisory agency to strengthen accountability and support the implementation of sustainable CSR.