A COMPARATIVE ANALYSIS OF DIGITAL HEALTH PLATFORM FOR TELEMEDICINE IN INDONESIA AND MALAYSIA: LEGAL CHALLENGES AND POLICY IMPLICATIONS

• Rizka Erlyani

  Universitas Pembangunan Nasional "Veteran" Jakarta

  Author

• Handar Subhandi Bakhtiar

  Universitas Pembangunan Nasional "Veteran" Jakarta

  Author

• Muthia Sakti

  Universitas Pembangunan Nasional "Veteran" Jakarta

  Author

This article aims to provide a comparative analysis of the regulatory frameworks governing digital health platforms for telemedicine in Indonesia and Malaysia. By examining the legal structures, challenges, and opportunities of telemedicine implementation through private digital platforms, the study identifies key differences and similarities between the two countries. The research employs a normative legal approach with a combination of statutory and comparative analysis. It evaluates the relevant laws and regulations in both countries, including Indonesia’s Law No. 17/2023 on Health and Malaysia’s Telemedicine Act 1997. The analysis focuses on platform-based models, such as Halodoc in Indonesia and BookDoc in Malaysia, to explore their regulatory compliance, data protection measures, and the implications for healthcare accessibility and patient safety. The findings reveal significant regulatory gaps in Indonesia, particularly in terms of legal recognition for private platforms and unclear accountability mechanisms. In contrast, Malaysia’s more integrated regulatory framework facilitates smoother collaboration between public and private sectors. The study concludes by recommending policy improvements for Indonesia, advocating for clearer regulations to ensure legal certainty, patient protection, and quality service in telemedicine.

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