Comparative Legal Protection of Female Tourism Workers in Indonesia and Malaysia: An SDGs 5 and 8 Analysis

The protection of female workers in the tourism industry in Indonesia and Malaysia raises legal challenges concerning discrimination, wage inequality, maternity protection, and sexual harassment in the workplace. These issues are important because the tourism sector employs many women and may expose them to unequal treatment and vulnerable working conditions. This study seeks to examine and compare the legal frameworks governing such protection across equality and non-discrimination, remuneration, working time, maternity protection, violence and sexual harassment, statutory coverage, and enforcement, and to formulate an ideal protection model based on the Sustainable Development Goals (SDGs). This study adopts a normative juridical approach using statutory and comparative analysis of legal materials applicable through September 2026 in Indonesia and, for the Employment Act 1955, Peninsular Malaysia and Labuan, selected for relevance to those dimensions. The findings indicate that Indonesia generally combines substantive statutory guarantees with differentiated protections relevant to female workers, while Malaysia more often relies on general employment standards supported by administrative and complaint mechanisms. The comparison identifies normative differences and gaps, particularly in remuneration and enforcement design. The resulting model integrates substantive rights protection, accessible enforcement and remedies, clear and inclusive statutory coverage, and jurisdiction-sensitive implementation, aligned with SDG Targets 5.1, 5.2, 8.5, and 8.8.