Mohammad Thoriq Bahri


As more governments implement Golden Visa programs to attract foreign investment, this strategy provides countries with
economic benefits, as well as risks associated with transnational crime and the legal system. Through comparative benchmarking and case
studies, this article tries to bridge the gap in order to establish the optimal Golden Visa system for Indonesia. This study will provide
insights into the most suitable scheme that Indonesia can implement by assessing the benefits and problems of different citizenship by
investment programs in Portugal, Spain, and Malta. This article will present the best schemes for Indonesia based on a qualitative doctrinal
comparative analysis technique, considering many legal and socioeconomic parameters such as investment thresholds, processing time,
residence restrictions, and return on investment. This research suggests that Indonesia, demographically, needs more investors to provide
more jobs, as Indonesia has a workforce of more than 117 million and maintains its economic stability to grow at a rate of 5% per year.
Furthermore, in terms of legal gaps, Indonesia does not have any legal basis to provide visas for more than 5 years, as regulated in
Immigration Law No.6/2011. Thus, an additional legal framework is required. Based on these findings, the paper will provide case studies
of investors who have successfully navigated the Golden Visa process in Indonesia, shedding insight on the practical aspects of the
application procedure as well as how to optimize investment outcomes.