B Bankruptcy is a legal instrument that provides legal certainty in the settlement of debts between debtors and creditors. indonesia and malaysia have different legal systems, namely the civil law system and the common law system, resulting in different mechanisms for resolving bankruptcy cases in each country.this study aims to analyze the legal framework governing the settlement of bankruptcy cases in indonesia and malaysia, as well as to compare the similarities, differences, advantages, and disadvantages of each system. this research employs a normative legal research method with a descriptive comparative law approach. the data used are secondary data obtained through library research, including legislation, books, academic journals, and court decisions, namely law number 37 of 2004 concerning bankruptcy and suspension of debt payment obligations, the insolvency act 1967, the supreme court decision number 65 pk/pdt.sus-pailit/2023, and the decision in affin bank berhad v. abu bakar bin ismail.the results of the study indicate that the indonesian bankruptcy system emphasizes legal certainty through statutory regulations and the suspension of debt payment obligations (pkpu) mechanism as a means of debt restructuring. meanwhile, malaysia applies the principle of prudence in determining bankruptcy status, requires the issuance of a bankruptcy notice, and places greater emphasis on debtor rehabilitation, which constitutes one of the strengths of its bankruptcy procedure. although both countries aim to protect the interests of creditors and debtors, they differ in their procedures and mechanisms for resolving bankruptcy cases. therefore, indonesia may adopt several advantages of malaysia’s business rescue concept to enhance the effectiveness of bankruptcy case resolution without compromising legal certainty.