Akad Sukuk Mudarabah, Praktiknya di Indonesia dan Bagaimana di Negara Kuwait

This study uses a qualitative method to examine the implementation of mudarabah sukuk contracts in Indonesia and Kuwait within the context of Islamic financial instruments development. In Indonesia, mudarabah sukuk has been developed as part of the national and private sector financing strategy, adhering to Sharia principles based on the fatwas of the National Sharia Council (DSN-MUI) and regulations from the Financial Services Authority (OJK). Its implementation focuses on project-based or asset-backed sukuk structures that ensure transparency and accountability, although challenges such as low public literacy and limited Sharia infrastructure remain. In contrast, Kuwait’s practice of mudarabah sukuk is more advanced in the banking and investment sectors, supported by a strong Sharia legal framework and a dominant oil-based economy. The Kuwaiti government applies a more established Islamic financial system with consistent regulations issued by Islamic financial institutions such as the Kuwait Finance House. This comparison shows that although both countries aim to develop similar instruments, their approaches to implementing mudarabah sukuk differ, reflecting their respective economic conditions, fiscal policies, and institutional capacities.