Cyberbullying Regulation and Victim Protection in Indonesia and Malaysia: A Comparative Analysis for Indonesian Criminal Law Reform

Abstract

Introduction: Cyberbullying presents challenges for criminal law and victim protection because harmful digital conduct may involve repeated harassment, threats, humiliation, and psychological harm. Indonesia’s fragmented regulatory framework raises questions concerning the adequacy of existing criminal law in addressing these forms of digital violence. Purposes of the Research: This study examines the legal regulation and victim protection mechanisms concerning cyberbullying in Indonesia and Malaysia and formulates implications for Indonesian criminal law reform. Methods of the Research: This normative legal study applies statutory, comparative, and conceptual approaches. Primary legal materials and relevant scholarly literature are analyzed through qualitative doctrinal reasoning, with attention to offense elements, victim protection, and institutional mechanisms. Findings of the Research: The analysis identifies differences in the legal treatment of cyberbullying, particularly concerning repeated conduct, the recognition of psychological harm, and the relationship between criminal enforcement and digital protection measures. The study argues that Indonesian reform requires clearer legal classification, safeguards for victims, and coordination between criminal justice institutions and digital governance mechanisms. Conclusion, Indonesian criminal law reform should develop a coherent framework for addressing repeated cyberbullying, evaluating psychological harm, preserving digital evidence, and ensuring accessible victim protection. The proposed framework requires further validation against applicable legislation and institutional practice in both jurisdictions.