The development of halal tourism worldwide reflects a response to the recognition and improvement of the needs of Muslim communities globally. The growth of Muslim countries around the world contributes to this increasing trend. Tourism is one factor that increases a country's foreign exchange. Many countries are preparing to increase visits from both local and international tourists, including attracting Muslims, who represent the second largest religious population in the world (Dyvik, 2023). In 2026, Muslim travelers are predicted to spend USD 180 billion on online travel bookings (Mastercard & CrescentRating, 2019). The innovation of each country's policy has created new trends. For example, Japan and Australia have introduced Omotenashi, which provides Muslim Travel Guide packages. Serendipity Travel in the UK offers worship facilities for Muslim tourists (Pranandari et al., 2023). The UK, in fact, has a Muslim minority status.

Indonesia, as a Muslim-majority country, has developed a strategic plan called the Islamic Economic Masterplan. This plan outlines both the potential and challenges of the Islamic economy in Indonesia. The 2019-2024 master plan identifies opportunities to develop several Muslim-friendly concept hotels, referencing several award-winning hotels as examples (National Committee for Sharia Finance, 2019). The government assigns responsibility for sharia economic policy to the Indonesian Ulema Council (MUI). This institution is a nongovernmental body authorized to address issues faced by Muslim communities in Indonesia through the issuance of fatwas. However, these fatwas are aspirational and do not have binding legal force (Tamam, 2021).

According to Mansyurah (2019), with a reported 87.2% Muslim population, the halal industry should be easy to develop in Indonesia. As part of the halal tourism sector, Sharia hotels present opportunities for entrepreneurs who want to take advantage of this growing market. The National Sharia Council-Majelis Ulama Indonesia (2016) defines the Sharia Hotel Business as the provision of accommodation in the form of rooms in a building. These hotels can also offer food and beverage services, entertainment activities, and other facilities on a daily basis to generate profit, provided they operate according to sharia principles (Fatwa Number 108/DSN-MUI/X/2016 Concerning Guidelines for Organizing Tourism Based on Sharia Principles, 2016).

Fatwa Number 108/DSN-MUI/X/2016 concerning Guidelines for Implementing Tourism Based on Sharia Principles is the only regulation that governs Sharia Hotel guidelines. This situation arises because the Minister of Tourism Regulation Number 11 of 2016 revoked the Minister of Tourism and Creative Economy Regulation Number 2 of 2014, which previously provided guidelines for the implementation of Sharia hotel business. The revocation occurred because the demands and development of tourism no longer aligned with the contents of the earlier regulation (Permenparekraf, 2016).

As Indonesia's neighboring Muslim country, Malaysia is equally friendly and benefits from government-regulated policies. The tourism sector, particularly in culture and nature, receives support from the best available facilities. Kuala Lumpur, the capital, has 53 halal-certified hotels with 1 to 2 stars and 273 halal-certified hotels with 3 to 5 stars (Fadhlan & Subakti, 2020). These data positively affect its policies, specifically Malaysia Standard 2610 of 2015 on Muslim Friendly Hospitality Services. The government's official policy regulates the requirements and attitudes necessary in hospitality services (Standard Malaysia, 2015).

The policies established by the two countries show almost equal similarities. In Indonesia, Sharia hotels are normatively regulated in Article 5 of MUI fatwa Number 108/DSN-MUI/X/2016. This regulation is non-binding and does not have the force of law. In contrast, Malaysia regulates Sharia hotels through Malaysian Standard (MS) 2610 2015, specifically in Articles 4 and 5. This regulation appears more binding because the Ministry of Science, Technology and Innovation supervises its issuance.

Islamic attributes serve as essential indicators of Muslim-friendly tourism needs and play a crucial role in convincing Muslim tourists to visit. This study will align the Islamic attributes of destinations with the policies of both countries. The comparison will show the suitability of these policies with the existing indicators. In addition, researchers rarely apply these parameters in this type of study. Therefore, this study can contribute to developing research in the Islamic hotel industry.

Halal tourism

The development of halal tourism in Indonesia and Malaysia differs significantly. There is an imbalance in the amount of halal tourism research between the two countries. Malaysia has only 18 articles, while Indonesia has 61 articles (Alam et al., 2024). This difference may occur because Malaysian articles rarely vary their theoretical frameworks. For example, researchers have adapted environmental awareness campaigns by non-profit communities to mosques in ITB as an innovation in halal tourism studies. This approach can strengthen halal ecotourism (Alam, Mellinia, et al., 2024). In addition, authors from Indonesia dominate halal tourism articles on Scopus. This dominance shows the significant development of halal industry studies in Indonesia (Alam et al., 2024).

The research "Comparison of Halal Concepts in Three Countries" compares halal tourism as developed by Indonesia, Malaysia, and Thailand through literature-based research. Indonesia, which has 800,000 mosques, has designated 10 halal tourism destinations. These include Aceh, Riau and its Islands, West Sumatra, Jakarta, West Java, Central Java, Yogyakarta, East Java, South Sulawesi, and Lombok. Malaysia is developing its halal tourism seriously through the Ministry and JAKIM. The country maintains consistency due to exceptional support and incentives for the halal industry. As a result, Malaysia ranked as the first Muslim-friendly destination by the MasterCard-Crescent Global Muslim Travel Index (GMTI) in 2016 (Djalaluddin, 2016). However, the policies of the three countries have not been the main focus of the comparison. (Peristiwo, 2020) found that halal tourism faces challenges because of differences in demand between Muslim and non-Muslim travelers. These differences have the potential to hinder industry growth. However, a study of Sharia hotel customer satisfaction in Indonesia shows that customers are satisfied with their stays in Sharia hotels (Alam et al., 2023).

(Peristiwo, 2020) found that halal tourism faces challenges because of differences in demand between Muslim and non-Muslim travelers. These differences have the potential to hinder industry growth. However, a study of Sharia hotel customer satisfaction in Indonesia shows that customers are satisfied with their stays in Sharia hotels (Alam et al., 2023). Facilities, prices, products, and services, including the possession of halal certification, strongly affect this satisfaction (Alam et al., 2023).

The effectiveness of the halal tourism policy in Indonesia was measured. Using a similar type of study, (Susilawati, 2023) found that fatwa No.108/DSN-MUI/X/2016, which concerns Guidelines for the Implementation of Tourism Based on Sharia Principles, has a non-binding legal status as the most recent law and is ineffective as a rule of law. In addition, this policy is further weakened by inadequate law enforcement, insufficient facilities and infrastructure, and limited public understanding. This research can contribute to examining one sector of halal tourism, specifically Islamic hotels. Furthermore, the research topic will be more robust when comparing the conditions in Indonesia with those in Malaysia.

Researchers measure Islamic Attributes of Destination to determine their development and to examine their influence on traveler satisfaction. (Battour et al., 2014) found, through the stages of construct size development, that Islamic attributes of destination, such as worship facilities and halal food, and traveler satisfaction have a positive relationship. This finding may indicate that destinations promoting Islamic attributes affect both Muslim travelers' satisfaction and competitiveness in the tourism market. The theory will be more interesting if the policies in this study are analyzed based on the requirements of the mentioned attributes.

Differences in Halal Standards in Several Countries

The absence of an international halal standard institution has led several countries to develop their own halal standards independently. However, international organizations can unite a vision that facilitates the development of the international halal industry. The Indonesia-Malaysia-Thailand Growth Triangle (IMT-GT) operates as a sub-region under ASEAN, with halal product investment as one of its focus areas. Through the collaboration of these three countries, Muslim minority countries such as South Korea, India, China, and Japan could establish halal certification standards (Setyaningsih, 2022) Tourism development in Japan led the country to create the Japan Halal Association (JHA).

This initiative is based on the concept of Omotenashi, which promotes the "hospitality" of Japanese citizens toward tourists. As a result, the number of Muslim tourists increased by around 30 percent in 2013 (Wahidati & Sarinastiti, 2018). In addition, Asazuma in (Fadhlan & Subakti, 2020) stated that 52 restaurants provide halal food. However, these restaurants are only available in big cities. There are also only 241 prayer spaces in strategic locations, such as Osaka and Tokyo.

This research is a normative study that uses data collection techniques in literature studies (Darmalaksana, 2020). The data analyzed include the policies of two countries, which remain an essential reference for Sharia hotel managers. In addition, the analysis includes data on the development of Sharia supervision and the political development of both countries. These factors affect Sharia hotel managers' compliance with policies set in Indonesia and Malaysia.

Indonesia Sharia Hotel Regulation

The government does not strictly regulate Islamic hotels. The National Sharia Council-Indonesian Ulema Council has issued fatwa No. 108/DSN-MUI/X/2016 concerning Guidelines for the Implementation of Tourism Based on Sharia Principles. The fifth article of this fatwa contains provisions related to Islamic hotels principles (Fatwa Number 108/DSN-MUI/X/2016 concerning Guidelines for Organizing Tourism Based on Sharia Principles, 2016). The government had issued regulations on implementing the sharia hotel business through the Minister of Tourism and Creative Economy Regulation Number 2 of 2014. However, Permenpar Number 11 of 2016 revoked this regulation because it no longer aligned with current tourism demands and development. Thus, the fatwa is the sole rule that Islamic hotel managers in Indonesia obey. The position of the fatwa is not binding (Tamam, 2021). As a result, many sharia hotels in Indonesia are only labeled as sharia without fully complying with sharia elements. However, some hotels still uphold the principles in their own way. For example, upholding Islamic business ethics can positively affect customer satisfaction (Maulidya et al., 2019). Religiosity can also moderate Islamic hotel marketing (Dienillah et al., 2020).

Malaysia Sharia Hotel Regulation

As a country with an Islamic constitution, the government enacts legislation based on Islamic principles. All Islamic hotel managers must comply with the 2015 MS 2610 regulation on Muslim-friendly hospitality services requirements. (Standard Malaysia, 2015), a National Standardisation Agency under the Ministry of Science, Technology and Innovation, issued this policy. By implementing this approach, Malaysia attracted global attention as the leading destination for halal tourism according to GMTI in 2019 and 2022. For example, Khan in (Peristiwo, 2020) showed that 273 halal hotels could be certified in the 3 to 5-star categories, and 53 hotels in the 1 and 2-star categories.

Sharia Hotel Policies

The regulations used and still valid by Indonesia and Malaysia have differences in terms of policymakers, policies, and characters. The sharia hotel policy that applies in Indonesia, Fatwa No.108/DSN-MUI/X/2016, concerning Guidelines for the Implementation of Tourism

The Department of Standards Malaysia issued MS 2610:2015 on Muslim Friendly Hospitality Services-Requirements with the following summary:

Malaysia also issued three fatwas on hotels, which Jabatan Kemajuan Islam Malaysia (JAKIM) issued: "Al-Quran Placed in Malaysian Hotels," "Providing Al-Quran and its Translation in Hotels," and "The Law of Selling Arak to Non-Muslims in Hotels". However, the entire content of the fatwas only provides views regarding two specific requirement points contained in MS 2610:2015.

Islamic Attributes of Destination

Tourism and accommodation managers must highlight the needs of Muslims, who differ from the general public when visiting a place. One way to attract Muslim tourists to tourist attractions is to give an Islamic touch to various areas of the destination (Battour et al., 2014). This study analyzed Muslim tourist satisfaction using Islamic Attributes of Destination (IAD) parameters that managers applied. The study simplified factors that Islam allows and prohibits into four dimensions.

Policy Comparison between Indonesia and Malaysia

Based on the analytical framework established above, the policies on Islamic hotels remain valid in Indonesia and Malaysia when compared with IAD. The points outlined in the policy align with the dimensions of IAD, which results in significant conformity. Several articles included in the policy correspond to the four dimensions of IAD.

Worship Facilities

In the fifth article of fatwa No. 108/DSN-MUI/X/2016, which discusses the provisions of Islamic hotels, the fourth point fulfills the criteria. The article states, "Provide adequate facilities, equipment, and facilities for the implementation of worship, including purification facilities." In the fifth article of MS 2610:2015, the point regarding public and prayer rooms also fulfills the criteria. Managers must ensure that rooms have Qibla directions and recommend adequate prayer tools, the Quran, and information on prayer times. In addition, public prayer rooms must fulfill the general feasibility requirements for places of worship, such as providing sufficient prayer mats and separate ablution places.

Islamic Facilities

In the fifth article of fatwa No.108/DSN-MUI/X/2016, points one, two, and seven fulfill the criteria. Some of these points mention, "Islamic hotels must not provide access facilities for pornography and immoral acts; Islamic hotels must not provide entertainment facilities that lead to polytheism, immorality, pornography, and/or immoral acts; Islamic hotels must use the services of Sharia Financial Institutions."

Several points also fulfilled the criteria in the fifth article of MS 2610: 2015. At the accommodation point, guests must clean the mughalladah impurity from non-halal animals brought to the hotel. The room must always be clean and maintained, and there must be no alcoholic beverages in the refrigerator. Public toilets, entertainment, and health facilities must also be clean and Muslim-friendly.

General Islamic morality

In the fifth article of fatwa No.108/DSN-MUI/X/2016, points five and six fulfill the criteria. They mention that hotel managers and employees must wear sharia-compliant clothing and must have guidelines and/or guidelines regarding hotel service procedures to ensure the implementation of hotel services in accordance with sharia principles.

All General Requirements of MS 2610: 2015 fulfill the criteria. It discusses Islamic management, including management responsibility to the muslim friendly, personnel and responsibility, muslim friendly management systems, training, documentation, and storage, and communication.

Halal Food

The third point of the fifth article in fatwa No.108/DSN-MUI/X/2016 fulfills the criteria. It states, "Food and drinks provided by Islamic hotels must have obtained a halal certificate from MUI." In addition, the fifth article of MS 2610:2015 also fulfills the criteria. This policy regulates the same requirements regarding halal certification and the obligation to provide services during the month of Ramadan.

In the IAD concept, Islamic morality is essential for Muslim travelers. Islamic services provide higher satisfaction. Halal food is a vital priority, and entertainment and Islamic facilities support this need. The availability of worship places and facilities is also important because Muslims require regular worship. Both institutions have organized all the criteria that match the dimensions of IAD through their respective policies. The policy listed by Malaysia Standard elaborates more specifically, using long sentences that are specific and semi-strict.

Several studies related to IAD show its influence on Muslim travelers. For example, (Sudigdo & Khalifa, 2020) found that IAD has a significant effect on tourism in Jakarta, which has a destination image that attracts Saudi Arabian tourists. The government is also asked to provide worship space in public spaces (Sudigdo & Khalifa, 2020). In addition, religion plays an important role in IAD because it is influential in tourist motivation and satisfaction (Battour & Ismail, 2014).

Policy comparisons based on IAD can make it easier for academics and policymakers to develop Islamic hotel regulations globally. However, this study is limited to Islamic hotel policies only. This study can reach other IAD research, especially in Islamic tourism. Fatwa DSN MUI and MS 2610 also discuss travel agencies, tour management, and tour guides.

One of the primary challenges in the development of sharia-compliant hotels is the absence of a unified international standard regarding the definition and operationalization of "Muslim-friendly hotels." This lack of standardization results in varying terminologies, understandings, and operational guidelines across different countries (Chantarungsri et al., 2024). Furthermore, international studies reveal that religiosity, brand identity, and reference group influence are significant determinants in Muslim travelers’ decision-making processes when selecting sharia hotels (Syara & Fauzan, 2023). A robust brand identity and consistent application of sharia principles are found to foster customer loyalty and enhance the global positioning of sharia hotels ((Mulyani et al., 2022); (Sarinastiti & Uljanatunnisa, 2020)). The consistent implementation of Islamic business ethics also contributes to higher levels of customer satisfaction and loyalty (Ghadas et al., 2019) (Solehudin et al., 2024) (Yuliafitri et al., 2020). From a policy perspective, comparative research between Muslim-majority countries underscores the pivotal role of clear governmental regulation and regulatory support in the successful implementation of sharia hotel standards (Syara & Fauzan, 2023). For instance, Malaysia’s stringent regulations and active governmental oversight have been shown to bolster traveler confidence and reinforce the country's image as a Muslim-friendly destination (Harith et al., 2022). In contrast, Indonesia’s reliance on non-binding fatwas often leads to inconsistencies in policy implementation at the operational level (Solehudin et al., 2024).

The international discussion advocates for a multidisciplinary approach in the development of sharia hotels, encompassing regulatory, marketing, human resource management, and service innovation aspects (Nahidloh & Qadariyah, 2021). Cross-country collaboration, policy standardization, and consistent implementation of Islamic values are essential to enhancing the global competitiveness of sharia hotels and meeting the increasingly complex expectations of Muslim travelers (Chantarungsri et al., 2024)(Harith et al., 2022).

Limitations And Future Research

Our investigation has several limitations and potential directions. This study examines only Islamic lodging requirements and is limited to the hospitality sector in both countries. This focused approach may not fully capture the broader applicability of Islamic Attributes of Destination (IAD) in related areas, such as tour guides, travel agents, or hotel support. Second, the research compares only Indonesia and Malaysia. This limitation may restrict the generalizability of the results to other nations with a majority of Muslims or to regions where Islamic travel is increasing, such as South Asia (India and Pakistan), the Middle East, or North Africa.

This study compared Islamic hotel policies in Indonesia and Malaysia using the Islamic Attributes of Destination (IAD) framework. Both countries’ regulations—Indonesia’s Fatwa No.108/DSN-MUI/X/2016 and Malaysia’s MS 2610:2015—demonstrate alignment with the four IAD dimensions: worship facilities, Islamic facilities, general Islamic morality, and halal food. Malaysia’s standards are more detailed and binding, while Indonesia’s are concise and non-binding. The findings highlight that both regulatory approaches support the development of sharia-compliant hospitality, though differences in legal force and specificity remain. The results of this research have several practical implications. Hotel operators in both Indonesia and Malaysia should ensure that their facilities and services comprehensively meet all four IAD criteria to enhance Muslim traveler satisfaction and competitiveness in the hospitality sector. Policymakers can utilize the IAD framework to refine or develop more effective and enforceable sharia hotel regulations, ensuring that legal standards are both clear and applicable in practice. Collaboration with halal certification bodies and investment in staff training on sharia compliance and cultural sensitivity are recommended for hotel management to maintain high standards and foster trust among Muslim guests. Furthermore, emphasizing compliance with IAD standards in marketing strategies can strengthen brand positioning and appeal to the growing segment of Muslim tourists.