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Potential of Cash Waqf Linked Sukuk (CWLS) Model as Financing
Tool in Malaysia
Izni Nadirah Najmuddin
1*
, Amal Hayati Ishak
2
,
1
Akademi Pengajian Islam Kontemporari, Universiti Teknologi MARA, Cawangan Melaka
2
Akademi Pengajian Islam Kontemporari, Universiti Teknologi MARA, Shah Alam
DOI: https://dx.doi.org/10.47772/IJRISS.2025.910000544
Received: 26 October 2025; Accepted: 01 November 2025; Published: 18 November 2025
ABSTRACT
Cash waqf-linked sukuk (CWLS) is an innovation of Islamic social finance and an Islamic capital market
instrument that has been introduced in Indonesia for various purposes, including social and economic
contributions. Based on Indonesia’s experience and success in implementing CWLS for the benefit of society
and Indonesia's economy, it seems to be a practical practice in Malaysia as well. This is because Malaysia and
Indonesia have similarities in their communities and landscapes. Besides, Malaysia is quite familiar with and
popular in implementing cash waqf and sukuk in general. Hence, the introduction of CWLS stands a chance to
be accepted and practice in Malaysia in future. This financing tool aims to ease the collection of cash waqf funds,
and act as an alternative for waqf assets to be developed, instead of focusing on the traditional practice.
Therefore, this conceptual paper aims to discuss the potential of practising CWLS in the Malaysian context by
conducting a document and content analysis. In the end of the research, it can be concluded that there are
possibilities for CWLS to be implemented in Malaysia, which then assists in overcoming the issue of society,
specifically in financial segment, and how this is in-line with Malaysia’s commitment in achieving Sustainable
Development Goals (SDGs).
Keywords: Cash Waqf Linked Sukuk (CWLS), Islamic Social Finance, Islamic Capital Market, Sukuk,
Sustainable Development Goals (SDGs)
INTRODUCTION
Waqf possesses the potential to serve as a pivotal instrument within Islamic social finance if it is integrated with
Islamic capital market instruments [1]. Recently, the practice of CWLS for financing social-based institutions
and various project purposes has been widely used in Indonesia. The combination of Islamic social finance and
Islamic capital market instruments to finance a project has been accepted by regulators and project developers
in Indonesia. The earliest project that has been financed through this model is the Eye Hospital of Achmad Wardi
at Serang, Banten, Indonesia [2]. The success of this project has raised the possibility of implementing the same
model for other projects in future.
The practice of the CWLS model in Indonesia is practised, where the cash waqf is collected from the society and
is used to purchase the Islamic certificate issued by the government, known as Sukuk Negara[3]. The issuance
of sukuk by the government has secured the investment and gives the investor (the donor) security that the fund
contributed is being used wisely for a specific project agreed and planned by the Badan Wakaf Indonesia (BWI)
with the government. Hence, this investment and donation made through CWLS has put the donor in peace and
confidence that the project developed is managed wisely.
This confidentiality and trust from donors are important to ensure the continuity of contributions in the future.
Besides, unlike other investments in sukuk, the flexible practice in CWLS in contributing cash waqf funds
depending on the interest and targeted by the investors is one of the key features of CWLS itself. In CWLS, the
investor is given the choice to either use the coupon given from the issuance of sukuk (temporarily contribute)
for individual purposes, or to fully deliver the coupon for the utilisation of the social project that is being worked
on (permanently contribute) [4].The option is given as a benefit for the donor who chooses to invest in this
INTERNATIONAL JOURNAL OF RESEARCH AND INNOVATION IN SOCIAL SCIENCE (IJRISS)
ISSN No. 2454-6186 | DOI: 10.47772/IJRISS | Volume IX Issue X October 2025
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scheme, which serves as an interaction for the donor to decide which one is better for their investment activities.
Based on the case study of Indonesia’s practice in CWLS, it has proven to have a positive impact towards many
parties involved in CWLS. The investors are capable of getting a secure investment, while at the same time being
able to achieve spiritual goals in helping those in need through the social projects that have been planned.
Whereas the project developer will have the capability to ensure the project is making timely progress, with
sufficient funds received throughout the collection. In addition, the society as the beneficiary will have the
opportunities to benefit from the projects that have been built through the fundraising made using this CWLS.
Therefore, with CWLS's ability to provide comprehensive benefits not only to the beneficiaries but also to all
stakeholders, this model is worthy of emulation and continuation by other institutions and countries.
Hence, this paper aims to overview of the potential of cash waqf-linked sukuk to be implemented in the
Malaysian context. Throughout this paper, the current practice of Indonesia in CWLS and Waqf Shares in
Malaysia will be discussed and relate how these two examples have proven to be a great factor for the practices
of CWLS in Malaysia in the future.
LITERATURE REVIEW
Cash Waqf-Linked Sukuk in Indonesia
Indonesia region, which is known as a country with a major Muslim population of 245 millions, consist of 87%
of Indonesian population [5] has actively developing Islamic finance instruments in their daily lives. This has
been proven with various instruments that have been introduced in Indonesia, aiming to encourage the growth
of Islamic Social Finance. Instruments such as the Dompet Dhuafa and Cash Waqf Linked Sukuk (CWLS) have
indicates the focus of Indonesia’s economy is currently shifting towards Islamic social finance instruments.
The Cash Waqf-Linked Sukuk, or CWLS was first introduced in Indonesia in March 2020 by the Government
of Indonesia through the Ministry of Finance in collaboration with Bank of Indonesia, the Indonesian Waqf
Board (BWI), and Islamic financial institutions [6] .Until 2020, Indonesia has issued two series of CWLS:
Institutional Wakaf Sukuk (SW001) for institutional investors and Retail Wakaf Sukuk (SWR001) which targets
individual investors. The government is also preparing the issuance of Retail Sukuk (SR) which has been opened
to investors from August 22, 2025. The series and continuous issuance of CWLS made by the government has
proven the commitment and support from the government in ensuring the success of this instrument [7] .
As a financial instrument that integrates shariah principles and fiscal policy, CWLS shows how innovation can
respond to social and economic challenges. By leveraging the large cash waqf potential, CWLS is able to
promote equal welfare and inclusive development [8]. According to Ismal (2022), the implementation of CWLS
model not only promises the benefits for the social needs, but also give the benefits to the government,
specifically the Ministry of Finance to lower the budget spending, especially to provide public facilities [9]. This
can be done as cash waqf is a zero-cost fund financing instrument, while the coupon paid by the government is
simply a form of an appreciation to the donors (investors) that contribute.
Through the benefits offered with the implementation of CWLS in social and economy purposes received by
Indonesia as been mentioned above, hence this instrument might be a potential instrument that can also benefit
other countries that have similar interests and Islamic finance industry, such as Malaysia itself [9].
Waqf Shares in Malaysia
In Malaysia, the integration of Islamic social finance and Islamic capital market instruments has also occurred,
through the introduction of waqf shares. Waqf shares is an innovative form of modern waqf designed to
encourage public participation in developing Islamic endowments through share ownership rather than cash or
property donations.
Waqf shares refer to shares or equity units contributed or dedicated as waqf by individuals, institutions, or
corporations. The dividends or profits generated from these shares are channeled for charitable and social
purposes, in accordance with Shariah principles. Among the agencies that have conducted this scheme are
INTERNATIONAL JOURNAL OF RESEARCH AND INNOVATION IN SOCIAL SCIENCE (IJRISS)
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Perbadanan Wakaf Selangor (PWS) and Majlis Agama Islam Negeri Johor (MAINJ).
Saham Wakaf Johor which has been introduced in Johor, has conducted a project where it allows the contribution
of waqf shares with a value as low as RM10 per unit to the Johor Islamic Religious Council, where the purpose
and benefits will be giving back to Muslim with various society projects [10] .
METHODOLOGY
This paper employed a qualitative methodology, using document and content analysis research approaches. The
data was analysed through the 2021 annual report of Cash Waqf Linked Sukuk as the primary reference in
reviewing the success factors that facilitate the implementation of CWLS in Indonesia. Subsequently, the
discussion on the potential and feasibility of practising CWLS in Malaysia is presented through selected articles
that specifically research CWLS. Since the aim of the discussion is within the Malaysian context, the selected
papers are those that conducted research in Malaysia, which form the sample for this discussion. Most of these
papers focus on the challenges on conducting it, instead of the potential in implying CWLS.
The discussion on this paper will first, be focusing on the issues of waqf assets in Malaysia and challenges faced
by Waqf Institutions, specifically in financial segment, in assisting the underprivileged society. The inter
relationship between issues of waqf assets and issues face by the Waqf Institutions has lead to the need in having
an alternative of financing tool in overcoming the issues.
Hence, the discussion is then focusing on how Cash Waqf-Linked Sukuk (CWLS) should be practiced in
overcoming the issues. Next, the potential risks and challenges that may occur in implementing it in Malaysia
are also being discussed, which then being answered through the case study from Indonesia perspective as the
source in answering the risks mentioned.
FINDINGS
Issues of Waqf Assets in Malaysia
The huge amount of waqf assets that has been left unattended was not a new issue. This continuous issue has put
waqf institution in need to have a long-term planning on fully utilized and manage these waqf assets wisely.
Until 2020, the valuation of waqf assets is estimated to surpass RM1.3 trillion. Besides, it is recorded that in
2023, it was reported that only about 13% of waqf land was utilized, and other studies have reported even with
a lower figures [11]. This has proven a low rate of waqf utilization, which made the growth of waqf is slow in
progress. This is contradict with the history and successful made on this instrument during the Uthmaniyyah Era,
where the waqf assets has been utilized productively, for various purposes.
Issues faced by Waqf Institutions
According to Sulistyowati et al, lack of funding is among the eight issues of waqf and non-governmental
healthcare institutions in providing healthcare services [12]. This lack of funding issues not only occur in the
healthcare sector, as there are many other waqf projects that have been developed and have to temporarily stop
due to the insufficient funds. This indicates issue of funding is the biggest concerned in ensuring the project can
be continued in a long-term [13].
Each waqf institutions has different practices in getting funds and financing for the institution to maintain their
business and projects in a long run. Besides depending on public fund received to operate the institution, there
are also other sources that Waqf Institutions rely on as sources of income in operating the business activities.
Potential of Waqf-Sukuk to be Viable in Malaysia
Securities Commission Chairman, Dato’ Seri Dr. Awang Adek Hussin emphasized that Islamic social finance
has gained traction worldwide, while waqf holds the potential to be an essential instrument of Islamic social
finance. These two instruments can play a crucial role in achieving social-economic development goals, which
include addressing poverty, unemployment, and financing healthcare, education and infrastructure
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development[14]. Based on the document analysis done in this study, it can be concluded that there are several
features that make waqf-sukuk potentially viable in Malaysia context:
The acceptance of cash waqf as an Indicator in Practicing CWLS in Malaysia
The potential of cash waqf in Malaysia has been discovered previously, which led to the existence of fatwa on
permitting the practice of cash waqf in Malaysia. This practice has been used widely in Malaysia in each state
for various purposes. This instrument has given a huge impact towards the growth of waqf assets in Malaysia in
general, as it give a flexibility for individuals to contribute in waqf through cash, which then led to a positive
impact towards the waqf management and authority to widen the potential of waqf assets.
This has been proven by many cases and projects developed in Malaysia, which indicate the growth of cash
waqf. By having this momentum and acceptance among the society in the practice of cash waqf, the possibility
of Cash Waqf Linked Sukuk in Malaysia is not far behind and has the potential to be implemented in Malaysia
if every party involved play a significant function and role together.
This is in-line with the recommendation stated by Jalaluddin et.al that cash waqf has the potential to be
developed as long as it can be managed optimally and suggested for the involvement of other parties from various
circles to provide understanding and information on cash waqf to shift people’s views on cash waqf[15]. Besides,
it is believed that by having support from the private sector, involving nazhir, Islamic financial institutions,
NGOs, practitioners and experts in waqf field hand in hand with the government and waqf institutions, the growth
and development of cash waqf can be explored and discovered in betterment.
Regulatory/Institutional frameworks for Waqf and Islamic Finance
In Malaysia, Waqf An-Nur Corporation (Wancorp) has first introduced and become the innovator of implying
waqf shares concept as an effort in innovating the productive of waqf. This has indicated that these two
instruments of the capital market and social finance can be integrated in producing a more productive element
to attract investors and the public in contributing in Waqf.
In addition, the introduction of Waqf-Features Fund Framework by the Securities Commission (SC) Malaysia,
in 2020 has allowed and strengthened the potential of Islamic funds, such as unit trusts, to have waqf features.
This framework is targeted to broaden the range of innovative Islamic capital market products and provide the
public access to Islamic funds that allocate whole or part of the fund’s returns towards socially impactful
activities through waqf [14]. SC chairman, Datuk Seri Dr Awang Adek Hussin has also added that the framework
has effectively fostered enhanced collaboration between Islamic Fund Management Companies and State
Islamic Religious Councils, as there has been a notable increase in collaborative efforts by all stakeholders in
exploring and identifying the potential inherent in waqf asset development. Through this formation, SC has
successfully initiated six waqf features funds, where the accumulated fund has reached RM46.7 million as of
December 2022 [16]. Besides, this framework has also expanded the Socially Responsible Investment (SRI),
Sukuk and Bond Grant Scheme to include sukuk issued for waqf asset development [14]. This has also emphasize
the potential of CWLS to be practised in the Malaysian context.
Previously, back in 2014, the potential of Waqf assets to be combined with Islamic Capital Market (ICM) in
Malaysia has been explored, when SCM itself proposed the guidelines on the governance of the Islamic Capital
Market to comply with Waqf features. The guidelines has also emphasised that these two assets have the viability
to be integrated and create a huge innovation towards the waqf concept [17]. In the end, the existence of a legal
framework that discusses specifically in Waqf sukuk matters will help the acceptance and progress of Cash Waqf
Linked Sukuk in Malaysia.
This effort is not possible to be made, as in Malaysia currently, AIBIM has early introduced the guidelines that
can be referred by Islamic banks in managing the waqf collection and contribution, with the presence of Code
of Governance and Transparency for Waqf Fund that have first been introduced in 2017[18].
Therefore, with the current practice of waqf and capital market instrument guidelines, the possibility to produce
a strong and solid guidelines that combine both instrument, specifically waqf-sukuk, will widen the practice of
productive waqf through Islamic capital market instrument.
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Demand and Societal Needs
The tremendous amount of waqf assets in Malaysia has put Malaysia as potential region to develop more in waqf
projects. According to data from Yayasan Wakaf Malaysia and the Department of Wakaf, Zakat and Hajj
(JAWHAR), merely 13 percent or approximately 30,000 hectares of waqf land in the nation is developed as of
2019, and such land is traditionally designated for religious institutions or educational establishments [19], which
indicates the potential of waqf assets.
Globally, there is demand for sustainable finance and social finance, where the questions on how this instrument
can assist in societal purposes have increased widely. This demand is based on the features of this investment
instrument that can have an impact on society in a long term.
Two of the examples that are widely used in Malaysia include the Environmental Social and Governance (ESG)
and Green Sukuk. These two instruments have also proven the data of huge numbers of contribution and
collection among the investors, which indicates the introduce of this instrument has create a potential of waqf-
sukuk as well. Through the implementation of responsible and sustainable investment methodologies, which
integrate environmental, social, and governance (ESG) criteria, is fundamental to ethical best practices, thereby
harmonizing financial decision-making with prevailing standards whilst preserving the ethical tenets inherent in
Waqf operations [20].
Besides, the social issues that occurred nowadays, such as the lack of funding for education purposes, healthcare
needed and infrastructure has require a new long-term funding sources to overcome the issues. Hence, the
researcher believes the introduction of Waqf-sukuk could help bridge the funding gaps that occur. In addition,
this effort is also in line with Sustainable Development Goals (SDGs), which were introduced by the United
Nations.
According to Awang Adek Hussin, the Waqf instrument has the potential to help drive Islamic social finance,
and achieve socio-economic development goals in addressing poverty, unemployment, as well as financing of
healthcare, education, and infrastructure development [14]. He added that waqf holds substantial promise for
utilisation in the attainment of socio-economic development objectives aimed at alleviating poverty, reducing
unemployment, and financing healthcare, education, and infrastructure advancements.
In addition, there is also precedent elsewhere, where Indonesia has issued Cash Waqf Linked Sukuk (CWLS)
retail sukuk-waqf to fund social and empowerment programs [21].
The alignment of Waqf Sukuk with Sustainable Development Goals (SDGs)
The introduction of waqf-sukuk instrument can lead to a bigger picture in fulfilling the needs of society in
Malaysia. Issues such as the lack of funding the infrastructure and project, healthcare development, education
needed and poverty issues are in need of other alternatives that are more sustainable and efficient.
The goals that have been highlighted by UN to achieve not only in Malaysia, but globally, such as Goal 1 on
reducing poverty issues, Goal 3 highlighting the need to achieve good health and well-being among the society,
Goal 4 focusing on quality education [22].
Challenges and Restrictions in Implying Waqf-Sukuk
Despite the potential of implying Cash Waqf-Linked
Sukuk in Malaysia, there are also significant hurdles in implying this instrument due to several factors:
Legal and Regulatory Challenges
Each Malaysian state has its own waqf legislation, under the supervision of State Islamic Religious Council
(SIRC), which act as the sole trustees of all waqf properties in Malaysia [23]. With a different legislation in
Islamic matters in each state, which include the management of waqf has put the effort in introducing CWLS
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might face some setbacks, due to lack of uniformity or comprehensive laws for waqf, especially in practising
cash waqf and for waqf assets [24].
Hence, the different legislation in each state in answering the questions of ownership, transferability and the
acceptance of cash waqf need to be standardized on first hand before moving forward in implementing CWLS
in Malaysia. This is a vital effort to be done, as the uniformity of legislation in one country can ease the possibility
to purchase the issuance of sukuk by the government, under one solid and single waqf institution.
In addition, it is vital to introduce a new legislation that fully discuss the features of CWLS. The combination of
waqf and sukuk structures have two different rules and regulations, hence by having one policy and guidelines
on this matter, will help to introduce and implement of CWLS in Malaysia [25].
Operational and Governance Issues
To imply waqf sukuk instrument, the understanding of the full operation of this instrument needs to be well-
known among the waqf managers. The understanding of management and policy of Waqf Sukuk need to be
clarified among the waqf institutions to ensure the smooth management and production of CWLS. A thorough
comprehension of cash waqf and sukuk is essential, without it, the efficient operation of this financial instrument
may become impeded, ultimately compromising its long-term efficacy. Consequently, a pivotal measure that
waqf institutions must undertake to facilitate the effective administration of CWLS is the recruitment of
personnel possess expertise in the domains of shariah and the management of the Islamic capital market.
In addition, it is important to have a policy standard that discuss the guidelines of waqf sukuk matters. The
guidelines on governance, transparency, and accountability need to be highlight to ensure the efficiency of
CWLS operational. It is vital to avoid a mismanagement that may occur in waqf institutions, which then may
led to erosion of donor trust [24].
Case Study and Lesson Learned from Indonesia
The issues and challenges mentioned above have already been experienced by Indonesia in introducing CWLS
previously. However, with efficient and productive actions taken by the government and stakeholders that are
responsible for the formation of CWLS, finally, this instrument has been increasingly practiced and has produced
many projects that aim to help the community.
One of the successful projects and serves as an exemplary model of CWLS is the establishment of Achmad
Wardi Eye Hospital [2]. Through the collaborative effort with Dompet Dhuafa, the Badan Wakaf Indonesia
(BWI) has adeptly overseen waqf assets, facilitating the construction of the Achmad Wardi Eye Hospital located
in Serang, Banten. On the 21
st
of October 2020, the Vice President of Indonesia, K.H. Ma’ruf Amin, officiated
the opening of the Retina and Glaucoma Centre at the Achmad Wardi Eye Hospital, which was constructed
through a cash waqf that was efficiently managed and invested in CWLS, amounting to a value of
Rp50,849,000,000 [26].
Pursuant to a private placement, the CWLS was issued on the 2020 by the Ministry of Finance of the Republic
of Indonesia, marking it as the inaugural waqf-linked sukuk instrument. Besides, with involvement from the BNI
Syariah, acting as the stakeholder to provide financing secured by the CWLS coupon, has led to the successful
of CWLS [26]. This adept management of the Achmad Wardi Eye Hospital exemplifies that professional and
accountable waqf asset management should be emulated in other regions, potentially yielding substantial benefits
for public welfare.
Hence, it can be concluded that the practice of CWLS in Malaysia, is not possible to be done. By having
government support through the standardisation of legal and regulations on CWLS, and efforts to introduce the
issuance of CWLS, the presence of CWLS can be firmly established in the future.
CONCLUSIONS
This paper addresses the research problem of assessing the impact of implementing Cash Waqf-Linked Sukuk
(CWLS) as the alternative financing tool in achieving the Sustainable Development Goals (SDGs) that have
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been highlighted by the United Nations. Through the integration of waqf and sukuk in CWLS, indicates the
possibilities of waqf to be combined with another financial instrument in creating a potential and bigger prospect
of Islamic financial instruments in the future. By having a bigger picture and variety of financial instruments in
this field, more social issues and problems can be conquered. it could not be denied, the present efforts that have
been done by the authorities has create a good social impact, however, there are still more area need to be
concerned. Thus, the innovation of Islamic social finance instruments need to be done. This is in-line with
Griffiths and Tan (2007), who agreed and highlighted that direct aid or charity had failed to eradicate poverty,
and suggested creating a sustainable way of alleviating poverty. Hence, this can be achieved through the practice
of Cash Waqf Linked Sukuk (CWLS) just as been done by Indonesia. Even so, the support and synergy among
the stakeholders are the key features to ensure the long-term success of this instrument.
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