Purpose: This study examines whether the Deferred Prosecution Agreement, an instrument developed to resolve corporate fraud, bribery, and money laundering cases in the United States, United Kingdom, and France, can be adapted into Indonesian criminal procedure to optimize recovery of state financial losses caused by corruption and economic crime.

Research Methodology: The research applies a normative juridical method combining comparative and conceptual approaches, examining statutory materials, international instruments, and doctrinal literature on deferred prosecution, corporate criminal liability, and restorative justice.

Results: Indonesia possesses substantial normative grounds for adopting a Deferred Prosecution Agreement, anchored in its ratification of the United Nations Convention against Corruption, the prosecutorial opportunity principle already recognized in national procedure, and compatibility with Pancasila values emphasizing corrective rather than purely retributive justice. Significant obstacles nonetheless persist, including the absence of explicit statutory authorization, the risk of prosecutorial abuse of discretion, and a legal culture still oriented toward retributive punishment.

Conclusions: An Indonesian model should combine the prosecutorial flexibility of the American approach with the judicial oversight of the British model and the compliance-monitoring rigor of the French approach.

Limitations: The doctrinal design has not been tested against empirical prosecutorial data or comparative field interviews.

Contributions: The study offers a synchronization framework linking prosecutorial discretion, judicial supervision, and corporate governance reform relevant to legislative drafting for state loss recovery.