Reframing Outsourced Labour Protections in Sri Lanka: A Comparative Analysis across Southeast Asian Jurisdictions

This paper explores the evolving legal landscape of outsourced labour in Sri Lanka, focusing on the precarious position of “sandwich workers”—individuals contracted by third-party agencies but operationally managed by principal employers. Despite the rise of outsourcing as a strategic HR practice, Sri Lanka lacks a comprehensive regulatory framework to safeguard these workers' rights. Drawing upon doctrinal analysis and comparative legal research, the study evaluates statutory frameworks in Malaysia, Indonesia, and the Philippines to identify transferable best practices. The findings reveal significant legislative gaps in Sri Lanka's labour law, particularly in employer liability, contract registration, and worker protections. This paper proposes a restructured legal approach to balance organisational flexibility with equitable labour standards, aiming to harmonise business needs with international human rights obligations.