Regulation of delay interest varies greatly under different legal frameworks, reflecting different statutory, economic, and ethical considerations. Comparative legal analysis of delay interest regulation under the law of Jordan, the UK law, and AAOIFI Shari’ah standards is presented here, evaluating the efficiency in balancing debtor rights, creditor protection, and economic stability. Under the law in Jordan, delay interest is statutorily capped at 9%, offering debtor protection at the expense of creditor flexibility. Under UK law, the Late Payment of Commercial Debts (Interest) Act 1998, the law is market-based, with statutory interest charged to induce discipline in finance. Under AAOIFI Shari’ah standards, Riba (usury) is prohibitive but payment for actual loss is acceptable, in line with Islamic finance principles.

Through comparative jurisprudential analysis, legislative review, and doctrinal examination, this research determines the most salient challenges and reform potential for each framework. It uncovers the legal rigidity in the Jordanian framework, the pro-creditor orientation in the UK law, and the ethical implications of AAOIFI standards. Legal hybridization is proposed by the research, with the suggestion for an adaptive delay interest model that integrates Shari’ah-compliant mechanisms for compensation, procedural simplifications, and tiered delay interest arrangements. Such reform would enhance creditor trust, economic efficiency, and ethical financial management.

This paper makes contributions to legal literature and policy-making by offering insight into the manner in which cross-border transactions navigate around competing delay interest laws. Research should follow by examining the economic implications of delay interest policies, judicial discretion during the enforcement process, and the international financial markets' compatibility with AAOIFI principles.