This article examines directors' personal liability in corporate bankruptcy under Article 104 of the Indonesian Company Law and compares it with the Business Judgment Rule (BJR) for State-Owned Enterprise (SOE) directors after the 2025 SOE reforms. It uses normative or doctrinal legal research through statutory, conceptual, and functional comparative approaches. The analysis shows that Article 104 neither imposes strict liability nor reverses the burden of proof wholesale. A claimant must establish the Article 104(2) trigger, including the causal connection between director fault or negligence, bankruptcy, and an insufficient bankruptcy estate. Article 104(4) then places an exculpatory burden on each director to demonstrate good faith, due care, absence of conflict, and preventive action. The 2025 SOE reforms likewise do not create absolute immunity. Article 9F, introduced by Law No. 1 of 2025 and retained in the current framework, substantially mirrors BJR criteria already found in the Company Law, while Law No. 16 of 2025 deleted Article 9G and revised Article 4B. The principal issue is therefore not a direct contradiction between two liability regimes, but the need for harmonized interpretation and evidentiary standards that distinguish legitimate business risk from culpable managerial conduct.