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Indonesia currently lacks a comprehensive central regulation governing the use of artificial intelligence (AI) across business sectors. The existing legal framework primarily consists of Ministry of Communication and Information (MOCI) Circular Letter (CL) 9/2023, regarding the Ethics of Artificial Intelligence.

This circular letter serves as a non-binding guideline for the use of AI by business entities. It offers ethical principles for AI implementation, emphasizing:

  • inclusivity;
  • humanity;
  • privacy and personal data security;
  • accessibility;
  • transparency;
  • credibility and accountability;
  • personal data protection;
  • sustainable environmental development; and
  • IP protection.

Sector-specific AI guidance

In addition to MOCI CL 9/2023, the Financial Services Authority (OJK) has issued the Ethical Guideline on the Responsibility and Reliability of AI. This guideline specifically targets companies in the financial technology sector, aiming to:

  • ensure responsible AI use; and
  • mitigate potential risks arising from AI integration in their operations.

Separately, the Press Council – an independent agency that was established to foster the development of a free, professional and responsible press in Indonesia – released Press Council Regulation (PCR) 1/2025 regarding Guidelines for the Utilization of Artificial Intelligence in Journalism. However, as the Press Council is not a government agency, this regulation applies solely to Indonesian media companies.

Which bodies are responsible for enforcing AI laws and regulations in Indonesia?

Indonesia does not currently have a dedicated regulatory body that specifically oversees AI. The regulator for AI companies depends on the sector in which the company operates. Generally, AI companies providing services in the technology sector fall under the supervision of the Ministry of Communication and Digital Affairs (MOCDA) – formerly MOCI. Companies operating in other sectors are subject to the relevant sectoral regulators. For instance:

  • banks are regulated by the OJK; and
  • fintech companies are regulated by Bank Indonesia.

Regulatory authorities in Indonesia typically have the power to impose sanctions on companies under their jurisdiction. Sanctions are generally applied on a case-by-case basis. In most instances, regulators begin by issuing a warning letter in response to non-compliance with applicable laws and regulations. If the company fails to address the issue, the regulator may impose more severe penalties at its discretion.

What can businesses expect next?

Overall, the current legal landscape for AI in Indonesia consists mainly of guidelines rather than enforceable regulations. A comprehensive legal framework, including possible sanctions, has yet to be established. The MOCDA has indicated that draft regulations concerning AI are currently being developed with input from stakeholders and industry players, with completion targeted for the third quarter of 2025.

As a comprehensive regulation on AI has yet to be issued in Indonesia, businesses currently follow the provisions set out in MOCI CL 9/2023. This circular letter sets forth the key principles and responsibilities that companies involved in AI development and deployment should observe when operating in Indonesia.

The vice minister of communication and digital affairs has further explained the government’s approach to drafting future AI regulations, which is built on three main pillars:

  • Policy: The government aims to establish a general AI regulatory framework applicable across sectors, while allowing each sector to develop its own specific regulations as needed.
  • People: The focus is on cultivating human resources capable of advancing Indonesia’s AI ecosystem.
  • Platform: The government emphasizes positioning Indonesia as a collaborative space where industry stakeholders can work together to drive the development of the national AI landscape.

Read the full Indonesia chapter of the Mondaq Artificial Intelligence Comparative Guide.

Download the pdf version of the chapter here.

Further Reading

Indonesia Proposes Overhaul of Copyright Law with Focus on Digital Content and Emerging Technologies

This article is adapted from the Indonesia chapter of the Mondaq Artificial Intelligence Comparative Guide, authored by Winnie Yamashita Rolindrawan and Qafaldi Putra Ismayudha of SSEK Law Firm. This publication is intended for informational purposes only and does not constitute legal advice. Any reliance on the material contained herein is at the user’s own risk. All SSEK publications are copyrighted and may not be reproduced without the express written consent of SSEK.

WRITTEN BY

For further information, please contact:

Winnie Yamashita Rolindrawan – SSEK,
winnierolindrawan@ssek.com

Winnie Yamashita Rolindrawan - SSEK. Winnie Yamashita Rolindrawan holds a Bachelor of Laws in economic law from the University of Indonesia and a Master of Science in communications management. She also earned an LL.M. and a Business Law Certificate from UC Berkeley.

Winnie Yamashita Rolindrawan received her Bachelor of Laws in economic law from the University of Indonesia in 2002. In 2007, she earned her Master of Science from the Faculty of Social and Political Sciences at the same university, majoring in communications management. In 2016, Winnie received her Master of Laws (LL.M.) from the University of California, Berkeley, School of Law, where she also earned a Business Law Certificate from the Berkeley Center for Law and Business.

Winnie joined SSEK in 2007 and has represented major domestic firms and multinational companies in a variety of transactions. She has worked on numerous projects involving M&A, financial services and fintech, data privacy, pharmaceuticals and healthcare, corporate and commercial matters, foreign investment, e-commerce, and real estate and property (particularly hotels).

Her projects in the fintech sector include acting as Indonesian counsel to Didi Chuxing in the acquisition of a substantial stake in Grab Inc., a transaction valued at over US$1 billion, and acting as lead Indonesian counsel to Mastercard as the lead investor in the series B funding round of Digiasia, an Indonesian fintech startup. Winnie advises clients on all aspects of fintech and payment systems (including e-money, remittances, payment gateways and switching), from obtaining the relevant licenses to cross-border fintech M&A transactions and navigating complex regulatory, legal and commercial challenges to ensure compliance with the relevant fintech and payment system regulations of Indonesia’s Financial Services Authority (OJK) and Central Bank (Bank Indonesia).

In the healthcare sector, Winnie has represented pharmaceutical companies, including manufacturers and distributors, in providing practical solutions for their day-to-day operations, corporate and commercial contracts, and specific regulatory issues.

Prior to joining SSEK, Winnie worked at another prominent corporate law firm in Jakarta, where she was involved in various capital market transactions including IPOs, bond issues and rights issues. She helped handle several debt restructuring projects involving the Indonesian Bank Restructuring Agency (IBRA), an independent government agency established in response to the Indonesian financial crisis.

Winnie was also an associate procurement expert for an Asian Development Bank-Indonesian Ministry of National Development Planning (Bappenas) project, where she developed and drafted model national procurement documents.

Winnie is a licensed attorney and a member of the Indonesian Advocates Association (Peradi). She participated in the 2014 Academy of American and International Law, sponsored by the Southwestern Institute for International and Comparative Law in Dallas, Texas.

Having spent her childhood in Hamburg, Germany, she speaks German in addition to English and her native Indonesian.

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