Cybersecurity Compliance In Indonesia: Key Legal Requirements For Electronic System Providers.
As businesses increasingly rely on digital technologies, cybersecurity has become a key compliance issue in Indonesia. Electronic system providers (“ESPs”) are subject to a range of legal obligations designed to safeguard electronic systems, protect personal data, and ensure effective responses to cyber incidents.
Indonesia’s cybersecurity framework is primarily governed by the Electronic Information and Transactions Law (“EIT Law”), Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions (“GR 71/2019”), the Personal Data Protection Law (“PDP Law”), and regulations issued by the National Cyber and Crypto Agency (BSSN).
Security and Risk Management Requirements
Under the EIG Law and GR 71/2019, ESPs must ensure their electronic systems are reliable and secure through appropriate physical and technical safeguards. They are also required to maintain documented security procedures, implement performance management measures, establish business continuity plans, and protect their systems against disruption, failure, and data loss.
GR 71/2019 also requires ESPs to conduct risk assessments and implement measures to identify, manage, and mitigate cybersecurity risks.
Internal Policies and Personal Data Protection
ESPs must establish internal policies governing information security and personal data protection in accordance with GR 71/2019 and Ministry of Communication and Information Regulation No. 20 of 2016.
Where personal data is processed, the PDP Law requires organizations to maintain the confidentiality, integrity, and availability of personal data by implementing technical and organizational security measures appropriate to the nature of the data and the risks involved.
Audit Trails, Personnel and System Testing
To support oversight, investigations, and dispute resolution, ESPs are required to maintain audit trails recording electronic system activities, including personal data processing.
Organizations must also provide appropriate training for personnel responsible for cybersecurity and personal data protection.
In addition, GR 71/2019 requires electronic systems to undergo objective feasibility testing to ensure they satisfy applicable security and operational requirements, although the regulation does not prescribe detailed technical testing standards.
Incident Response and Reporting
Indonesia’s cybersecurity regulations also impose obligations relating to cyber incident preparedness and response.
ESPs are expected to establish an incident response capability, typically through a dedicated incident response team responsible for managing cybersecurity incidents, coordinating recovery efforts, and engaging with relevant stakeholders.
Where a cyber incident occurs, ESPs may be required to:
- report incidents to the relevant authorities;
- notify regulators and affected individuals where a personal data breach has occurred under the PDP Law;
- share incident-related information where required to support coordinated responses and reduce future risks; and
- implement contingency plans addressing threat scenarios, recovery procedures, communication protocols, and reporting obligations. These contingency plans must be evaluated annually and tested at least once every two years.
Key Cybersecurity Compliance Obligations
In summary, ESPs operating in Indonesia should ensure they:
- maintain secure and reliable electronic systems;
- conduct cybersecurity risk assessments;
- implement internal security and data protection policies;
- protect personal data through appropriate technical and organizational measures;
- maintain audit trails;
- provide cybersecurity training for relevant personnel;
- conduct electronic system feasibility testing;
- establish an incident response capability;
- comply with cybersecurity and personal data breach notification requirements; and
- maintain and regularly test cybersecurity contingency plans.
As Indonesia’s cybersecurity and data protection framework continues to evolve, organizations should regularly review their compliance programs to ensure they meet current legal and regulatory requirements.
Read the full Indonesia chapter of the ICLG Cybersecurity Laws and Regulations 2026 global legal guide.
Download the PDF version of the chapter here.
Further Reading
This article is adapted from the Indonesia chapter of International Comparative Legal Guide (ICLG) – Cybersecurity Laws and Regulations 2026, authored by SSEK Law Firm partners Winnie Yamashita Rolindrawan and Nico Angelo Putra Mooduto, and associate Agung Kurniawan Sihombing.
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.
