Over the past two years, the Government of Indonesia has launched several significant initiatives to strengthen digital safety, including specific measures aimed at protecting children within the gaming ecosystem.
In early 2024, through Presidential Regulation No. 19 of 2024, dated February 12, 2024, regarding the Acceleration of the National Game Industry, the Government established a National Game Industry Acceleration Team composed of representatives from relevant ministries and agencies to implement the national game industry acceleration program.
This commitment is further reflected in the issuance of Minister of Communications and Informatics (now Minister of Communication and Digital Affairs or “MOCDA”) Regulation No. 2 of 2024, dated January 24, 2024, regarding Game Classification (“MOCDA Reg. 2/2024”).
In the same vein, Government Regulation No. 17 of 2025, dated March 27, 2025, regarding the Governance of Electronic System Implementation in Child Protection (“GR 17/2025”) was enacted this year to further strengthen child protection in the digital environment.
Indonesia Game Rating System (“IGRS”) under MOCDA Reg. 2/2024
MOCDA Reg. 2/2024 introduces a two-year transition period ending in January 2026, during which game publishers are required to classify their games through a self-assessment process based on content and the appropriate user age group. The regulation aims to help publishers market their products in a manner consistent with the nation’s cultural values and norms, support users in selecting age-appropriate games, and assist parents in guiding children’s game consumption.
Article 8 of MOCDA Reg. 2/2024 outlines the game classification framework, setting out user age groups determined by content categories such as alcohol, drugs, violence, blood and mutilation, language, character appearance, horror elements and online interactions:
- ages 3 years and older;
- ages 7 years and older;
- ages 13 years and older;
- ages 15 years and older; and
- ages 18 years and older.
Games rated 3+ and 7+ must be used under parental supervision, while those rated 13+ and 15+ must include parental guidance when used by children.
Taking the above into account, and as required under Articles 4 and 5 of MOCDA Reg. 2/2024, game publishers must first register as a Private Electronic Service Provider (“ESP”) and then independently conduct the game classification. Publishers must also display the classification results (after they pass the conformity test) on the game’s description, packaging and advertisements.
The independent classification process is regulated under Articles 6, 7, 16 and 18 of MOCDA Reg. 2/2024. It is carried out by completing the game description form, uploading game clips (content and gameplay simulation), and answering the classification questionnaire through an online system available on the official IGRS platform (https://igrs.id/). The process generally consists of the following steps:
The verification is carried out by Game Classification Examiners, which are qualified business entities authorized to perform conformity assessments and officially designated by the MOCDA. These examiners must conduct the assessments in accordance with the standards established by the Minister and issue the resulting conformity assessment, as required under Article 16 of the regulation.
Pursuant to Article 14 of MOCDA Reg. 2/2024, a game cannot be classified if it contains any of the following prohibited content:
- displays and/or features pornography;
- constitutes gameplay based purely on chance or any form of gambling that may use legal payment instruments, foreign currency, electronic money or intangible digital commodities that can be traded and converted into legal payment instruments, and that provide/support/facilitate a cash-out feature; and/or
- violates statutory regulations.
Following the completion of the classification process, game publishers must take the following actions when marketing their classified games in Indonesia:
- include the results of the independently conducted game classification on the game’s description, packaging and advertisements;
- adjust the game’s packaging design in accordance with classification results;
- ensure that advertising content aligns with the classification results;
- display the parental guidance requirement on the game’s packaging and advertisements for games classified in the 3+ and 7+ age categories; and
- display the parental supervision requirement on the game’s packaging and advertisements for games classified in the 13+ and 15+ age categories.
A key feature of MOCDA Reg. 2/2024 is its detailed enforcement mechanism, which authorizes MOCDA to impose a range of administrative sanctions for non-compliance, depending on the severity of the violation. A game publisher’s failure to display the official classification on the game’s description, packaging or promotional materials may result in a written reprimand, temporary suspension or termination of access for Indonesian users.
In addition, MOCDA may block access to a game if the publisher fails to conduct the required self-assessment before promoting the game, advertises an unclassified game or does not reclassify the game when instructed by MOCDA.
Intersection Between IGRS and Child Protection in the Digital Sphere under GR 17/2025
Indonesia’s regulatory landscape for child protection in the digital environment is becoming increasingly comprehensive, with GR 17/2025 (discussed in detail here) and MOCDA Reg. 2/2024 operating in parallel to regulate children’s exposure to online game content.
These two regimes overlap in several key respects. GR 17/2025 treats games as part of a broader category of digital products, services, and features that children are likely to encounter, thereby triggering obligations related to safety-by-design, parental authorization and heightened protections for children’s data and privacy. Meanwhile, the IGRS system under MOCDA Reg. 2/2024 imposes an additional layer of requirements, including mandatory age classification, compliance with content-rating criteria and clear display of the assigned rating.
Together, these frameworks create a dual compliance structure that integrates child-protection duties with content-classification obligations. Game publishers must therefore navigate both regulatory layers to meet Indonesia’s evolving standards for safeguarding children in the digital environment.
Specifically, GR 17/2025 defines “child” as any person under the age of 18. Under Article 20(2), ESPs must establish minimum age categories for access to digital content or products (3-5, 6-9, 10-12, 13-15, and 16-17 years), calibrated to the level of risk associated with the content, including exposure to violent, pornographic or otherwise harmful content.
One of the most significant areas of intersection between the two regimes concerns age verification and parental involvement. Similar to Article 8 of MOCDA Reg. 2/2024, GR 17/2025 requires ESPs to obtain verifiable consent from a parent or legal guardian before providing children access to any digital product, service or feature. This consent must be obtained proactively and presented in a transparent manner so that parents understand the nature and implications of the access being granted.
GR 17/2025 further outlines situations where an opt-out system may apply. For users under 17, ESPs must wait up to 24 hours for parental or guardian consent before providing access; no access may be granted during this waiting period, and failure to obtain consent requires the ESP to block access entirely. For 17-year-olds, ESPs may allow temporary access, but the parent or guardian must be given a six-hour window to object; if no objection is submitted, the access can continue. If the parent or legal guardian refuses to provide consent, any consent previously given by the child is rendered to be null and void, and the ESP is required to promptly delete all personal data of the child from its system. (5 December 2025)
