Indonesia - National AI Regulation

Overview

The Rancangan Peraturan Presiden tentang Kecerdasan Buatan is a two-part, executive-level package comprised of (1) a Buku Putih Peta Jalan Kecerdasan Artifisial Nasional (National AI Roadmap White Paper) and (2) a Perpres setting out ethics, safety and governance obligations for AI systems. The initiative, led by the Ministry of Communication and Digital (Komdigi), was opened for public consultation in August 2025 and the ministry reported submission of an izin prakarsa to the State Secretariat in late August–early September 2025. The stated purpose is to accelerate responsible AI development, align multi-stakeholder priorities, and provide a legal umbrella for sectoral regulators and government-led capacity building. For the consultation and download of the White Paper and ethics concept, see the Komdigi public notice and consultation materials. Komdigi: Konsultasi Publik Peta Jalan KA. ([portal.komdigi.go.id](https://portal.komdigi.go.id/kanal-publik/berita-kini/9526?utm_source=openai))

Definitions

The draft defines key terms to reduce interpretive ambiguity for implementation. Definitions typically include: 'Artificial Intelligence' (KA) as computational systems that perform tasks commonly associated with intelligent agents; 'AI system' as a software/hardware assemblage employing AI methods; 'developer' and 'provider' as natural or legal persons designing, training or placing AI systems on the market; 'user' and 'operator' as the party deploying the system; 'high-risk AI' as systems with significant potential for harm to safety, fundamental rights, or critical infrastructure; 'model owner' and 'model deployer'; and 'impact assessment' (assessmen dampak) including privacy/data, safety and socio-economic impacts. These baseline definitions are intended to align with international practice and to enable a risk-based regulatory approach under the Perpres.

Governance and Institutional Framework

The draft designates the Ministry of Communication and Digital (Komdigi) as the central coordinating authority for the Perpres, responsible for publishing the National AI Roadmap, convening inter-ministerial working groups, and issuing implementing guidance. Sectoral regulators (e.g., Otoritas Jasa Keuangan for finance, Kementerian Kesehatan for health) retain authority over domain-specific applications and enforcement. Cybersecurity responsibilities and technical standards coordination are assigned to the National Cyber and Crypto Agency (BSSN). The draft envisages a permanent advisory council or task force composed of government, academia, industry and civil society to support policy development and to advise on priority areas such as talent development, infrastructure and public-interest use cases. The Perpres also foresees collaboration with the State Secretariat for harmonization and with the Ministry of Law for legal vetting. See Komdigi consultation announcement and ePPID extension for dates and process details. Komdigi ePPID: Consultation Extension. ([eppid.komdigi.go.id](https://eppid.komdigi.go.id/berita/detail/perpanjangan-waktu-konsultasi-publik-buku-putih-peta-jalan-kecerdasan-artifisial-nasional-dan-konsep-pedoman-etika-kecerdasan-artifisial?utm_source=openai))

Key Focus Areas

The draft centers on (1) Ethics & Human Rights: embedding principles such as transparency, fairness, human oversight and non-discrimination; (2) Risk-based Classification: distinguishing low- from high-risk AI to calibrate obligations (e.g., mandatory impact assessments for higher-risk systems); (3) Safety Testing & Evaluation: requirements for pre-deployment testing and ongoing monitoring; (4) Data Protection & Privacy: alignment with national data protection frameworks and sectoral rules to safeguard personal data processed by AI; (5) Transparency & Documentation: mandated model cards, provenance logs, and user-facing disclosure for certain systems; (6) Conformity & Registration: pathways for conformity assessment, voluntary certification and mandatory registration for high-risk systems; (7) Cybersecurity & Model Security: measures for model robustness, supply-chain security and mitigation of misuse; (8) Market Surveillance & Enforcement: institutionalized inspection, incident reporting, and sanctions; and (9) Capacity & Localisation: initiatives to support Indonesian-language models, research funding and training. The White Paper emphasizes inclusive growth and identifies priority sectors (healthcare, finance, education, public services, transportation) for early targeted programs. Komdigi Public Notice. ([portal.komdigi.go.id](https://portal.komdigi.go.id/kanal-publik/berita-kini/9526?utm_source=openai))

Implementation Framework

Implementation is described as phased: initial publication of the White Paper and ethics concept; public consultation and revision; formal izin prakarsa submission to the State Secretariat; harmonization with the Ministry of Law; then promulgation as a Perpres. The Perpres establishes a rulemaking and guidance pipeline: Komdigi will issue technical guidelines (e.g., risk taxonomy, conformity procedures, model documentation templates), sectoral regulators will define domain-specific obligations under their statutory remit, and an inter-agency technical secretariat will coordinate cross-cutting activities such as incident reporting, cross-border data flows, and procurement standards for government use. The government has indicated target timelines for harmonization and finalization but retains flexibility contingent on stakeholder inputs and legal vetting. ([portal.komdigi.go.id](https://portal.komdigi.go.id/kanal-publik/berita-kini/9526?utm_source=openai))

Monitoring and Evaluation

The draft envisages continuous monitoring through reporting obligations, periodic audits of registered/high-risk systems, and indicators tracked via the National AI Roadmap. Monitoring includes qualitative reviews (ethics compliance, socio-economic impact) and quantitative metrics (adoption rates, incidents, uptime/availability). The Perpres anticipates a public registry of high-risk systems or certification status, periodic public reporting by Komdigi on AI safety and ethics, and mechanisms for civil-society participation in evaluation. Market surveillance authorities will be empowered to perform inspections and compel remediation. The Perpres design assumes a feedback loop to update the White Paper and technical guidance as the technology and market practice evolve. ([portal.komdigi.go.id](https://portal.komdigi.go.id/kanal-publik/berita-kini/9526?utm_source=openai))

Penalties, Liability, and Appeals

The draft establishes administrative enforcement measures (warnings, corrective orders, temporary suspension of operations, administrative fines), requirements for remediation plans, and public naming for egregious non-compliance. It contemplates coordination with sectoral regulators for joint enforcement (e.g., OJK for financial penalties where applicable). Liability allocation remains anchored in existing civil and criminal frameworks: the Perpres reinforces obligations that support civil liability and potential criminal sanctions for severe negligence or malicious misuse but does not replace existing law. The draft includes an appeals pathway and requires regulators to follow administrative procedural rules when imposing sanctions. The government also signals support for accessible remedies and redress mechanisms for individuals harmed by AI systems. ([portal.komdigi.go.id](https://portal.komdigi.go.id/kanal-publik/berita-kini/9526?utm_source=openai))

Relationship to Other Instruments

The Perpres is intended to complement, not supersede, existing national laws and sectoral regulations: it will interface with personal data protection law, consumer protection statutes, sectoral health and financial regulations, the Electronic Information and Transactions framework, and national cybersecurity law. The Perpres aims to harmonize with Presidential and ministerial regulations already governing electronic systems and public services (e.g., SPBE frameworks) and will include transitional provisions to avoid conflicts. Implementation requires active coordination with the Ministry of Law and Human Rights for legal consistency and with the State Secretariat for procedural approval. ([portal.komdigi.go.id](https://portal.komdigi.go.id/kanal-publik/berita-kini/9526?utm_source=openai))

International Alignment

The draft frames Indonesia’s approach within international trends: a risk-based regulatory model, emphasis on ethics and human oversight, and compatibility with OECD/UN guiding principles on AI governance. Komdigi has indicated that the White Paper and Perpres are developed with reference to international best practice and with awareness of IP and data-flow implications; the Perpres also contemplates international cooperation on standards, cross-border incident response and research collaboration. Indonesia intends to remain open to foreign investment while safeguarding national priorities such as data protection and local capacity-building. Komdigi Consultation Announcement. ([portal.komdigi.go.id](https://portal.komdigi.go.id/kanal-publik/berita-kini/9526?utm_source=openai))

Implementation Timeline

Sources and References