Indonesia | Herbert Smith Freehills Kramer

Policy

AI regulation

AI-related law and regulation

Sector-specific AI regulations

1 เม.ย. 2026 Insight

Reports and highlights

Indonesia does not have dedicated AI regulation. Instead, it relies on existing regulations in areas such as electronic information and transactions, personal data protection, and the regulation of electronic system operators to oversee AI technology and its applications. The Indonesian government has also introduced guidelines addressing business activities involving AI-based programming and to promote ethical AI use, signalling Indonesia’s commitment to fostering responsible and sector-appropriate AI practices while broader regulations are still under development.

AI Strategy

In 2020, the Indonesian government, through the Agency for the Assessment and Application of Technology (now the National Research and Innovation Agency or BRIN), introduced the Indonesian Artificial Intelligence National Strategy: Year 2020–2045.

The policy paper outlined the country’s strategic vision for AI development over a 25-year period, focusing on ethics and policy, talent development, infrastructure and data, and research and industrial innovation. Priority sectors include healthcare, bureaucratic reform, research and education, food security, and mobility and smart cities, with the goal of positioning Indonesia as a leader in AI by 2045.

In August 2025, Indonesia’s Ministry of Communication and Digital Affairs released the country’s first comprehensive AI Roadmap whitepaper, outlining a national vision for artificial intelligence development through 2045. The roadmap sets out strategic priorities for AI adoption across government, industry, and society, emphasising talent development, digital infrastructure, and responsible innovation. Alongside the roadmap, the Ministry published a draft concept for national AI ethics guidelines, aiming to ensure that AI systems are developed and deployed in line with Indonesian values, human rights, and public trust. Importantly, both documents are currently drafts, open for public feedback and pending finalisation.

Development of Regulation

The Indonesian government announced in 2025 plans to establish a legal framework for artificial intelligence that comprises:

Regulations addressing AI that aims to ensure safety and ethical use within specific applications such as automated decision-making and facial recognition.
Sector-specific AI regulations that address AI applications in industries such as finance, healthcare, and human resource management.
Legal liability provisions that establish accountability for harm or unforeseen damages caused by AI, including criminal and civil liability.
Voluntary ethical guidelines.

The Indonesian government also plans to launch the National Data and Artificial Intelligence Ethics Council (Dewan Etika Data dan Kecerdasan Artifisial Nasional) to oversee the responsible use of AI. The council is yet to be established, but Indonesia continues to advocate for human-centric AI adoption.

In January 2026, Indonesia’s Ministry of Communication and Digital Affairs confirmed that the Indonesian Artificial Intelligence National Strategy 2020–2045 and the accompanying AI ethics framework which had previously existed as policy papers will be formalised as Presidential Regulations. According to the Deputy Minister of Communication and Digital Affairs, the State Secretariat is in the process of finalising both documents, which will elevate Indonesia’s long‑term AI strategy and ethical principles from policy guidance into binding national instruments applicable across government, business, academia, and industry.

Once enacted, these Presidential Regulations are intended to serve as foundational national guidelines for the development and deployment of AI in Indonesia, emphasising trust, transparency, accountability, and digital talent development, while reinforcing responsible and human‑centric AI adoption in priority sectors such as healthcare, public governance, education, food security, and mobility.

International Stage

Indonesia also collaborates internationally with other jurisdictions on AI. Indonesia is a party of the Association of Southeast Asian Nations (ASEAN) which released the ASEAN Guide on AI Governance and Ethics in February 2024 and was supplemented by the Expanded Guide in February 2025, with a particular focus on generative AI.

Globally, Indonesia is also a party to the G20 AI Principles, 2023 UK AI Summit's Bletchley Declaration, adopted UNESCO's Recommendation on the Ethics of AI, completed an AI Readiness Assessment with UNESCO, and signed the 2025 AI Action Summit's joint statement on Inclusive and Sustainable AI for the People and the Planet.

Helpful resources

Indonesian AI National Strategy 2020-2045

Currently, there is no umbrella AI-specific regulation or legislation in place in Indonesia.

From consumer protection law to online safety, AI continues to stretch existing legal frameworks. See the latest updates below.

Two key pieces of legislation provide a legal framework for issues such as data protection, electronic transactions, and related concerns in the context of AI implementation:

Law No. 27 of 2022 on Personal Data Protection - the data protection and electronic information and transaction law – as supplemented by MOCI Regulation No. 20 of 2016 on Personal Data Protection in Electronic System, which requires electronic system operators to comply with data processing requirements for the data processing activity, including those who use AI.
Law No. 8 of 2011 on Electronic Information and Transactions, along with its implementing regulations, require electronic operators using AI to register themselves as electronic system operators and subjects them to compliance with Circular Letter No. 9 of 2023 on AI Ethical Guidelines (Indonesian AI Ethics Letter)

The Indonesian AI Ethics Letter emphasises that the use and implementation of AI must align with the principles of intellectual property protection as outlined in existing regulations.

Indonesian Copyright Law does not explicitly address the use of AI in the creative processes but does acknowledge the possibility of creations being produced using technology, reflecting its recognition of the evolving role of technology in the creative landscape. The interplay between IP protections and AI-generated works is expected to become an increasingly central area of focus in Indonesia’s IP regulatory development.

The Deputy Minister of Communication and Digital Affairs indicated in August 2025 that the Presidential Regulation on AI would address copyright issues related to AI.

The National Consumer Protection Agency of Indonesia (BPKN) has highlighted the increasing complexity of consumer protection in the era of digitalisation and AI. BPKN has committed to ensuring that digital and AI technologies are implemented in ways that are fair and responsible to consumers. Their focus is on mitigating risks while empowering consumers to navigate the evolving digital landscape. Particular attention is being given to vulnerable groups, including children, women, and the elderly, ensuring they are not disproportionately affected by technological advancements.

Indonesian Manpower Law stipulates that all employees in the workforce are entitled to equal opportunities and treatment, free from discrimination by employers. Employers are required to provide employees with their rights and responsibilities without differentiating based on gender, ethnicity, race, religion, skin colour, or political affiliation. While the Indonesian Ministry of Manpower (MoM) has acknowledged the growing use of AI and its transformational impact on different groups of employees across various sectors during public forums, formal regulations or guidelines have not yet been issued to address the use of AI in relation to Indonesia’s existing labour protection framework.

On human rights, particularly the right to privacy in journalistic content, the Indonesian Press Council (IPC) issued IPC Regulation No.1/Peraturan-DP/I/2025 on Guidelines for the Use of Artificial Intelligence in Journalistic Works on 22 January 2025. The regulation requires journalists to obtain explicit acknowledgement and approval of all parties involved when generating their likeness using AI and using it in journalistic content. It also requires journalists to disclose when journalistic content is made with the assistance of AI.

Technology

Businesses involved in AI-based programming activities in Indonesia – which encompass consultation, analysis, and programming that uses various AI technologies, including machine learning, natural language processing, expert systems, and related applications - fall within the Indonesian Business Classification (KBLI) Code 62015.
As set out in the Ministry of Communications and Informatics (MOCI) Regulation No. 3 of 2021 on Standards for Business Activities and Product Standards, businesses must meet several obligations, including adhering to applicable legislation, implementing internal policies on data management and AI ethics, sharing technological advancements through publicly accessible means whilst accounting for privacy and legal considerations, and submitting annual activity reports to the Director General of Informatics Applications.
MOCI also issued Circular Letter No. 9 of 2023 on AI Ethical Guidelines on 19 December 2023, which is directed at public and private electronic system operators engaging in AI-based programming activities, as well as business players classified under KBLI Code 62015. The circular emphasises the importance of ethical AI use and provides a general framework for responsible AI implementation across all sectors.
See our article here for further details on the coverage of AI use guidelines in Indonesia.

Financial Services

Otoritas Jasa Keuangan (OJK) - the Indonesian Financial Services Authority - has published guidelines for AI use among fintech actors in Indonesia. These guidelines recognise the potential of AI and machine learning to improve business efficiency and streamline financial transactions, while simultaneously addressing unique risks associated with AI - serving as a code of conduct to ensure ethical and responsible AI use in fintech operations.
In April 2025, OJK published the Indonesian Banking Artificial Intelligence Governance as a guideline for the responsible use of AI in the banking sector. The guideline acknowledges the potential of AI, including advanced systems, to enhance banking operations, while also addressing the risks that come with its use. It outlines key considerations such as system piloting, legacy integration, compliance, organisational change, and user experience. It also discusses governance tools like the VCIO model and reinforces the need for internal and external audits to ensure effective oversight throughout the AI lifecycle.

Key contacts

Michelle Virgiany

Director, Prolegis LLC, Singapore

Legal Notice

The contents of this publication are for reference purposes only and may not be current as at the date of accessing this publication. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action based on this publication.

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