Searchlight AI
Indonesia

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 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. For more details, access BPKN’s official newsletter here.

With the rise of deepfakes, AI-generated misinformation, and manipulated media, ensuring trust and credibility in journalism has become more important than ever. Recognising this challenge, 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, setting legal standards for AI-generated content in the press industry. While the regulation allows press companies to adopt AI technology, it mandates that AI-driven journalism must uphold professional ethics, maintain human oversight, and ensure transparency in its implementation.

The regulation applies to journalistic content, which includes any product, content, or work created by journalists in the course of their activities. Press companies are required to handle data, information, images, audio, video, and other AI-generated content with caution to ensure compliance with copyright regulations and other applicable laws.

To uphold journalistic integrity, any significant use of AI in journalism must be explicitly acknowledged, reinforcing accountability and ethical responsibility in the industry.

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 blog here for further details on the coverage of AI use guidelines in Indonesia.