Independent map & monitor Indonesia Est. 2026 AI Governance Observatory

Mapping the governance of artificial intelligence in Indonesia

Indonesia governs AI with a handful of binding rules resting on a much larger base of ethics circulars, sector codes, and drafts still working through the State Secretariat. This site maps those rules, watches whether the binding ones get followed, and tracks the court cases that turn on AI.

WAICO founding memberFounding member of the World AI Cooperation Organization, signed in Shanghai on 16 July 2026 by Airlangga Hartarto, Coordinating Minister for Economic Affairs.
Explore the map Open the Observatory Analyze the case tracker
22instruments mapped
3binding
6soft-law / guidance
5draft / pipeline
8regional / international
01The map

An enforceability spectrum

Instruments are stacked by how much force they carry, from binding law with sanctions down to voluntary regional principles. That ordering is the argument: almost everything still sits below the binding line. Each entry links to its source where we've verified one; the rest are on the way.

All Binding Soft law Draft / pipeline Regional
All types AI-specific Data protection Cyber and crime Digital and telecom Copyright
Binding lawenforceable, in force
Sectoral · E-commerce

Permendag 19/2026

Trade Ministry e-commerce (PMSE) regulation
Ministry of Trade · In force 2026
First Indonesian instrument with AI-specific duties on commercial operators (Article 47): disclose/label AI use, keep AI output accurate, maintain internal AI governance, answer complaints. It replaces Permendag 31/2023.
Digital and telecomGeneral catch
Binding Source ↗
Binding in text, but Article 47 is absent from the sanctioned list. We track it here.
Horizontal · Data

UU 27/2022

Personal Data Protection Law (PDP)
DPR RI · In force
Governs processing of personal data, including data used to train and run AI systems; underpins profiling, automated-decision and consent questions.
Data protectionVia data
BindingSource ↗
Horizontal · Electronic systems

UU 1/2024

Electronic Information & Transactions Law (ITE), as amended
DPR RI · In force
Baseline regime for electronic information, transactions and content. It is the horizontal floor that AI-driven platforms operate on.
Digital and telecomGeneral catch
BindingSource ↗
Soft law & guidanceno direct sanction
Circular · AI ethics

SE Menkominfo 9/2023

AI Ethics Circular
Kominfo (now Komdigi) · Issued Dec 2023
Ethical guideline for AI use, built on six values (inclusivity, humanity, security, accessibility, credibility, accountability). A circular (surat edaran), so internal guidance, not a sanctionable duty.
Digital and telecomGeneral catch
Soft lawSource ↗
Sectoral · Banking

OJK AI Governance for Banking

Lifecycle AI guideline for banks
OJK · Issued Apr 2025
A lifecycle AI-governance guideline for banks. It is a supervisory benchmark, not a statute, and draws on the EU AI Act and Basel standards.
AI-specificAI-native
Soft lawSource ↗
Sectoral · Fintech

OJK Fintech AI Code of Ethics

Responsible-AI code for fintech
OJK & industry associations · Issued Nov 2023
A code of conduct for responsible, trustworthy AI in fintech, issued with the four industry associations. Guidance, not an enforceable rule.
AI-specificAI-native
Soft lawSource ↗
Strategy

Stranas KA 2020-2045

National AI Strategy
Government of Indonesia · Issued 2020
Long-horizon policy direction across ethics, talent, infrastructure, data and priority sectors. Strategic, not regulatory.
Digital and telecomGeneral catch
Soft lawSource ↗
Sectoral · Press

Perdewan Pers 1/2025

AI in journalism guidelines
Dewan Pers (Press Council) · Issued Jan 2025
Requires journalists to disclose when content is AI-assisted and to get consent before generating a person's likeness with AI. Self-regulatory, but binding within the press system.
Digital and telecomGeneral catch
Sector ruleSource ↗
Sectoral · Education

SKB 7 Menteri 2026

AI in education guideline
Seven ministries (joint decree) · Issued Mar 2026
National guidance for using and teaching digital technology and AI across formal, nonformal and informal education. Education units must assess their AI readiness and governance and put child-protection measures in place. Issued as guidance, not a sanctioned statute.
Digital and telecomGeneral catch
Soft lawSource ↗
Draft & pipelinenot yet in force
Presidential regulation

Draft Perpres on AI Ethics

AI umbrella regulation + ethics guidelines
Komdigi & State Secretariat · In consultation 2025
An umbrella Perpres plus a Konsep Pedoman Etika KA, with a three-tier risk model echoing the EU AI Act. Reporting says it would lean on sectoral enforcement rather than its own sanctions.
AI-specificAI-native
Roadmap

Draft Perpres on National AI Roadmap

Buku Putih Peta Jalan KA
Komdigi · In consultation
White paper setting implementation priorities for 2025-2029 under the Stranas KA: ethics, talent, infrastructure, data and priority use cases.
AI-specificAI-native
Copyright

Copyright Law Amendment

Extends copyright to AI-generated works
Amends UU 28/2014 · Proposed
Proposal to extend copyright protection to AI-generated works, contested over risks to human creators and market concentration.
CopyrightGeneral catch
DraftProposal: no public text yet
Competition

Draft Digital Market Law

Platform algorithm & data-control bill
KPPU · Proposed to DPR
Proposed law on algorithms, AI and data control by digital platforms, including algorithm audit and self-preferencing oversight.
Digital and telecomGeneral catch
DraftProposal: no public text yet
Cybersecurity

Draft Cybersecurity & Cyber Resilience Law

RUU Keamanan & Ketahanan Siber
Government / DPR · Proposed
A cyber-resilience bill that also reaches the dissemination of deepfakes and synthetic media, a possible route to AI-content rules outside the trade and ethics tracks.
Cyber and crimeGeneral catch
DraftProposal: no public text yet
Regional & internationalvoluntary
ASEAN

ASEAN Guide on AI Governance

Regional responsible-AI principles
ASEAN · Adopted 2024 (GenAI expansion 2025)
Voluntary, risk-based principles for responsible AI, expanded in 2025 for generative AI, plus a Responsible AI Roadmap 2025-2030. Implementation left to member states.
VoluntarySource ↗
BRICS

BRICS AI cooperation

Shared AI principles among members
BRICS · Indonesia joined 2025
Shared principles on transparency, ethics, data protection and equitable development. This is cooperation, not binding law.
VoluntarySource pending
G20

G20 AI Principles

OECD-derived AI principles
G20 · Voluntary commitment
Indonesia is not a direct OECD adherent, but as a G20 member it backs the G20 AI Principles, which are drawn from the OECD AI Principles.
VoluntarySource ↗
UNESCO

UNESCO Recommendation on AI Ethics

First global AI-ethics standard (194 states)
UNESCO · Adopted 2021
The first global standard-setting instrument on AI ethics. Indonesia, as a UNESCO member, is committed to its values and policy action areas.
VoluntarySource ↗
UNESCO

UNESCO AI Readiness Assessment (RAM)

Indonesia readiness diagnostic
UNESCO & Komdigi · Report 2025
A diagnostic of Indonesia's legal, institutional and technical readiness for ethical AI. Indonesia was the first country in Southeast Asia to complete it.
AssessmentSource ↗
Multilateral summit

Paris AI Action Summit statement

Inclusive & sustainable AI statement
Summit declaration · Indonesia signed 2025
Statement on Inclusive and Sustainable AI for People and the Planet. Indonesia signed; the US and UK did not.
VoluntarySource ↗
Multilateral summit

Bletchley Declaration

Frontier-AI safety declaration
AI Safety Summit · Adopted 2023
The first summit-level declaration on frontier-AI safety. Indonesia is among the parties to the AI Safety Summit series.
VoluntarySource ↗
United Nations

Global Digital Compact

UN digital & AI commitments
United Nations · Adopted 2024
Shared commitments on digital and AI governance, including an international scientific panel and a global dialogue on AI.
VoluntarySource pending
02Second reading

Making sense of Indonesia's AI governance model

Prescriptive Principles Nonbinding Binding
Empty among rules in force. The draft Perpres point here.
Binding and enforceable
Binding, no direct sanction
Soft law / guidance
Regional / international
Draft / pipeline

Tap a marker

Twenty-two instruments, two readings

Five are drafts in the pipeline, shown dashed; the rest are in force, adopted, or assessments. Among the binding rules, the binding and principles corner stays empty: where the law binds, it also prescribes. The draft Perpres are the first instruments pointing into it.

All twenty-two instruments
Compare this model with
03Indonesia AI Observatory

Tracking Indonesia's binding AI obligations in practice

The Observatory monitors the AI-specific obligations in Indonesian law that are actually binding on operators. Today there is exactly one: Article 47 of Permendag 19/2026. That scarcity is the point. It is the first and so far only place where the law says shall rather than should.

The catch: Article 47 is binding in text but absent from the regulation's sanctioned list (Arts. 57 / 65). Its teeth are borrowed from neighbouring duties. The Observatory builds a public record of what operators actually do.
Currently tracking · Permendag 19/2026

The six obligations

What operators must do when they deploy AI. Three of the six are visible from outside the company: disclosure, internal governance, and a complaint channel. Those are the ones the Observatory checks below.

47 / 1

Lawful use

AI may be used, provided the use conforms to applicable law. Deployment now carries legal responsibility.

47 / 2

Non-delegable accountability

The operator is legally responsible for its AI; outcomes cannot be blamed on the system itself.

47 / 3(a)

Disclosure & labelling

Must inform or label consumers when goods, content, recommendations or promotions are AI-driven. Core duty tracked here.

47 / 3(b)

Accuracy

AI-mediated information must be truthful, clear, accurate and accountable.

47 / 3(c)

Internal AI governance

Platforms must maintain AI governance proportionate to the risk profile of their deployment.

47 / 4

Complaint & correction

A mechanism to challenge AI outputs and receive a substantive response.

The observatory

Observed disclosure practice

Submit an observation

Three of Article 47's six duties can be checked from the outside: whether consumers are told AI is in use, whether the operator keeps an internal AI policy proportionate to its risk, and whether there is a channel to complain about AI-related harm. Each operator below is checked against those three. Entries record observed practice on a given date, not a verdict of compliance. Assessed companies are open to tap; the rest are marked Coming soon until they are reviewed.

All models Online retail Marketplace Classifieds Price comparison Daily deals Social-commerce Ride-hailing Online travel
D AI disclosure G Internal AI governance C Complaint channel Last updated 29 June 2026 · tap a company to expand

How an observation is made

  1. Disclosure (D). Look for a label or notice telling the consumer that content, recommendations or promotions are AI-driven, and record where it appears.
  2. Internal governance (G). Look for a written AI policy, or an AI clause in the platform's terms, that sets out how AI is used and what data it collects.
  3. Complaint channel (C). Check, yes or no, for a reachable way to complain about AI-related harm. A general customer-complaint route counts if it covers AI, as does an AI policy that names one.
  4. Capture evidence for each: date, URL, screenshot.
  5. Record observed practice, not a verdict of compliance.

Framing & limits

Article 47 carries no direct sanction, so this monitor does not label any operator "non-compliant." It records what is publicly observable on a given date, with evidence, and lets readers draw their own conclusions.

This is an independent research project and does not constitute legal advice.

04Case Compendium

Indonesian legal proceedings that turn on AI

A running record of court cases and investigations in Indonesia where AI is part of the facts. Most of it is deepfake fraud and synthetic sexual content, now joined by a civil tort over an AI face-swap and a divorce ruling on how to authenticate digital evidence. Five rulings are decided; the rest sit at investigation or prosecution.

The pattern: courts are convicting and awarding damages on the substance of synthetic media, mostly before the law has a settled method to authenticate it, and none of these cases had an AI-specific statute to rely on.
9proceedings tracked
5decided
4investigation / prosecution
The record

Cases and proceedings

Tap a case to read the facts, the legal basis, and where it stands. Status reflects the most recent stage we have on record.

All Decided Prosecution Investigation

What the record shows

Indonesian courts are deciding these cases without any AI-specific law, leaning on the Criminal Code, the ITE Law, the PDP Law, the Civil Code, and, in the election case, constitutional principle. Most turn on the substance of synthetic media even though no settled way to authenticate it yet exists, though one recent ruling has begun to require digital forensics. As of June 2026 Indonesia still has no standalone deepfake or AI-content statute.

How this is compiled

Compiled from a June 2026 review of public sources, with status noted per case.

Each entry links to a traceable source: an official decision where one exists, otherwise credible reporting. This is a record of reported proceedings, not legal advice.

Indonesia · AI-IP Index

How Indonesia aligns AI and intellectual property

DJKI holds the human line: purely AI-made works are not recorded, patent inventorship stays human, and the copyright bill codifies a human-contribution test rather than extending protection to machines.

Accommodation 0.67 · Institution 0.5. Protective of human creators, with purely AI-made work refused and inventorship kept human. Moderately built out on the institution side.
The framework

What the index measures

The AI-IP Index reads a country on two questions that usually get folded together. Accommodation asks how far the law will go to protect intellectual property that a machine helped produce. Institution asks how much administrative machinery sits behind that law: its guidance, its international submissions, its disclosure duties.

A country can be generous on paper and have built almost nothing, or cautious and highly organised, so the two are scored apart and reported as a pair. Each rests on three questions, scored 0, 0.5 or 1.

Accommodation

How far the law will protect intellectual property that a machine helped make.

  • Q1. Patentability of AI-assisted inventionsWhether an invention developed with AI help, filed with a human named as inventor, can be granted. It decides whether AI-assisted research can be protected at all.
  • Q2. Copyright in AI-generated outputWhether output made with AI attracts copyright when a person directed the work. It sets who, if anyone, owns AI-assisted creative work.
  • Q3. Training and text-and-data-miningWhether copyrighted works can be used to train a model without the owner's permission. This is the main fault line between model builders and rights holders.
Institution

How much administrative machinery sits behind that law.

  • Q4. WIPO Conversation participationWhether the IP office has engaged the WIPO Conversation on IP and Frontier Technologies with a substantive submission. It shows the office is working the question at the international level.
  • Q5. National IP office AI guidanceWhether the office has published dedicated guidance on examining AI-related filings. It tells applicants where they stand before they file.
  • Q6. Disclosure or transparency dutyWhether a filing has to declare that AI was used. It is the office's main lever for provenance.

The scale runs the same way on both axes: 0 is the open or developed end, 1 is the restrictive or absent one, and 0.5 sits between for anything conditional or untested. Read as a pair, the two scores show whether AI-assisted work can be protected here, and whether the office has said so in writing.

Within each axis the three questions carry equal weight. That is a deliberate choice, not an oversight. An AI developer might reasonably value freedom to train above patent inventorship, but weighting is where indices lose their credibility, so the score stays a flat mean and the choice is stated in the open. Each cell also cites a statute section, a case or an office page, so any single score can be challenged without disputing the rest.

Two positions are worth naming. A country can be open on the law but thin on machinery, an open-but-undeveloped stance that bets on ambiguity. Or it can be restrictive on rights yet run an active office, a restrictive-but-developed stance that reflects a settled policy choice rather than a gap. The pair of scores tells those two apart where a single ranking would blur them.

Calibration

Testing the scale against known ground

A rubric is only as good as the results it produces on cases where the answer is already known. These three jurisdictions sit outside this series and are scored with the same six questions, as a check. Their law is the best documented anywhere, so if the scale puts them where the law actually sits, the scale is doing its job. They are reference points, not editions.

United StatesAccommodation 0.33 · Institution 0.17
Q10Q20.5Q30.5Q40Q50Q60.5

Firm judicial settlement at both poles and the weakest statutory position on training. The courts have closed the door on AI inventors and AI authors, while everything on training rides on unresolved fair-use litigation. There is no per se duty to declare AI use in a filing, only a candour duty that bites where the use is material.

Thaler v. Vidal, 43 F.4th 1207 (Fed. Cir. 2022); Thaler v. Perlmutter (D.C. Cir. 2025), cert. denied 2 Mar 2026; Bartz v. Anthropic (N.D. Cal. 2025); USPTO revised inventorship guidance, 90 Fed. Reg. 54636 (28 Nov 2025); 89 Fed. Reg. 58128 (17 Jul 2024); 89 Fed. Reg. 25609 (11 Apr 2024).

EuropeAccommodation 0.17 · Institution 0
Q10Q20.5Q30Q40Q50Q60

The most permissive statutory position on training and the strongest transparency duty in force, sitting over an authorship question no court has answered. Read the label carefully: training and transparency run through EU law, but patents run through the EPO under the European Patent Convention, which is not an EU institution and covers 39 states.

Directive (EU) 2019/790, arts. 3 and 4; Regulation (EU) 2024/1689, art. 53(1)(c) and (d); EPO J 8/20 (2021); EPO Guidelines G-II 3.3.1 (2026 edition); Infopaq C-5/08; Painer C-145/10.

United KingdomAccommodation 0.33 · Institution 0.67
Q10Q20.5Q30.5Q40.5Q50.5Q61

Liberal on patents since the Supreme Court abandoned the Aerotel test in February 2026, conservative on copyright, and currently thin on AI-specific machinery after the dedicated AI examination guidance was withdrawn. Section 9(3) nominally protects a work with no human author for 50 years, the widest AI-output right on paper, but no court has ever applied it to generative AI.

CDPA 1988 ss. 9(3), 12(7), 29A, 178; Thaler v Comptroller-General [2023] UKSC 49; Comptroller-General v Emotional Perception AI [2026] UKSC 3; UKIPO practice notice, 14 Jul 2026; Data (Use and Access) Act 2025 ss. 135 to 137.

The check earned its keep twice. The untested rule held: section 9(3) of the UK Copyright Act reads like the widest AI-output right anywhere, yet because no court has applied it to generative AI it scores as untested rather than open, which is the correct answer and the one a headline reading would miss. The check also exposed a limit worth stating. The Institution axis measures AI-specific machinery, not general office capacity, so a long-established office can score poorly when it has withdrawn its AI guidance and imposes no disclosure duty. Read that axis as what an office has built for AI, nothing wider.

Scorecard

The evidence, question by question

Each row below carries the test we applied and the finding behind the score, with a source. The rationale, not the number, is the point.

Direction of travelTightening. The draft Copyright Bill would require permission and compensation to use protected works for training, tightening the input side further. This is recorded apart from the scores: a pending change is signal, not yet the rule.

Scores verified 16 July 2026, against AIP Index codebook v1.0. A score is only true as of its date.

0 · open or developed0.5 · conditional or emerging1 · restrictive or absent

Accommodation: what the law permits

Mean 0.67
0.5
Q1. Patentability of AI-assisted inventions

What we look forA granted patent or a clearly workable examination route, not merely a silent statute.

The findingThe 2024 patent amendment admits AI as a computer-implemented invention with a human inventor, and DJKI applies it, but no grant decision demonstrates the AI-assisted pattern.

UU 65/2024
0.5
Q2. Copyright in AI-generated output

What we look forProtection applied where human choices shape the work, and refusal of purely machine output.

The findingDJKI protects AI-assisted works with substantial human contribution and refuses purely AI output, through office practice rather than a settled rule, with the codifying bill still in draft.

DJKI practice; RUU Hak Cipta
1
Q3. Training and text-and-data-mining

What we look forA statutory or judicial mining lane. Silence scores against the miner, since the reserved-rights default governs.

The findingThere is no mining exception, and the draft bill would require permission and compensation for training data. With copyright silent, the reserved-rights default governs.

UU 28/2014; draft bill

Institution: how developed the machinery is

Mean 0.5
0.5
Q4. WIPO Conversation participation

What we look forA traceable, substantive submission on the record, not bare membership.

The findingDJKI engages WIPO as a member, with no traceable substantive Conversation submission found.

WIPO records
0.5
Q5. National IP office AI guidance

What we look forA standalone AI examination text, not AI handled quietly under general practice.

The findingOfficial statements, training material and a bill consultation, but no formal published AI examination guidance.

DJKI
0.5
Q6. Disclosure or transparency duty

What we look forA mandatory declaration inside the filing, not a proposal or an informal request.

The findingThe draft bill would require AI-content labeling and DJKI's practice asks for human-contribution evidence, but neither is yet a binding filing duty.

DJKI; draft bill

Conclusions

Can AI be named as inventor?
No
Statutory opt-out from training?
None
Volume of disputes
None reported

Instruments where AI meets IP

Copyright

UU 28/2014, Copyright Law

Pencipta means a person
DPR RI / DJKI · In force
No AI provisions, but the author is defined as a person, and DJKI and practitioners agree fully autonomous AI output gets no copyright. The AI's source code is protectable as a computer program; the algorithm itself is not.
Copyright reform

RUU Hak Cipta

The human-contribution test, in draft
DPR initiative bill · Awaiting joint deliberation, Jul 2026
Draft Article 44 requires selection, curation, refinement and documented human intervention for protection, and gives AI works without human intellectual involvement no copyright at all. The revision is also slated to address training-data permission and compensation and mandatory AI-content labeling. Creator groups and scholars are contesting parts of it.
Patents

UU 13/2016 as amended by UU 65/2024

AI patentable, AI inventorship not
DPR RI · In force Oct 2024
The third patent amendment lets AI and machine-learning systems in as computer-implemented inventions while keeping inventorship strictly human. Roughly 400 AI-related patent applications were filed over the eight years to 2024.
AI ethics

SE Menkominfo 9/2023

IP protection as an AI ethics principle
Kominfo · Dec 2023
The AI ethics circular makes deployment subject to IP-protection principles, one of its nine values. Guidance, not a sanctionable duty.
Soft lawSource ↗
Office practice

DJKI registration practice

Gatekeeping without a circular
DJKI · Practice, 2024-2026
No formal circular on AI works exists; the gate is official statements and training material, including a four-step test (own prompt design, human editing, protected-category check, personal character) presented in DJKI education sessions. Indicative practice rather than formal guidance.
PracticeDJKI ↗

The case record

No verified reported decision. Searches of the Supreme Court decision directory and court dockets surface no Indonesian ruling on AI and IP, and the DABUS AI-inventorship project never filed here. A caution for readers: two commercial-court case numbers circulate in academic articles as supposed AI-copyright rejections, but neither appears in the court directory and their captions do not match real commercial-court formats, so this index treats them as unverified. The closest real dispute, the 2025 controversy over Ghibli-style AI images that sparked the artists' movement against AI imagery, produced a ministry legal analysis but no lawsuit.

Method. Six questions, three per axis, scored 0, 0.5 or 1 against AIP Index codebook v1.0. The three questions in each axis are weighted equally by choice, and the two axes are reported as a pair, never blended into one number. Every score cites a statute, case or office page, carries a verified date, and records its direction of travel apart from the level. Positions are editorial judgements read from primary law and office practice, not official scores. WIPO's public catalogue of IP-office AI initiatives does not score jurisdictions on this basis, so the readings here come straight from the source law. Not legal advice.

05About

Why this exists

Indonesia's approach to AI is real but unstructured: a thin layer of binding rules over a much thicker layer of ethics circulars, codes of conduct, and drafts. Reviewing it means piecing the picture together from scattered instruments, most of which can't be enforced.

It does three things. It maps the governance structure as an enforceability spectrum, with every instrument linked to its source, so the whole picture reads at a glance. It runs an observatory on the narrow band that actually binds anyone, starting with Article 47 of Permendag 19/2026, to see whether a binding rule with no sanction behind it changes what platforms do. And it tracks the court cases where AI is part of the facts.

A comparative thread runs alongside: where Indonesia states a labelling duty without a method, jurisdictions such as China have already operationalised one. That comparison is where the next round of reform has to work.

Behind this country report

Muhammad Deckri AlgamarIP & digital law · LL.M. (IE-WIPO), AIGP
Zar Motik AdisuryoTech governance · M.A. (Georgetown University), M.Sc. (University of Oxford)

Contribute

Seen a platform using AI, with or without a disclosure label? Send a link and a screenshot, and it will be reviewed before publishing.

Submit an observation

Private ordering

When a platform uses AI, the job of governing that use falls on it, and so does the choice of how. That is private ordering: rules written and enforced by companies, not by the state. It can move fast, and from the outside it is hard to see. Most people never learn how a platform writes or applies its own AI rules, and they get no say in them.

This site exists to change that. It records how each platform governs its own AI and checks that practice against Article 47 of Permendag 19/2026, so that decisions made inside a company become visible to the public.

An independent research and educational project. Information is provided as-is, may be incomplete, and does not constitute legal advice. Monitoring entries record observed practice on a stated date, not a legal finding of compliance or breach.