Detailed overview
Indonesia does not currently have a comprehensive AI Act equivalent to the EU AI Act. Its AI governance framework is based on official guidance, electronic-system rules, personal-data protection, sectoral regulation and ethical AI principles.
Circular Letter No. 9 of 2023 on AI Ethics
Indonesia's Ministry of Communication and Informatics issued Circular Letter No. 9 of 2023 on Artificial Intelligence Ethics. The circular is addressed to business actors engaged in AI programming and to public and private electronic system providers involved in AI-related activities.
The circular requires AI programming businesses and electronic system providers to make and apply internal company policies on data and AI ethics. It is intended to guide internal AI policies and the use of AI-based consultation, analysis and programming activities.
AI ethics values
Indonesia's AI ethics values include inclusiveness, humanity, security, accessibility, transparency, credibility and accountability, personal-data protection, sustainable development, environmental responsibility and respect for intellectual property. These principles are relevant to AI systems used in online services, consumer platforms, financial services, employment, education, healthcare and public administration.
Existing-law overlays
Where AI processes personal data, Indonesia's personal-data protection law may apply. Where AI is provided through electronic systems, electronic-system provider obligations may also apply. AI used in regulated sectors may trigger financial, healthcare, telecommunications, consumer or public-sector rules.
Penalties
Indonesia does not currently have one AI-specific fine table. Penalties depend on the underlying law breached, including personal-data protection, electronic-system regulation, consumer protection, intellectual-property law, criminal law or sector-specific regulation.
Practical requirements & details
Sourced from Circular Letter No. 9 of 2023 on AI Ethics (Kemenkominfo), the Personal Data Protection Law (Law 27/2022), Government Regulation 71/2019 on Electronic System Operators, and sectoral rules from OJK and BPOM.
AI Ethics Circular Letter 9/2023
- Applies to AI programming businesses and ESOs involved in AI.
- Requires internal company policies on data and AI ethics.
- Values: inclusiveness, humanity, security, accessibility, transparency, credibility, accountability, personal-data protection, sustainable development, environmental responsibility, IP respect.
PDP Law 27/2022
- Lawful basis, transparency, data subject rights, security, breach notification.
- Sensitive personal data: additional protections.
- Cross-border transfer: adequacy or contractual safeguards required.
- Penalties up to IDR 50 billion + 2% revenue + imprisonment for sensitive-data offences.
Electronic System Operators (PSE) overlay
- AI-powered electronic systems must register; private-sector PSEs comply with content moderation, lawful access, security audits.
Sector overlays
- OJK AI/digital-finance circulars on responsible AI in banking, insurance, fintech.
- BPOM AI as medical device.
- Consumer protection (Law 8/1999) and misleading-advertising rules apply to AI-driven marketing.