	AI Legislative Guide
	Indonesia
	(Asia Pacific) Firm ABNR Counsellors At Law Contributors Emir Nurmansyah Ayik Candrawulan Gunadi Nurdin Adiwibowo Updated 04 Aug 2025
Has specific legislation, final regulations or other formal regulatory guidance addressing the use of AI in your jurisdiction been implemented (vs reliance on existing legislation around IP, cyber, data privacy, etc.)?	Yes. The Ministry of Communications and Information Technology (currently known as the Ministry of Communications and Digital Affairs or “MOCD”) has issued Circular Letter No. 9 of 2023 on the Ethics on Artificial Intelligence (“CL AI”), which provides general guidelines on the use of AI in Indonesia. However, the CL AI merely contains high-level guidelines and principles on the use of AI, instead of providing detailed requirements on the use of AI. Additionally, the Indonesian Financial Service Authority (Otoritas Jasa Keuangan or “OJK”) launched the Artificial Intelligence Governance for Indonesian Banking (“OJK Guideline”), which is applicable for the use of AI by banks in Indonesia.
Please provide a short summary of the legislation/regulations/guidance and explain how legislators aim to strike the balance between innovation and regulation.	The CL AI generally acknowledges the increasing development and integration of AI in Indonesia. Considering the ever-developing nature of this technology in its current state, the MOCD issued the CL AI as a reference on value and ethics in implementing AI. The CL AI requires the implementation of AI to consider the following aspects: inclusivity, humanity, security, accessibility, transparency, credibility and accountability, personal data protection, sustainable development and environment, and protection of intellectual property. The CL AI also emphasizes the involvement of humans by prohibiting the use of AI as the ultimate decision-making tool. Taking into account the nature of CL AI, which is not a binding regulatory instrument, it is implied that the MOCD is adopting a “wait and see” approach to avoid imposing restrictive rules that may prevent the development of AI, whilst giving them the opportunity to determine the most appropriate approach to regulate this technology. This is consistent with the principles of “technological neutrality” adopted by Law No. 11 of 2008 on Electronic Information and Transactions, as amended by Law No. 1 of 2024. However, based on recent news, the MOCD is currently drafting a regulation that would govern the use of AI that is inclusive and multi-sectoral. MOCD is aiming to finalize the regulation in September 2025. The OJK Guideline was further developed to ensure that the use of AI technology, including advanced artificial intelligence-based systems, is carried out ethically and in accordance with regulations in all banking activities. It also introduces the fundamental principles of AI use in banking: - Reliability, meaning that an AI model must be capable of producing output through an explainable and easily understandable system, be secure, and be generated by a robust and resilient system - Accountability, meaning that the AI systems provided must be trustworthy, beneficial, fair, respect human rights, transparent, and explainable, as well as robust and secure. - Human supervision, meaning that human oversight should be conducted in a timely and targeted manner as a precautionary measure in case the AI system makes decisions independently, potential biases arise unconsciously, and to prevent AI from producing outcomes that are inconsistent with values of fairness, deviate from its objectives, violate regulations, and are inconsistent with humanitarian ethics The above principles show the OJK’s intention to retain a certain degree of non-automated control over the AI systems and emphasize the responsibility of undertakings operating the AI.
Which agency regulates the use of AI in your jurisdiction?	The MOCD regulates the use of AI in Indonesia in general. However, specifically in the financial sector, the OJK has the jurisdiction to regulate and supervise the use and development of AI in financial services.

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Has specific legislation, final regulations or other formal regulatory guidance addressing the use of AI in your jurisdiction been implemented (vs reliance on existing legislation around IP, cyber, data privacy, etc.)?

Yes. The Ministry of Communications and Information Technology (currently known as the Ministry of Communications and Digital Affairs or “MOCD”) has issued Circular Letter No. 9 of 2023 on the Ethics on Artificial Intelligence (“CL AI”), which provides general guidelines on the use of AI in Indonesia. However, the CL AI merely contains high-level guidelines and principles on the use of AI, instead of providing detailed requirements on the use of AI.

Additionally, the Indonesian Financial Service Authority (Otoritas Jasa Keuangan or “OJK”) launched the Artificial Intelligence Governance for Indonesian Banking (“OJK Guideline”), which is applicable for the use of AI by banks in Indonesia.

Please provide a short summary of the legislation/regulations/guidance and explain how legislators aim to strike the balance between innovation and regulation.

The CL AI generally acknowledges the increasing development and integration of AI in Indonesia. Considering the ever-developing nature of this technology in its current state, the MOCD issued the CL AI as a reference on value and ethics in implementing AI. The CL AI requires the implementation of AI to consider the following aspects: inclusivity, humanity, security, accessibility, transparency, credibility and accountability, personal data protection, sustainable development and environment, and protection of intellectual property. The CL AI also emphasizes the involvement of humans by prohibiting the use of AI as the ultimate decision-making tool. Taking into account the nature of CL AI, which is not a binding regulatory instrument, it is implied that the MOCD is adopting a “wait and see” approach to avoid imposing restrictive rules that may prevent the development of AI, whilst giving them the opportunity to determine the most appropriate approach to regulate this technology. This is consistent with the principles of “technological neutrality” adopted by Law No. 11 of 2008 on Electronic Information and Transactions, as amended by Law No. 1 of 2024.

However, based on recent news, the MOCD is currently drafting a regulation that would govern the use of AI that is inclusive and multi-sectoral. MOCD is aiming to finalize the regulation in September 2025.

The OJK Guideline was further developed to ensure that the use of AI technology, including advanced artificial intelligence-based systems, is carried out ethically and in accordance with regulations in all banking activities. It also introduces the fundamental principles of AI use in banking:

- Reliability, meaning that an AI model must be capable of producing output through an explainable and easily understandable system, be secure, and be generated by a robust and resilient system

- Accountability, meaning that the AI systems provided must be trustworthy, beneficial, fair, respect human rights, transparent, and explainable, as well as robust and secure.

- Human supervision, meaning that human oversight should be conducted in a timely and targeted manner as a precautionary measure in case the AI system makes decisions independently, potential biases arise unconsciously, and to prevent AI from producing outcomes that are inconsistent with values of fairness, deviate from its objectives, violate regulations, and are inconsistent with humanitarian ethics

The above principles show the OJK’s intention to retain a certain degree of non-automated control over the AI systems and emphasize the responsibility of undertakings operating the AI.

Which agency regulates the use of AI in your jurisdiction?

The MOCD regulates the use of AI in Indonesia in general. However, specifically in the financial sector, the OJK has the jurisdiction to regulate and supervise the use and development of AI in financial services.