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AI Legislative Guide

Indonesia

(Asia Pacific) Firm ABNR Counsellors At Law

Contributors Emir Nurmansyah
Ayik Candrawulan Gunadi
Nurdin Adiwibowo

Updated 05 May 2026
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 (“MOCD CL AI”), which provides general guidelines on the use of AI in Indonesia. However, the MOCD CL AI merely contains high-level guidelines and principles on the use of AI, instead of providing detailed requirements on the use of AI. The MOCD also published the National AI Roadmap White Paper (“AI Roadmap”) and draft AI Ethical Guidelines in 2025, which are intended to strengthen the ethical framework in MOCD CL AI.

Furthermore, there have been several guidelines and circular letters issued regarding the use of AI in several sectors, as follows:

  • 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; and
  • The Indonesian Broadcasting Commission (Komisi Penyiaran Indonesia or “KPI”) issued Circular Letter No. 1 of 2026 on Utilization of Artificial Intelligence in Broadcasting Programs at Broadcasting Institutions (“KPI CL AI”).
Please provide a short summary of the legislation/regulations/guidance and explain how legislators aim to strike the balance between innovation and regulation.

The MOCD 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 MOCD CL AI as a reference on value and ethics in implementing AI. The MOCD 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 MOCD 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 MOCD 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. The government is also currently preparing a Presidential Regulation to address overarching policy concerns relating to accountability and security of the AI sector, however there is currently no visibility on its date of issuance.

The AI Roadmap addresses the increasing need for a more policy-driven approach to AI governance through the following key aspects:

  • sets out the conceptual framework for AI, identifies key issues, and articulates the government’s policy direction and strategic response to AI-related challenges, including the establishment of a National AI Coordination Task Force to align stakeholders and harmonize sectoral laws and regulations with international standards;
  • introduces the AI lifecycle framework (i.e., conception, data collection, pre-processing, data processing, post-processing, and evaluation), under which each stage is subject to specific principles aimed at mitigating the risks associated with AI development and use; and
  • outlines the core principles of AI governance, namely: dignity, justice, accountability, personal data protection, transparency, security, sustainability, integrity, inclusivity, as well as human involvement and oversight.

The AI Ethical Guidelines also provide further guidance in implementing the ethical principles previously addressed in the MOCD CL AI. The AI Ethical Guidelines provide, among others, a general self-assessment questionnaire (which includes questions on how to detect and mitigate AI biases, whether there are clear and sufficient accountability schemes and redress measures to the AI system, and whether AI decision-making processes are explainable to its users) to help business undertakings in evaluating AI systems against ethical standards. 

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, is secure, and is 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 to emphasize the responsibility of undertakings operating the AI.

Additionally, the KPI CL AI serves as a guideline to all broadcast programs that utilize AI in broadcasting institutions, both at the planning, production, management, and broadcasting stages of broadcast programs. The KPI CL AI emphasizes that any broadcast programs that utilize AI must be conducted in a responsible, transparent, and ethical manner, while upholding information accuracy, balance, and public trust. KPI further requests broadcasting institutions to adhere to the following:

  • To inform the public in a clear and understandable manner about the use of AI, especially if such use impacts the public’s perception of reality, facts, and accuracy of information.
  • The use of AI in broadcast programs must not copy, manipulate, or modify the face, voice, statement, or identity of a natural person without proper consent and shall not violate a person’s human rights, privacy, and dignity.
  • The use of AI on broadcast programs must be done in good will and avoid pornographic, lies, defamation, sadism, and/or discrimination towards ethnicity, religion, race, and inter-group content.
  • All broadcast programs containing AI must comply with regulations under broadcasting and the Broadcasting Code of Conduct and Broadcast Program Standards.
  • Broadcasting institutions must ensure that all broadcast programs using AI are under human supervision/control, and their use can be held professionally accountable.
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. Furthermore, the KPI has the jurisdiction to regulate and supervise the use of AI by broadcasting institutions in broadcast programs.

AI Legislative Guide

Indonesia

(Asia Pacific) Firm ABNR Counsellors At Law

Contributors Emir Nurmansyah Ayik Candrawulan Gunadi Nurdin Adiwibowo

Updated 05 May 2026