Indonesia is rapidly establishing itself as a key player in the regional digital economy and is increasingly focused on adopting artificial intelligence (AI). The Indonesian government outlined its long-term vision for AI with the Artificial Intelligence National Strategy for Indonesia 2020-2045: AI Towards Indonesia Vision 2045. A 2023 Kearney report projected that AI could contribute USD366 billion to Indonesia’s GDP by 2030.
Despite this ambition, Indonesia’s AI governance framework is still in its early stages, reflecting the challenges of aligning legal and institutional responses with the country’s rapid technological development. This gap in regulation presents both opportunities and challenges to strengthen accountability, enhance legal certainty and build public trust in AI technologies.
Framework and Governance
Currently, Indonesia does not have specific laws or regulations addressing AI. Instead, the operation and use of AI are governed by existing laws, including those related to electronic systems under the Electronic Information and Transactions Law, amended by Law No.1 of 2026 on Criminal Adjustment (EIT Law) and Government Regulation No.71 of 2019 on the Provision of Electronic Systems and Transactions. Under this framework, AI can be considered an “electronic agent,” defined as a device within an electronic system operated by a person.
However, this definition may be inadequate for modern AI systems, which often operate autonomously and exhibit complex problem-solving capabilities. In the absence of detailed AI-specific regulations, the Ministry of Communication and Digital Affairs (MOCD) issued Circular Letter No.9 of 2023 on Artificial Intelligence Ethics (CL9), providing general guidelines on the ethical values and control of AI-based activities.
These ethical values include inclusivity, security, accessibility, transparency, credibility, and accountability. AI operators are expected to safeguard society, prevent discrimination, and consider risk and crisis management. Sector-specific regulations also apply, such as the Financial Service Authority (OJK)’s Indonesian Banking Artificial Intelligence Governance, which focuses on reliability, accountability, and human oversight.
The OJK has also introduced a Code of Conduct for Responsible and Trustworthy Artificial Intelligence in the Financial Technology Industry, emphasizing fairness, transparency, and explainability.
Emerging AI-Specific Policies and Development
While a comprehensive legal framework is still under development, the MOCD published the National AI Roadmap White Paper in August 2025. This roadmap covers the conceptual framework of AI, issues analysis, and government policy direction, including establishing a National AI Co-ordination Task Force. It also introduces an AI lifecycle with principles to minimize risks at each stage and outlines key principles of AI governance, including dignity, justice, and accountability.
Complementing the roadmap, the MOCD also published AI Ethical Guidelines to strengthen the ethical framework in CL9, providing a self-assessment questionnaire for businesses. The government is also preparing a presidential regulation on AI to address accountability and security concerns and align AI initiatives across ministries and agencies.
Key Legal Challenges
Despite recent developments, several legal and institutional issues remain. Indonesia currently lacks a unified legal definition of AI, leading to uncertainty about how it should be regulated. The regulatory landscape is fragmented, potentially leading to overlapping authorities and inconsistent standards. This also raises concerns about personal data protection, as AI development often involves collecting and processing large datasets.
Indonesian law does not currently recognize AI as a separate legal subject, leaving liability for AI-related harm to be determined based on existing legal frameworks. To date, You’ll see no court decisions or specific legal provisions clarifying liability arising from the use of AI.
Frequently Asked Questions
What is Indonesia’s long-term vision for AI?
The Indonesian government set out its long-term AI vision through the Artificial Intelligence National Strategy for Indonesia 2020-2045: AI Towards Indonesia Vision 2045.
What is the role of the Ministry of Communication and Digital Affairs (MOCD) in AI governance?
The MOCD issued Circular Letter No.9 of 2023 on Artificial Intelligence Ethics (CL9) and published the National AI Roadmap White Paper in August 2025, indicating a growing policy-driven approach to AI governance.
What are some of the key legal challenges facing AI governance in Indonesia?
Key legal challenges include the lack of a unified legal definition of AI, a fragmented regulatory approach, privacy risks, and unclear liability and accountability frameworks.
As Indonesia continues to integrate AI across sectors, will the country be able to effectively balance innovation with the need for robust legal and ethical safeguards?
