Building trust in the algorithm: Indonesia’s emerging AI framework

Indonesia is becoming a key player in the regional digital ecosystem and is increasingly focused on adopting artificial intelligence (AI). A recent report projects AI could contribute USD366 billion to the country’s GDP by 2030, though its AI governance framework is still in its early stages.

Framework and governance

Indonesia currently governs AI operations through existing laws and regulations, including those related to electronic systems and transactions. Under this framework, AI may be considered an “electronic agent,” though this definition may be inadequate for the complex, autonomous nature of modern AI systems.

To address this, the Ministry of Communication and Digital Affairs (MOCD) issued Circular Letter No.9 of 2023 on Artificial Intelligence Ethics, providing guidelines on values, ethics, and controls for AI-based activities. These guidelines emphasize 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’s (OJK) guidelines for AI governance in the banking sector, which focus on reliability, accountability, and human oversight.

Emerging AI-specific policies and development

The MOCD published the National AI Roadmap White Paper in August 2025, outlining a conceptual framework for AI, establishing a National AI Co-ordination Task Force, and introducing an AI lifecycle encompassing conception, data collection, processing, and evaluation. The roadmap also outlines key principles of AI governance, including dignity, justice, and transparency.

Complementing the roadmap, the MOCD also published AI Ethical Guidelines to strengthen the ethical framework established in Circular Letter No.9. 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. A unified legal definition of AI is lacking, leading to uncertainty and fragmented regulatory approaches. This fragmentation could result in overlapping authorities and inconsistent standards.

The growing use of AI also raises concerns about personal data protection, particularly regarding the collection and processing of data for AI development. Indonesian law does not currently consider AI a separate legal subject, creating ambiguity regarding liability for AI-related harm.

As Indonesia accelerates AI integration, the primary challenge lies in governance readiness, addressing legal gaps related to AI definition, privacy, and accountability. Meaningful progress will depend on incorporating current initiatives into binding legal instruments that offer legal certainty and effective enforcement.