Data & Privacy ยท Indonesia
Data protection & privacy law in Indonesia (2026)
Indonesia shaded by its data & privacy status
Data protection in Indonesia: comprehensive law.
FrameworkLaw No. 27 of 2022 on Personal Data Protection (PDP Law), as amended by Law No. 1 of 2026, with Government Regulation No. 33 of 2026 as the primary implementing regulation.
Indonesia has a comprehensive, GDPR-inspired personal data protection regime under Law No. 27 of 2022, which took effect on 17 October 2022 with a two-year transition period that expired on 17 October 2024. Government Regulation No. 33 of 2026, issued on 16 July 2026 and taking effect 16 January 2027, provides detailed implementing rules on data subject rights, controller/processor obligations, DPIAs, DPOs, breach notification, cross-border transfers and sanctions. The dedicated independent Personal Data Protection Authority (Lembaga PDP) mandated by the law has not yet been formally established; supervision and enforcement are handled on an interim basis by the Ministry of Communication and Digital Affairs (Komdigi).
Key points
Law No. 27 of 2022 (UU PDP) applies to public and private controllers/processors handling personal data of persons in Indonesia, and extraterritorially where processing has legal effects in Indonesia. It distinguishes general and specific (sensitive) personal data and establishes a rights-based framework across electronic and non-electronic systems.
Government Regulation No. 33 of 2026, enacted 16 July 2026 and effective 16 January 2027, elaborates data subject rights, controller/processor obligations, DPO appointment, DPIAs, breach notification, cross-border transfer mechanisms, compensation claims and administrative sanctions.
The PDP Law mandates an independent Personal Data Protection Authority (Lembaga PDP) reporting to the President, but it has not yet been formally established. In the interim, the Ministry of Communication and Digital Affairs (Komdigi), through its Directorate General of Digital Space Supervision, exercises supervisory and enforcement functions; a Presidential Regulation to formally establish the DPA is being finalized.
Data subjects are granted GDPR-style rights, including access, correction, deletion/erasure, withdrawal of consent, objection to automated decision-making, restriction of processing, data portability/interoperability, and compensation for damages arising from violations.
Transfers of personal data outside Indonesia are permitted only if the recipient country provides a level of protection equal to or higher than the PDP Law, or, failing that, if there is adequate and binding protection (e.g., standard contractual clauses, binding corporate rules) or the data subject's explicit consent.
Administrative sanctions include written warnings, temporary suspension, data erasure orders and administrative fines of up to 2% of a controller's/processor's annual revenue. Criminal penalties for offences such as unlawful collection, disclosure or use of personal data include imprisonment of up to 6 years and fines up to IDR 6 billion for individuals; corporations face fines multiplied up to IDR 210 billion (approx. US$14 million) plus profit confiscation, asset freezes or business closure.
Timeline - major decisions & events
The long-delayed implementing regulation (RPP PDP) and the Presidential Regulation establishing Indonesia's Personal Data Protection Agency entered the harmonization stage at the Ministry of Law in October 2025, with the agency targeted to become operational in 2026; until then the Ministry of Communication and Digital Affairs handles supervision.
Chambers and Partners โThe grace period under Law No. 27/2022 expired, so all data controllers and processors must now fully comply with the PDP Law and face administrative and criminal sanctions for breaches, even though the dedicated supervisory authority is not yet operational.
DLA Piper Data Protection Laws of the World โA LockBit 3.0-variant ransomware attack on Indonesia's temporary National Data Centre disrupted 282 public services including immigration, with attackers demanding US$8 million; the government refused to pay and the breach exposed that only ~2% of hosted data was backed up.
GovInsider โPresident Joko Widodo signed the second revision of the Electronic Information and Transactions Law, refining provisions on electronic systems, content, and criminal penalties that had drawn criticism for chilling online speech.
SSEK Law Firm โA threat actor exfiltrated and offered for sale a database of roughly 252 million voter records from the General Elections Commission (KPU) ahead of the February 2024 presidential election, after employee credentials were compromised by infostealer malware.
Resecurity โIndonesia's first comprehensive data-protection law came into force, establishing data-subject rights, controller/processor obligations, special-category data rules, cross-border transfer requirements, fines up to 2% of annual revenue, and a mandate to create a national supervisory authority.
Library of Congress โHighly sensitive data (national ID/NIK, phone, email, address) tied to the state health-insurance agency BPJS Kesehatan was leaked and sold on Raid Forums; the National Police summoned BPJS executives, intensifying public pressure for a dedicated data-protection law.
Indonesian National Police โGR 71/2019 (replacing GR 82/2012) modernized rules for electronic system operators, mandated PSE registration for both public and private operators, eased data-localization for private operators, and set personal-data-protection and security obligations.
Global Compliance News โThe first dedicated personal-data-protection rule required written consent, encrypted storage, a minimum five-year retention, breach notification, and coordination with the ministry for cross-border transfers, the de facto framework until the PDP Law.
Ministry of Communication and Informatics (via DataGuidance) โThe first revision of the ITE Law added the concept of electronic system providers, a right to request deletion of irrelevant electronic information (right to be forgotten), content-blocking powers, and recalibrated criminal penalties.
Conventus Law โIndonesia's foundational digital-law statute recognized electronic documents and signatures and contained the country's earliest, limited personal-data provision (consent to use electronic personal data), forming the legal base later built upon by GR 71/2019 and the PDP Law.
Law No. 11 of 2008 (JICA translation) โIndonesia - other topics
Data & Privacy in other countries
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