AI Laws and Guidelines Around the World -Part 1: Indonesia-

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→AI Laws and Guidelines Around the World -Part 1: Indonesia-

AI Laws and Guidelines Around the World
-Part 1: Indonesia-

November 2025
One Asia Lawyers Group
AI Legal Practice Group
Yusuke Tomofuji, Lawyer (State of New York, USA)

1. Introduction

    More than a year has passed since the EU Artificial Intelligence Act (the “EU AI Act”) [1]was enacted in August 2024. The EU AI Act will enter into full effect two years after its enactment, and its main enforcement phase is scheduled to begin in August next year.

    However, regulatory approaches toward AI vary significantly across jurisdictions, and in many countries, legal developments and official guidelines remain fragmented or insufficiently disclosed.

    Going forward, One Asia Lawyers will provide periodic updates focusing on AI-related legislation and guidelines around the world, especially Asia. In this first edition, we highlight the current AI regulation in Indonesia.

2. Ministerial Circular No. 9/2023 on Ethical Guidelines for Artificial Intelligence

(1) Overview

  Although Indonesia does not yet have specific regulations governing the development or use of artificial intelligence, the Ministerial Circular on AI Ethics (No. 9/2023) issued in December 2023 by the Ministry of Communication and Informatics (now the Ministry of Communication and Digital Affairs) functions as a non-binding ethical guideline.

(2) Ethical Principles

  The Circular sets out nine ethical principles applicable to AI use (Article 6(b)), including:

• Inclusivity;
• Humanity;
• Security;
• Accessibility;
• Transparency
• Credibility and Accountability;
• Personal data protection;
• Sustainable Development and Environment; and
• Intellectual property rights.

(3) Principles Relating to Implementation and Responsibility

  In addition, the Circular sets forth principles to be observed by AI developers and operators. These principles are not accompanied by concrete compliance requirements or sanctions, but are expected to guide AI-related activities in Indonesia.

• Implementation Principles (Article 6(c)(1))
  • Implementation based on internal rules and ethical policies;
  • Implementation of training and human resources development;
  • Support of human activities;
  • Supervision by the government, organizers and users;
  • Use of AI to enhance creativity and efficiency; and
  • Protection of data privacy.
• Responsibility Principles (Article 6(c)(2))
  • Public interest protection;
  • Restrictions on AI-based policy-making;
  • Prevention of discrimination;
  • Promotion of innovation;
  • Compliance with laws and regulations;
  • Transparent provision of information; and
  • Risk management.

3. Summary

  Although Indonesia currently lacks binding regulations governing AI development and deployment, the above Circular serves as a reference framework.
  While the Circular is not legally enforceable, it establishes:
  (i) Ethical principles (e.g., humanity, security, transparency, and accountability),
  (ii) Implementation principles (e.g., implementation based on internal policies, training, and monitoring), and
  (iii) Responsibility principles (e.g., prevention of discrimination and risk management).

  The Circular remains at the guideline stage, but it may serve as the basis for future AI-specific legislation. Continued monitoring of regulatory developments is therefore advisable.

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[1] See our past newsletter on EU Ai Act here: https://oneasia.legal/en/5633