Indonesia: Data Protection

Investors of Mergers and Acquisitions (“M&A”) transactions in Indonesia should be mindful of key considerations that require close monitoring. In practice, M&A deals are risky due to regulatory and compliance requirements, particularly when they affect the licensing, reporting, corporate governance, and control structure of target companies.

As of the writing of these responses, there are no specific regulations governing artificial intelligence ("AI") in Indonesia. However, Law No. 11 of 2008 on Electronic Information and Transactions, as lastly amended by Law No. 1 of 2024 ("EIT Law") is specific in describing AI as an "Electronic Agent".

Indonesia's new Personal Data Protection Law ("PDP Law") is the country's first comprehensive law to govern personal data protection in both electronic systems and non-electronic systems.