Electronic System Operator Call to Compliance: 6 June 2026 Deadline for Submission of Child Protection in Digital World Self-Assessment

Issue 23, June 2026

At the outset of 2025, the Minister of Communication and Digital Affairs (“MOCDA”) has introduced a new obligation of child protection for all Electronic System Operators (“ESOs”) to implement. Following the issuance of the Government Regulation No. 17 of 2025 on Governance of Electronic System Operations in Child Protection (“PP Tunas”), the MOCDA subsequently issued the Minister of Communication and Digital Affairs Regulation No. 9 of 2026 (“MOCDA 9/2026”), serving as the implementing regulation of the PP Tunas itself.

Issued on 6 March 2026, through a short-noticed announcement, the MOCDA 9/2026 requires ESOs to submit the results of a self-assessment on the risk level of their products, services, and features in relation to children no later than 6 June 2026. This development reflects increased regulatory scrutiny over digital platforms and their compliance obligations, particularly in relation to child protection measures and platform governance requirements.

The key points ESOs should be aware of under these new requirements are set out below.

A. Risk Level Assessment of ESOs’ Products, Services, and Features in relation to Children

Self-assessment of risk level towards ESO’s Products, Services, and Features (“PSF”) are conducted to two types of PSF, which are:

1. PSF specifically designed to be used or accessed by children; or
2. PSF that may be used or accessed by children.

The MOCDA 9/2026 provides the indicators which shall be used during the ESOs’ risk level self-assessment, which consist of the following:

1. contact with unfamiliar or unknown individuals;
2. exposure to pornographic content, violent content, content harmful to life safety, and other content inappropriate for children;
3. the exploitation of children as consumers;
4. threats to the security of children’s personal Data;
5. causing addiction;
6. psychological health disorders affecting children; and
7. physiological disorders affecting children.

Furthermore, the MOCDA 9/2026 only recognizes two types of risk profiles resulting form the self-assessment result, which are the high-risk and low-risk. A risk profile will be classified as high-risk if at least one of the seven indicators carries a risk score exceeding 50%, while a risk profile will be classified as low-risk if all the seven indicators mentioned above are lower than or equal to 50%.

At present, there is no additional guidance beyond what is provided under the relevant Ministerial Regulation and MOCDA Decree. In practice, the MOCDA conducts its assessment based on the documents and information submitted by the ESO.

To support the self-assessment processes, MOCDA has also issued the MOCDA Decree No. 142 of 2026 (as amended). The decree provides components and assessment parameters applicable to each of the seven self-assessment indicators, as well as the forms to be completed by ESOs in relation to the risk level assessment of their PSF.

Following MOCDA’s approval of the self-assessment results, MOCDA, through the relevant Director General (currently the Director General of Digital Space Supervision and Personal Data Protection), will issue an official determination of the risk profile of the relevant ESO’s PSF.

B. Submission channel

To date, the online portal for the submission of self-assessment forms had not yet been launched. During this period, ESOs may submit their self-assessment forms and supporting documents either electronically via email to the Tunas Secretariat at sekretariat.tunas@komdigi.go.id or physically/offline to the MOCDA.

Based on our direct consultation with MOCDA, there are indications that the submission deadline may be extended. However, as this has not yet been formally confirmed, ESOs are encouraged to complete and submit their required documents by the current deadline of 6 June 2026.

C. Suggested approach for ESOs that are newly seeking registration in Indonesia

For ESOs that are newly seeking registration in Indonesia, we would generally suggest obtaining the Electronic System Registration Certificate (Tanda Daftar Penyelenggara Sistem Elektronik or “TDPSE”) first while simultaneously preparing the required self-assessment documents. Once the TDPSE has been issued, the ESO may proceed with the submission of the child protection self-assessment and supporting documents.

This approach is recommended as, although a TDPSE is not formally required as a prerequisite for the child protection submission process, in practice MOCDA uses the TDPSE for data synchronization purposes and may request it during the process.

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If you have any questions, please contact

1. Reagan Roy Teguh, Partner - reagan.teguh@makarim.com
2. Edward Jeremiah Maruli Sitorus, Associate - edward.sitorus@makarim.com
3. Auliya Yasyfa Anwar, Associate - auliya.anwar@makarim.com
4. Dante Deva Daniswara, Associate - dante.daniswara@makarim.com

_{M&T Advisory is a digital publication prepared by the Indonesian law firm, Makarim & Taira S. It informs generally on the topics covered and should not be treated as legal advice or relied upon when making investment or business decisions. Should you have any questions on any matter contained in M&T Advisory, or other comments in general, please contact us at the emails provided at the end of this article.}